second edition guidance manual - wbdgstructure of an asbestos o&m program. this manual offers...

An Authoritative Source of Innovative Solutions for the Built Environment

Second Edition

Guidance ManualAsbestos Operations & Maintenance Work Practices

National Institute ofBUILDING SCIENCES

1996

The National Institute of Building Sciences (NIBS) is a non-governmental, non-profit organization,authorized by Congress to encourage a more rational building regulatory environment and toaccelerate the introduction of existing and new technology into the building process.

This second edition was prepared with the support of U.S. General Services AdministrationContract No. GS11P94EGD0010. The original document was prepared with the support of U.S.Environmental Protection Agency Cooperative Agreement No. CX-817924-01-0 and U.S. GeneralServices Administration Contract No. GS11P91EGD0113.

Individual copies or bulk rate orders of this report are available from the National Institute ofBuilding Sciences. For pricing information contact:

The National Institute of Building SciencesPublications Department1201 L Street, N.W., Suite 400Washington, D.C. 20005-4014202/289-7800 FAX 202-289-1092e-mail: [email protected]: www.nibs.org

This report can also be ordered using VISA or Master Card by calling NIBS with the followinginformation: the card account number, the expiration date, the name as it appears on the card.

Copyright ©. 1996 by the National Institute of Building SciencesAll rights reserved. Reproduction of this document, in whole or in part, by any means, such as byany mechanical, photographic, or electronic process, or utilization of this document other than in itsoriginal form, such as by phonographic or tape recording, storage in a retrieval system ortransmission for public or private use, or copying all or portions of this document for resale orredistribution, without written permission from the National Institute of Building Sciences is strictlyprohibited, except as follows:

1. The purchaser of this document may make one copy of all or selected portions ofthis document solely for the purpose of developing and implementing one sitespecific O&M manual for operations and maintenance programs, procedures, orwork practices for buildings owned by such purchaser.

2. Designers and consultants who purchase this document for the purpose ofdeveloping an owner specific O&M manual for a client may make one copy of all orselected portions of this document if the document is turned over to the client in itsentirety along with the one site specific O&M manual for a building(s) owned bythe client. In such cases, the designer or consultant shall provide the name, address,telephone number and individual contact for the client to NIBS in writing.

Permission to reproduce this document under any other terms and conditions may be requested bycontacting the National Institute of Building Sciences Publications Services at the above address.

NIBS Document Number - 5176-7

NIBS Document Number - 5176-7

DISCLAIMER

The Guidance Manual: Asbestos Operations & Maintenance Work Practices wasdeveloped in response to a pressing national need for guidance on managing in-placeasbestos-containing materials in buildings. The Guidance Manual was drafted by aqualified independent contractor, and subjected to several iterations of review,modification, and refinement by a National Institute of Building Sciences (NIBS),project committee composed of representatives from a broad cross section ofknowledgeable professionals from the building and environmental communities. During the review process and the subsequent ballot approval process the projectcommittee followed consensus rules set forth in the Rules and Procedures of theNIBS Consultative Council.

The National Institute of Building Sciences, the members of the NIBS ProjectCommittee, the project contractor, the funding agencies, and their employees orrepresentatives make no warranty, guarantee, or representation, expressed, orimplied, with respect to the accuracy, effectiveness, or usefulness of anyinformation, method, or material in this document. Nor do they assume any liabilityfor the use of any information, methods or materials contained herein, or fordamages arising from such use; nor assume any responsibility for any injury toindividuals or property, or for any financial loss, sustained as a result of the use orapplication of the Guidance Manual.It should be noted that:

- Operations and maintenance activities involving asbestos-containing materialsmay involve health risks to those performing them or in proximity to thelocation of the work.

- Experts from the building, scientific, and environmental communities havediffering views as to many aspects of proper management of in-place asbestos-containing materials. The purpose of this document is to bring together, frommany sources, information and viewpoints reflecting current knowledge andtechnology.

The Guidance Manual must be considered solely as a resource documentrepresenting a consensus of expert opinion. The Manual does not purport torepresent the views, policies, or position of the U.S. Environmental ProtectionAgency, the U.S. General Services Administration, or any other agency of thefederal government, or any participant in the development of the document.

It is intended that the document serve as a guide for building owners, employers,managers, consultants, and others in developing asbestos O&M programs and forworkers who implement such programs. It is not the purpose or burden of thisdocument to provide all-embracing answers to every problem related to managingin-place asbestos-containing materials. Users bear all risks associated with relianceon these work practices and shall have the sole responsibility to evaluate theinformation contained herein, to form their own independent judgments on the useof the Guidance Manual, and to modify or adapt it as may be appropriate to specificcircumstances.

These Asbestos Operations & Maintenance Work Practices are neither laws norregulations. While this document refers in some cases to certain federal and statelaws and regulations, it is not intended to supersede or supplement any law orregulation or to identify all laws and regulations applicable to management ofasbestos in buildings.

NIBS does not assume responsibility for the currency of referenced documents,requirements, or other provisions included or identified in the Guidance Manual.

P - 1 # Preface # Asbestos O&M Work Practices # © NIBS 1996 # Page - i

PREFACE

The National Institute of Building Sciences (NIBS) is pleased to publish this documentGuidance Manual: Asbestos Operations & Maintenance Work Practices, SecondEdition for use by those engaged in building operations and maintenance activitiesinvolving asbestos.

The Institute would like to acknowledge the financial support provided by the U.S.General Services Administration for the development of this document which is aregulatory update of the first edition. Financial support was provided by the U.S.Environmental Protection Agency and the U.S. General Services Administration for thedevelopment of the original document.

The NIBS Board of Directors appreciates the outstanding leadership of Mr. Ralls C.Melotte, AIA, of Analytical Design Group, Inc., who served as chairman of the NIBSproject committee, Casimer Szewczak of the Navy Environmental Health Center, whoserved as vice-chairman, and Robert J. DeFrank of the University of Maryland, whoserved as secretary. Also, the Institute wishes to acknowledge the excellent professionalservices provided by the Institute's contractor, Roger G. Morse, AIA. Most importantly,the Institute wishes to acknowledge and thank the members of the project committee fortheir exceptional and untiring efforts that were necessary to carry out this assignment.

NIBS' manual was envisioned from the outset as a companion to the EPA documentManaging Asbestos In Place, also known as the "Green Book," which describes thestructure of an asbestos O&M program. This manual offers specific, detailed technicalguidance to building owners, asbestos program managers, and building workers foractivities that involve working near or on asbestos-containing materials. It does notquantify or explain the health risks associated with asbestos but is structured in responseto the potential for exposure which might be encountered. Such a guidance manualwould not have been contemplated if health risks did not exist.

It incorporates, not only the collective knowledge and experience of a broad cross-sectionof experts, but also the value of their unique perspectives in the building and operationmanagement process. The procedures set forth in the manual represent a currentcharacterization of continually evolving practices and technology. Standards andregulations for asbestos activities also continue to evolve and change. The projectcommittee considered a broad range of issues including, compliance with federal, state,and local regulations, varied and evolving standards of care within the industry, and avariety of concerns of building owners and managers relating to economic objectives,company-specific environmental policies, and liability issues.

It is neither intended nor appropriate for this guidance manual to be used for regulatorypurposes. It was purposely structured so that responsibilities for decisions relating tolevels of precaution and stringency within each specific building O&M program remainwith the responsible building owner or employer.

It is expected that the work practices in this manual will be refined and continuallyimproved as they are used in a wide array of O&M programs in numerous and varied

P - 2 # Preface # Asbestos O&M Work Practices # © NIBS 1996 # Page - ii

building situations. The Institute encourages feedback from users of the manual as to theeffectiveness of these work practices in order to improve its response to the likely needfor revisions.

The manual is a consensus document. One hundred and sixteen professionals andspecialists from across the spectrum of the building and environmental communitieshelped to produce the guidance it offers. It is intended that building owners, managers,designers, environmental consultants, and maintenance and custodial workers and theiremployers, avail themselves of this reference tool to help them effectively manage theasbestos-containing materials in their buildings while protecting workers and occupants.

The Institute's Board of Directors recognizes and appreciates the extensive and highlyprofessional effort and expertise that went into this document and is especially grateful tothe members of the project steering committee who worked diligently to coordinate thedevelopment of the manual. A valuable public service has been performed by theInstitute's Asbestos Project Committee and others who contributed to this superior effort.

Gerald H. Jones, P.E. David A. Harris, FAIAChairman of the Board President

TOC - 1 # Table of Contents # Asbestos O&M Work Practices # © NIBS 1996 # Page - iii

Table of ContentsI. Initiating an O&M Program

1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32. Elements of an O&M Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73. O&M Work Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 154. Design O&M Work Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 255. Use of O&M Work Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

II. Asbestos Program Manager General Procedures APM Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44APM1 Selection of Personal Protective Equipment &

Decontamination Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46APM2 Work Scheduling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47APM3 Federal, State and Local Notification . . . . . . . . . . . . . . . . . . . . . . . . . . . 47APM4 Notification of Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48APM5 Assigning Workers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48APM6 Developing the Air Monitoring Program and Assigning

Air Monitoring Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49APM7 Record keeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51APM8 Confined Spaces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51APM9 Selection of Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52APM10 Emergency Work and Dry Removal . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

III. Worker General ProceduresLevel A Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58Level B Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59Level C Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60W1 Tools, Equipment and Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61W2 Preparing Amended Water or Removal Encapsulant . . . . . . . . . . . . . . . 61W3 Shut-off and Lockout of HVAC and Electrical Systems . . . . . . . . . . . . 62W4 Securing Work Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62W5 Critical Barriers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62W6 Putting on Respirators and Performing Fit Checks . . . . . . . . . . . . . . . . . 63W7 Putting on Protective Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63W8 Beginning and Conducting Air Monitoring . . . . . . . . . . . . . . . . . . . . . . 64W9 Precleaning Work Areas and Wet Wiping . . . . . . . . . . . . . . . . . . . . . . . 65W10 Polyethylene Drop Cloth . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66W11 Packaging and Labeling Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66W12 Applying Lockdown Encapsulant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68W13 Cleaning Tools, Equipment and Work Area . . . . . . . . . . . . . . . . . . . . . . 68W14 Decontaminating Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69W15 Worker Decontamination and Removal of Protective Clothing

and Respirators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69W16 Visual Inspection and Completing Air Monitoring . . . . . . . . . . . . . . . . . 70W17 Waste Transportation, Storage and Disposal . . . . . . . . . . . . . . . . . . . . . 71W18 Glovebag Removal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71W19 Disposal of Contaminated Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74W20 Mini-enclosures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74

TOC - 2 # Table of Contents # Asbestos O&M Work Practices # © NIBS 1996 # Page - iv

IV. Surfacing Materials Work PracticesSurfacing Materials Location Illustration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78Code Levels DescriptionS1 A B C Moving one non-asbestos-containing ceiling panel

below a plenum space that has exposed surfacing ACM . . . . . . 87S2 A B Attach component to an ACM finished surface that is

above a non-asbestos-containing ceiling . . . . . . . . . . . . . . . . . . 95S3 B C Remove a small amount of ACM surfacing above a ceiling . . . 99S4 A B C Work in ceiling plenum space where exposed surfacing

ACM is present . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105S5 A B C Install wiring in plenum space where exposed surfacing

ACM is present . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 113S6 A B C Attach item to ceiling finished with ACM . . . . . . . . . . . . . . . . 121S7 A B C Repair or replace item in surface finished with ACM . . . . . . . 129S8 B C Cut or drill hole in surfacing ACM . . . . . . . . . . . . . . . . . . . . . 136S9 A B Replace bulbs in light fixture attached to or in surface

finished with ACM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 141S10 A Clean room with exposed surfaces finished with ACM . . . . . . 145S11 A B C Repair damaged surfacing ACM . . . . . . . . . . . . . . . . . . . . . . . 147S12 A B C Accessing through an ACM finished surface . . . . . . . . . . . . . . 152S13 A B C Painting surfacing ACM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 158

V. Thermal Systems Insulation (TSI) Work PracticesThermal Systems Insulation Location Illustration . . . . . . . . . . . . . . . . . . . . . . . . 164Code Levels DescriptionT1 B C Remove asbestos-containing insulation on exposed

pipe for maintenance work . . . . . . . . . . . . . . . . . . . . . . . . . . . . 170T2 B C Remove asbestos-containing insulation on

pipe above ceiling for maintenance work . . . . . . . . . . . . . . . . 177T3 B C Remove asbestos-containing insulation on exposed

pipe in elevated location for maintenance work . . . . . . . . . . . 185T4 B C Remove asbestos-containing insulation on pipe in

occupied area for maintenance work . . . . . . . . . . . . . . . . . . . . 193T5 A B C Repair damaged asbestos-containing insulation

on a pipe . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199T6 B C Repair damaged asbestos-containing insulation on a

boiler, duct or flue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 205T7 B C Install device in, or access surface of, asbestos-containing

insulation on a pipe, boiler, duct or flue . . . . . . . . . . . . . . . . . 210T8 B C Remove asbestos-containing duct insulation

above ceiling for maintenance work . . . . . . . . . . . . . . . . . . . . 215T9 B C Remove asbestos-containing insulation inside HVAC

unit for maintenance work . . . . . . . . . . . . . . . . . . . . . . . . . . . . 221T10 B C Clean up asbestos-containing debris in crawlspace

or tunnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 227

TOC - 3 # Table of Contents # Asbestos O&M Work Practices # © NIBS 1996 # Page - v

VI. Miscellaneous Materials Work PracticesMiscellaneous Materials Location Illustration . . . . . . . . . . . . . . . . . . . . . . . . . . . 234Code Levels DescriptionM1 A B Clean potentially asbestos-contaminated carpet . . . . . . . . . . . 240M2 A B C Remove asbestos-containing ceiling panels in

lay-in ceiling system . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 243M3 B C Remove asbestos-containing ceiling tiles attached

with adhesive . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 247M4 B C Remove asbestos-containing ceiling tiles in

spline ceiling system . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 250M5 B C Cut or drill asbestos cement panels . . . . . . . . . . . . . . . . . . . . . 253M6 A B C Remove asbestos cement panels . . . . . . . . . . . . . . . . . . . . . . . 257M7 A B Remove asbestos cement cooling tower louvers . . . . . . . . . . . 261M8 A B Remove or replace asbestos cement roof shingles . . . . . . . . . 264M9 A B Remove and replace asbestos cement siding shingles . . . . . . . 269M10 A B C Remove high-temperature resistant (HTR)

asbestos cement panels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 272M11 A B C Remove asbestos-containing chalk board . . . . . . . . . . . . . . . . 276M12 A B C Remove asbestos-containing fire door

and/or door hardware . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 280M13 A B Remove asbestos-containing built-up roofing . . . . . . . . . . . . . 285M14 A B Remove asbestos-containing asphalt shingles . . . . . . . . . . . . . 289M15 B C Cut or drill asbestos-containing drywall, plaster

or drywall compound . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 294M16 B C Remove section of asbestos-containing drywall . . . . . . . . . . . 300M17 A B C Remove asbestos-containing flexible duct connector . . . . . . . 305M18 A B C Remove asbestos-containing paper or cloth from ductwork . . 310M19 B Remove filters from HVAC unit . . . . . . . . . . . . . . . . . . . . . . . 315M20 B Clean up debris . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 317M21 A B C Replace asbestos-containing gaskets/packing . . . . . . . . . . . . . 320M22 B C Emptying and changing filter in HEPA vacuum or

changing filter in HEPA fan unit . . . . . . . . . . . . . . . . . . . . . . . 328M23 A B C Remove asbestos-wrapped wiring . . . . . . . . . . . . . . . . . . . . . . 332M24 A B C Removing asbestos-containing caulking compound . . . . . . . . 339M25 A Clean room that has asbestos-containing dust . . . . . . . . . . . . . 343

TOC - 4 # Table of Contents # Asbestos O&M Work Practices # © NIBS 1996 # Page - vi

VII. Resilient Flooring Work PracticesResilient Flooring Materials Location Illustration . . . . . . . . . . . . . . . . . . . . . . . . 348Code Levels DescriptionR1 A B+ Replacement of resilient asbestos floor tiles . . . . . . . . . . . . . . 360R2 A B+ Replacement of vinyl sheet flooring with ACM backing . . . . 370R3 A Install new resilient flooring or carpet over resilient

asbestos flooring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 377R4 A B+ Install partition over resilient asbestos flooring . . . . . . . . . . . . 379R5 A Wet strip floor wax from resilient asbestos flooring . . . . . . . . 382R6 A Dry or spray buffing resilient asbestos flooring . . . . . . . . . . . . 385R7 A Cleaning resilient asbestos flooring . . . . . . . . . . . . . . . . . . . . . 388R8 A B+ Remove carpet over resilient asbestos flooring . . . . . . . . . . . . 391

AppendicesAppendix A - Job Request Form for Maintenance Work . . . . . . . . . . . . . . . . . 399Appendix B - Maintenance Work Authorization Form . . . . . . . . . . . . . . . . . . . 401Appendix C - Evaluation of Work Affecting Asbestos-Containing Materials . 403Appendix D - Waste Tracking Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 405Appendix E - Resilient Flooring Covering Form . . . . . . . . . . . . . . . . . . . . . . . 407Appendix F - Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 411Appendix G - References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 417Appendix H - General Safety Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . 420Appendix I - Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 425Appendix J - NIBS Feedback Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 463

Index to IllustrationsFigure 1 - Guidelines for 3 Levels of Work Practices . . . . . . . . . . . . . . . . . . 21Figure 2 - OSHA Requirements for Work Practices for Resilient

Floor Covering Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24Figure 3 - Work Practice Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41Figure 4 - Asbestos Program Manger Checklist . . . . . . . . . . . . . . . . . . . . . . 44Figure 5 - Level A Worker Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58Figure 6 - Level B Worker Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59Figure 7 - Level C Worker Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60Figure 8 - Surfacing Materials Location Illustration . . . . . . . . . . . . . . . . . . . 78Figure 9 - Thermal System Insulation Location Illustration . . . . . . . . . . . . 164Figure 10 - Miscellaneous Materials Location Illustration . . . . . . . . . . . . . . 234Figure 11 - Resilient Flooring Location Illustration . . . . . . . . . . . . . . . . . . . 348

I. Initiating an O&M Program

1 - 1 # Introduction # Asbestos O&M Work Practices # © NIBS 1996 # Page - 3

1. IntroductionGeneral This Guidance Manual: Asbestos Operations and Maintenance(O&M) Work Practices has been preparedto provide guidance on worker protection,basic O&M procedures, O&M cleaningpractices, and procedures for respondingto minor asbestos fiber release episodes infacilities with asbestos-containing material(ACM). This manual has been preparedby a National Institute of BuildingSciences' (NIBS) committee under anassistance agreement between NIBS andthe U.S. Environmental Protection Agency(EPA) and the General ServicesAdministration (GSA). The projectcommittee has prepared the manualfollowing the rules of the NIBS consensusprocess. This process provides anopportunity for representatives from allsectors of the building community toparticipate in the development andapproval of the document.

The NIBS Consultative Council throughits Operations Committee has approvedthe composition of the project committeefor balanced representation and expertise,and has provided oversight of the projectactivities to insure conformance with theNIBS consensus process and has acceptedthe final report of the project committee.

Scope and Flexibility The workpractices described in this manual areapplicable to repair, maintenance andcleaning operations where asbestos-containing material (ACM) or presumedasbestos-containing material (PACM)including thermal system insulation,surfacing, resilient flooring or othermiscellaneous asbestos-containingmaterials are involved. The workpractices are intended to assist in meetingthe current OSHA regulations applicableto O&M work. Appendix I of this manualdescribes the specific requirements of the

OSHA Regulations relative to asbestosO&M work.

Work practices in this manual are notintended for dedicated asbestos abatement,but rather to control disturbance ofasbestos during repair, maintenance, orcleaning. These activities are by natureshort in duration and small in scale. Theamount of ACM disturbed by any O&Mactivity should be limited. Projects producing more waste than will fit in asingle 60 inch X 60 inch waste bag, aswell work falling outside OSHA’s O&Mwork classifications, should be performedin accordance with generally recognizedasbestos control techniques, such as thosedescribed in NIBS' Asbestos Abatementand Management in Buildings: ModelGuide Specifications. These O&M workpractices are not to be used for activitiesrequiring abatement of ACM.

This manual is intended for use by adesigner of an asbestos O&M program,which will be implemented by anAsbestos Program Manager (APM) andtrained workers. The APM may designthe program as well as implement it. Thetitle “Asbestos Program Manager” is usedthroughout, however, other titles can beused by individuals holding similarresponsibilities.

The manual provides checklists and step-by-step work practices which might beused by an O&M program designer todevelop facility specific work practices forworkers performing O&M work. Becauseasbestos in buildings is present underwidely varying circumstances including,but not limited to, its condition, location,material type, friability, and accessibility,a range of guidance for commonoperations and maintenance procedures isoffered in this manual. The projectcommittee determined that flexibility iscrucial to the efficient and cost effective


completion of an O&M activity. Thisleaves the ultimate choice of methods toon-site personnel who have first-handknowledge of the asbestos material,facility conditions, and other pertinentneeds. These work practices were writtenwith the knowledge that there might bealternate procedures or equipment beyondthose in this manual that will adequatelyaccomplish O&M objectives. The projectcommittee encourages the developmentand application of new and innovativeequipment and safe, cost effectiveprocedures for O&M work.

The work practices included in the manualare based on practices known to thecommittee. Many of these work practiceswere in use when the manual was written. However, exposure data is not availablefor many of the work practices. Duringdevelopment of work practices for afacility the program designer will need toperform an exposure assessment for eachwork practice. Generally, this exposureassessment will involve exposuremonitoring. This monitoring is necessaryto comply with OSHA requirements, andto demonstrate compliance with the O&Mprogram’s goals for airborne asbestosexposure if more stringent than OSHA. Exposure monitoring may not benecessary if there is already sufficient dataavailable for a negative exposureassessment as required by OSHA (Forexample, see section R, “ResilientFlooring Work Practices”). Also, initialmonitoring may not be required forhousekeeping activities governed by thegeneral industry standard (1910.1001)where a determination has been made thatthe activities are not reasonably expectedto result in exposures at or above theTWA permissible exposure limit and/orexcursion limit (refer to Section VIIResilient Flooring and Appendix I

regulations for more information). Thework practices in this manual are not theonly successful methods currentlyavailable or in use, but were judged by thecommittee to be applicable to a wide rangeof common situations. Preventativemeasures that provide protection forundamaged ACM might be installed inconjunction with the O&M activitiescovered by this manual. A feedback formis included in Appendix J to allow users toprovide alternate work practice proceduresand comments to NIBS.

Different recommendations, referred to aslevels, of the same work practice areprovided to give examples of differentlevels of effort that can be applied to agiven task. This may be necessary toaccommodate for variations in the typeand condition of the ACM to be workedon, the building conditions in which theACM is located, the skill level of workers,and the exposure goals of the O&Mprogram. It is assumed that varyingconditions will necessitate different workpractice levels to accomplish the samebasic task. Selection of the appropriatelevels upon which to base facility specificwork practices should be made by theO&M program designer for each specificmaterial based upon the conditionseffecting that material. In addition,generally accepted good constructionwork practices should be used for allaspects of O&M activities. Riskassessments and liability concerns mightalso influence the selection of the level fora specific work practices.

Assumptions The manual has beendeveloped on the assumption that, at aminimum, all asbestos O&M work will bedone in accordance with applicableregulations by persons with a general


training in managing asbestos and O&Mmethods in particular. It is important toemphasize that this is a guidancedocument only, and is not now, nor everintended to be used for regulatorypurposes. This manual is not intended tosupplant work practices already in placeand being successfully applied.

Likewise, it must be emphasized that usersof this manual are expected to modify (incompliance with applicable regulations)the guidance provided here to suit theirunique circumstances. For example, asstated elsewhere, the forms included in themanual must be modified to accommodatethe operations and circumstances of thespecific facility. Work practices will needto be updated based on data from pastwork, new equipment developments orother unique situations. This manualoffers guidance only. The user mustverify the success of whatever workpractices are used. The development ofinnovative and creative new equipmentand procedures that work safely andeffectively for performing O&M activitiesis encouraged.

EPA Green Book This manual isintended as a companion volume to theguide Managing Asbestos in Place("Green Book") issued by the EPA in July,1990. The Green Book explains theobjectives and administrative proceduresfor an O&M Program. This O&M WorkPractices Manual provides the basis fordevelopment of detailed procedures forconducting O&M work involving ACM,such as maintenance, repair and minorrenovation work. Information presentedin the Green Book is not repeated in thisguide but is referenced where appropriate.

Statutory & RegulatoryRequirements There are a number offederal regulations that must be compliedwith during O&M operations. State andlocal regulations, which might be the sameas, equivalent to, or more stringent thanfederal regulations, might also apply. These will influence the design of theO&M program and the O&M workprocedures. This manual deals only withfederal regulations. The O&M designerand APM must determine the effect ofstate and local regulation. The majorfederal regulations that effect O&M workare listed below and discussed in moredetail in Appendix I.

1. OSHA's asbestos construction andgeneral industry, construction safety,personal protection and hazardcommunication standards

2. National Emission Standards forHazardous Air Pollutants (NESHAP)

3. Asbestos Hazard EmergencyResponse Act (AHERA)

4. Asbestos School Hazard AbatementReauthorization Act (ASHARA)

5. EPA Worker Protection Rule (WPR)

6. Department of Transportation'shazardous waste transportationstandards

EPA Guidance Documents1. Asbestos in Buildings: Simplified

Sampling Scheme for FriableAsbestos Materials ("Pink Book")

2. Guidance for Controlling Asbestos-Containing Materials in Buildings


("Purple Book")3. A Guide to Respiratory Protection for

the Asbestos Abatement Industry("White Book")

A list of references, including the

regulations and guidance documents listedabove, is given in Appendix G of thismanual.

2 - 1 # Elements of an O&M Program # Asbestos O&M Work Practices # © 1996 # Page - 7

2. Elements of an O&MProgramThe overall frame work for an asbestosO&M program is described in the EPAguidance document “ Managing Asbestosin Place (Green Book).” Operationally,an asbestos O&M program consists ofadministrative procedures which causespecific work practices to be used formaintenance work on asbestos-containingmaterials (ACM). This manual containssuggestions for work practices to be usedin such an O&M program. To insure thatthe work practices are applied as intendedit is necessary to set up an administrativeframe work. This frame work need not becomplex. In fact, the more simple andstraightforward the administration of theprogram, the more likely it is that it willperform reliably. There are severalelements necessary for a successful asbestos O&M program.

Definition of Scope Before theprogram can begin, the type, locations andcondition of ACM to be controlled by theprogram must be determined. This can beaccomplished by an inspection, or bypresuming that all materials suspected ofcontaining asbestos are indeed asbestos-containing. Unless an inspection isperformed and the materials aredetermined not to contain asbestos, OSHArequires that all thermal system insulation,sprayed or troweled on surfacingmaterials, and resilient flooring materialinstalled no later than 1980 be presumedto contain asbestos. In addition, OSHArequires that materials known to containasbestos, or that should have been knownby exercise of due diligence, also beidentified. The Asbestos School HazardAbatement Reauthorization Act(ASHARA) requires that all inspections ofcommercial and industrial buildings as

well as schools be performed by an EPA-accredited asbestos inspector. (Theaccredited inspector requirement does notapply to visual or physical examinationsof resilient floor covering material whenconducted as part of the process ofreplacing an existing floor where thematerial has not been sanded, ground,mechanically chipped, drilled, abraded orcut.) The first step in the initiation of anasbestos O&M programs is the preparationof an inventory of ACM or presumedasbestos-containing materials (PACM).

Policy and Organization Toinsure success, there needs to be a formaldecision at the topmost level ofmanagement adopting the asbestos O&Mprogram as a matter of policy. This givesthe program legitimacy within theorganization and insures that the asbestosprogram manager (APM) will be givenadequate authority to implement theprogram. A specific administrativeposition must be given the responsibilityfor the asbestos O&M program. It is bestif this position already has the authoritynecessary to implement the program. Thisposition must have effective control overactivities that could impact on the ACM inthe facility. At a minimum, this positionneeds to have control over internalmaintenance and cleaning personnel,outside maintenance contractors andrenovation projects. In most organizationsthis person is the head of buildings andgrounds or the facilities manager. Otherwise well conceived controlprograms have failed because theadministrative position implementingthem had inadequate authority. This mosttypically occurs when the safetydepartment is given the responsibility, but


not given adequate authority.

Program Administration Therewill already be administrative controls inplace for other purposes over internal andexternal personnel working on a facility. It is usually a simpler matter to add to orslightly modify these existing controlsthan to invent and administer entirely newones. For example, if a facility uses awork order system, work orders for workon ACM could contain a notificationabout the ACM and reference to theappropriate work practice. Standardizedpurchase order forms for outsidemaintenance work on asbestos-containinginstallations can be developed. Theissuing of work orders and purchaseorders can be handled in the same mannerand by the same people already involvedin non-asbestos facility maintenance. Theforms provided in this manual giveexamples of the kinds of informationusually required for an asbestos O&Mprogram. These forms should be freelymodified and adapted to existingpaperwork systems.

Documentation Questions can ariseabout regulatory compliance or programeffectiveness. This can result from a visitfrom OSHA or the EPA; or questions fromstaff or their collective bargaining agents. It is useful if the administration of theprogram is set up so that it generatesdocumentation to respond to thesequestions. A documentation system doesnot need to be elaborate. It simply needsto keep the work orders, purchase orders,exposure monitoring and air testing resultsin a common location. Usuallydocumentation will be needed for thefollowing:

Program Operation: The activities of

the program should be documented. These include documentation of the use ofwork practices, personnel, areas andsystems involved.

Program Effectiveness: The level ofconsistency with which control methodsare used should be documented. The levelof isolation provided to controlled areasshould be documented. Air sample resultscollected during work and background airsampling conducted on a periodic basis todocument the overall effectiveness of thecontrol methods used should bemaintained.

Material Inventory: At the beginning ofthe program, an inspection should beconducted, resulting in an inventory ofACM or PACM. During the course of theasbestos O&M, a great deal of detailconcerning the location and condition ofthese materials will be generated as workis performed. This information should beintegrated in the ACM inventory. AsACM is removed the inventory should beupdated. This will prevent theunnecessary expense of applying controlsto non-ACM.

Regulatory Compliance: The buildingowner is required to comply with OSHA,EPA NESHAPS, and perhaps state andlocal regulations. The documentationshould be adequate to demonstratecompliance with all applicable regulations. OSHA specifically requires maintenanceof the following records: objective data, ifrelied on; exposure measurements;medical surveillance; training records;evidence used to rebut PACM; andrequired notifications.

The documentation is used to evaluate andimprove the O&M program. To beeffective, the system of documentation


should grow out of existing procedures. For example in a facility that uses a paperwork-order system, if different coloredwork-orders are used for asbestos O&Mwork, it is possible to tell at a glance ifO&M procedures were applied to all workon ACM.

Controlled Areas, Systems Thebasic administrative method ofimplementing an asbestos managementprogram is to establish controlled areasand systems. These are areas or systemsthat are to be accessed or worked on onlywith the proper controls. These controlsconsist of specific work practices appliedby trained personnel.

Controlled Areas: Where ACM is in anarea to which access can be controlled,disturbance of the ACM can be avoidedby controlling this access. The area isdesignated as “Controlled.” Onlyindividuals with the proper training areallowed access into the “Controlled Area.” This training can be as simple asawareness training that informs a workerabout the location of the ACM andinstruction to avoid contact with it. Insome instances entry into the controlledarea may require specific work practicesto protect the workers and the buildingenvironment. Examples of controlledareas include: spaces above suspendedceilings where there is asbestos-containingfireproofing or pipe insulation, andmechanical areas with ACM where accessis limited to personnel that have beentrained. A sign should be posted at theentrance to all mechanical rooms/areaswhich contain ACM or PACM . The signshould identify the materials present, theirlocation, and appropriate work practices toensure that the material will not bedisturbed. This sort of signage is required

by the OSHA construction standard (29CFR 1926.1101(k)(6)) which governsmost O&M maintenance activities (seeAppendix I for more information onOSHA requirements).

Controlled Systems: Building systemsthat contain asbestos should be designatedas controlled systems. Examples include:fireproofing that contains asbestos that issprayed or troweled on structuralmembers, pipe insulation fabricated frommaterials that have been identified andinventoried as containing asbestos,equipment insulation on boilers,breechings, tanks, converters and relatedequipment that has been identified ascontaining asbestos. Contact with a“Controlled System” should be allowedonly for individuals with the propertraining. If the ACM is intact, non-friable,encapsulated, or enclosed, this trainingcan be as simple as awareness training thatinforms the individual about the locationsof the ACM and instructions to avoiddisturbance of it. Work that involves thedisturbance or potential disturbance ofACM requires specific work practices(such as those in this manual) applied byindividuals with adequate training. TheOSHA construction standard, whichgoverns most O&M maintenanceactivities, requires that, where feasible,labels be affixed to notify employeesabout ACM or PACM (29 CFR1926.1101(k)(8)(vii)) .

Work Practices Specific workpractices are used to enter a controlledarea or work on a controlled system. These procedures are designed to protectworkers and control the release of airborneasbestos, material and debris when the


area or system is disturbed. To be useful,the work procedures must be simple andquick enough to permit practicalmaintenance of the building. This manualcontains a number of work practices thatare thought to be useful for asbestos O&Mprograms. In addition, the NationalInstitute of Building Sciences ModelGuide Specification for AsbestosAbatement & Management in Buildingscontains procedures in specification formfor contracted O&M work.

O&M programs should always emphasizethe use of careful handling to avoidunnecessary disturbance of asbestos; andwetting, local collection and local exhaust,etc. to control disturbance of ACM. Workprocedures, or modifications to these workpractices, should be designed inaccordance with the airborne asbestosgoals of the owner and/or employer, thecircumstances of the particular building,and the skill and training of the APM andworkers.

Work practices need to be designed for theparticular circumstances of a facility. Theeffectiveness of the work practice inprotecting workers and the environmentneeds to be demonstrated throughexposure monitoring. Typically, a workpractice will be tested and exposuremonitoring collected. The work practiceshould be modified and retested until itreaches the exposure goal of the facility.

Training The program should be setup so that only trained workers contactasbestos containing materials. Thenecessary training for activities thatshould contact asbestos includes not onlyclassroom training but also hands-ontraining specific to the work to be

performed. All workers who couldcontact or disturb ACM should receiveawareness training and be advised to avoiddisturbance of ACM and PACM. TheAsbestos Program Manager whoadministers the O&M should be trained asrequired for a competent person andinspector. Refer to Appendix I“Regulations” for more information ontraining requirements.

The amount and content of workertraining must meet OSHA and EPAminimums and should correspond to thetype, condition and quantity of ACM thatthe custodial and/or maintenance staff willencounter in the course of their work. Training should emphasize hands-onmethods. The workers should learn howto use the O&M plan as well as to performspecific tasks. In addition to specific workpractices, there are general subject areasthat all O&M training should include,such as personal protective equipment andrespirator training where applicable, thehealth risks associated with asbestosexposures, and the vital importance ofcarefully adhering to building O&Mprograms. State and local regulations mayalso impose training requirements forO&M activities and these requirementsmay differ from and some may be morestringent than the federal requirements.

The APM should have training sufficientto perform inspections and identify whereasbestos will be encountered; assess thecondition of ACM; evaluate potentialexposure; understand building compo-nents, building systems, and buildingusage patterns; administer O&Mactivities; be familiar with cleaning andmaintenance tasks; understand applicablelaws and regulations; and be aware ofother crucial factors associated with anO&M program. The APM in a school,


commercial or public building who will beinspecting for ACM must be trained andaccredited as required by AHERA (40CFR 763 Appendix E to Subpart C. AtI.B.3).

The direct supervisor of O&M workersneeds to be a Competent Person as definedby OSHA. See Appendix I “Regulations”for information on training requirementsfor competent persons. In addition thegeneral requirements for a competentperson specified in the OSHA regulation(29 CFR 1926.32) must be met. If theO&M program involves mini-enclosures,the competent person should also haveasbestos abatement worker training. Under the general industry standard, acompetent person is not required foractivities such as housekeeping.

The AHERA regulation for schoolsincludes required O&M training andoutlines a minimum training program. EPA recommends this training for allO&M workers.

Most O&M activities in this manual aregoverned by the OSHA constructionstandard. This standard containsminimum training requirements forconstruction workers (including thoseinvolved in O&M activities) based uponthe class of work involved. Minimumtraining requirements are set forth forworkers involved in Class I work (theremoval of asbestos-containing thermalsystems insulation (TSI) or surfacingACM), Class II work (removal of otherACM), Class III work ( repair ormaintenance activities that may disturbACM), and Class IV work (maintenanceand custodial activities that contact ACMor involve clean-up of ACM). OSHA alsohas minimum training requirements for thecompetent person that supervises each

class of work. Additional trainingbeyond OSHA requirements might bedesirable for some types of O&M work.

Communications The owner of abuilding is required by OSHA to makenotification to the following employersabout the presence, location and quantityof ACM or PACM: C Prospective employers applying for or

bidding for work, C employees of the owner, C all employers on multi-employer work

sites, C tenants occupying areas. This notification is required if theseemployers or their employees will beperforming work in or adjacent to areaswhere ACM or PACM is located.

Maintenance Workers: The obligationto notify extends beyond those employedby the owner and includes anyone whomay disturb or contact these materials. Maintenance workers (whether directlyemployed by the owner or by amaintenance contractor), buildingoccupants, contractors and those workingfor contractors are all included. Theowner is obligated to notify contractorsworking on his building. Thesecontractors are then responsible fornotifying their employees.

The building owner is required to notifyaffected employees of the existence ofACM which they may disturb during thecourse of their employment. OSHAexplicitly requires a building or facilityowner to locate and identify thesematerials.

Occupants: Experience has demonstratedthat the best way to deal with buildingoccupants is to be absolutely frank about


the asbestos in their building and what isbeing done to control it. Thecommunication should begin when aninspection is commissioned and continueas long as ACM remains in the building. Attempts to hide or minimize asbestoscontrol work creates an atmosphere ofdistrust. An explanation of the effortsbeing expended to insure the well being ofbuilding occupants is usually wellaccepted. People react well whenmanagement cares enough to protect them. The program should be explained in thislight.

If there has been an episode where ACMhas been released into the buildingenvironment, the people affected may bejustifiably concerned. This concern is aperfectly reasonable reaction from peoplewho are concerned for their well being,and should not be treated as hysteria. Detailed and accurate answers should begiven to all questions. Ultimately, logicand calm will prevail for the greatmajority of people. First, however, peopleneed to know that they are being listenedto and taken seriously.

In-house Personnel The asbestosO&M program needs to include controlover in-house personnel such as cleaningand maintenance staff that may come incontact with ACM. There should beclearly defined limits on the type ofprocedures performed and amount ofmaterial that in-house personnel areallowed to work on. In general, it is betterto limit in-house personnel to workpractices that they will be routinelyperforming. If an activity is seldomencountered, it is easy for a worker toforget the details of the neededprocedures. These activities might betterbe left to a contractor experienced in the

removal of asbestos-containing materials. For example, some asbestos O&Mprograms restrict in-house personnel fromany activity that might disturb asbestos,and contract this work out to an asbestosabatement contractor. Frequently, in-house personnel are limited to thoseactivities that can be performed withoutentering into an environment where thereis an elevated level of airborne asbestos. The direct supervisor of workers involvedin work on ACM needs to be a competentperson as required by OSHA (seeAppendix I “Regulations” for moreinformation).

Contractors The asbestos O&Mprogram should include control overcontracted services.

Custodial work: Contractors involved incleaning and other custodial serviceswhich are in the vicinity of but do notdisturb asbestos containing installations,debris or dust should be notified of thelocation of ACM. This notification shouldbe signed by the contractor who employsthe workers and returned to the owner fordocumentation of the notification.

Repair and maintenance: Repair ormaintenance in controlled areas or oncontrolled systems must involve specificwork procedures using trained workers. The NIBS Publication, Model GuideSpecifications for Asbestos Abatement andManagement in Buildings, containsdetailed information on contracting thistype of work. Detailed specifications canalso be developed from the work practicesin this manual. specifications can then beattached to a purchase order or made partof a set of a contract documents.

A convenient method for acquiring


outside contract services is by use of anannual service contract for the asbestosO&M services. Unit prices can beestablished for each work activity basedupon specified work practices. Pricing foran O&M activity can then be determinedby applying the unit price to the quantityof work performed. For example, theremay be a unit price for removal of pipeinsulation using glovebags. The cost ofthe work can be determined bymultiplying the cost per glovebag removalby the number of glovebag removalsperformed. The owner can bid thiscontract on an annual basis. This permitsthe owner to acquire the required servicesquickly when needed and still havecompetition control costs.

A contractor is liable for the safety ofthose working for him. However, thecontract between the owner and contractorif improperly drawn can transfer part ofthis liability to the owner. This frequentlyoccurs due to work specifications thatattempt to be over-protective or insureOSHA compliance without adequatelydefining the role of the contractor as theprotector of his employee. If, forexample, the specification called forworker protection or respiratory protectionprocedures to be approved by the ownerthis can effectively transfer some of theresponsibility for the effectiveness of

these measures to the owner. The owneris responsible for notifying the contractorwho is in turn responsible for notifying hisemployees. The standard procedures forcontracting maintenance services shouldinclude submittals from the contractor tothe owner demonstrating compliance withworker and respiratory protectionrequirements. The designer of an O&Mprogram that is going to contract outasbestos control work should review thediscussion in the introduction to the NIBSModel Guide Specifications for AsbestosAbatement and Management in Buildings,on owner, designer and contractorliabilities.

Audit and Review The entireprogram should be critically evaluated atperiodic intervals. This evaluation shouldconsider: success of work procedures,effectiveness of administrative controls,adequacy of documentation, compliancewith current regulations, level ofpersonnel training, equipment condition. This audit should be carried out by anindividual or agency external to theprogram. This can be accomplished byanother division of the organization or anoutside consultant. If the audit isperformed by the program designer then itbecomes an opportunity to evaluate newsituations, and augment worker training.


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3 - 1 # O&M Work Practices # Asbestos O&M Work Practices # © NIBS 1996 # Page -15

3. O&M Work PracticesGeneral The EPA Green Book pro-vides building owners, managers, wor-kers and other building staff with basicinformation on how to develop andcarry out operations and maintenanceprograms.

The O&M work practices in this manualare intended as the basis for thedevelopment of detailed and specificguidance to the O&M personnel forconducting maintenance, repair andminor renovation work in accordancewith an established asbestos O&Mprogram and applicable regulations. The work practices in this manual aredesigned to reduce or contain materials,dust, or fiber release resulting fromwork performed on or near asbestos-containing materials (ACM). The workpractices are also intended to minimizethe extent and impact of any releaseswhich do occur. Summaries of eachwork practice and examples of typicalsituations that might be encountered areincluded to assist in the selection ofappropriate work practice levels.

This manual presumes that an O&Mprogram is, or will be, established. Thework practices in the manual addressmost commonly encountered operationsand maintenance tasks involving ACM. This manual is not exhaustive and doesnot document or establish a definedprocedure for every possible situation. The manual is formatted to present anarray of actual conditions which mightbe encountered. It establishes a logical

path to be followed in selecting the mostappropriate work practice(s) for a givensituation. Building workers are oftenvery familiar with actual building con-ditions and might provide valuable inputto the design of O&M work. Workersmight also wish to offer suggestions formodifications to specific work practices. Any changes to the work practicesshould be reviewed with the APM.

As a part of the O&M program, theAsbestos Program Manager (APM)should review building inspectioninformation to determine whether or nota material that is to be included in theO&M contains asbestos. If a materialwhich potentially could contain asbestosis to be worked on, but has not beensampled, it should either be sampled andanalyzed in accordance with the EPAPink and/ or Purple Books, or bepresumed to contain asbestos (PACM)and treated accordingly. The OSHAregulation (29 CFR 1926.1101) requiresthat a building or facility ownerdetermine the location of ACM andPACM before any work is begun.

If work practices based on this manualare incorporated into an existing O&Mprogram, the entire O&M programshould be reviewed and updated, ifnecessary. Building renovation, main-tenance or repair work that does notdirectly affect ACM might necessitaterevisions to an O&M program if perti-nent factors, such as accessibility toACM, are altered.


O&M Program Assumptions This O&M Work Practices Manualassumes that all elements of an O&Mprogram listed below are considered andapplicable elements are established. References to related information areincluded in Appendix G.! Asbestos Program Manager ap-

pointment and training! Building inspection and assessment! Written building-specific O&M

program! Copies of applicable regulations

and guidance documents! Occupant notification/communica-

tion program! O&M worker, supervisor, and

competent person assignments andtraining program

! Work control/inspection/permitsystem

! Periodic surveillance program! Record keeping program! Hazard communication program! Worker protection program (per-

sonal protective equipment) ! Respiratory protection program! Medical surveillance program! Asbestos fiber release episode re-

sponse program ! Air monitoring program! Waste disposal program! Historical air monitoring data! Confined space program! Safety program for other hazardsAll O&M related programs should bereviewed periodically and revised ifnecessary. Regulatory and guidancedocuments should also be reviewedperiodically to ensure that they arecurrent.

Organization of WorkPractices The O&M work practicesin this guide are grouped according tothe type of ACM that will be affected bythe work. ACM is classified in thismanual according to the three (3)categories used by the EPA. Thisclassification system has been widelyused in the asbestos industry since thepublication of the Asbestos HazardEmergency Response Act Rules(AHERA) in 1987. These categoriesare:

1. Surfacing Materials - materialssprayed or troweled onto buildingsurfaces, such as acoustical materi-als or fireproofing. Drywallsystems are not considered asSurfacing Materials.

2. Thermal Systems Insulation (TSI) -pipe, boiler, tank, duct and otherinsulation applied to components toreduce heat loss, heat gain orcondensation.

3. Miscellaneous Materials - materialssuch as floor tile, ceiling tile, roof-ing, cement asbestos products, felt,woven asbestos products, and othermaterials that are not included incategories 1 or 2 above.

The work practices in this manual aregenerally designed to address one ma-terial at a time. If more than one type ofmaterial is involved, work practicesshould be selected and used in the orderin which the materials will beencountered during the work. If two (2)or more materials must be addressed atone time, the O&M designer shoulddevelop a combined Work Practice toaddress the particular work situation.


When developing a combined workpractice, the O&M designer shouldconsider the following:

1. The checklist for the most precau-tionary level of work practice shouldbe used.

2. The work area should be preparedin accordance with the checklist forthe most precautionary level of workpractice being used.

3. Once the work area is prepared andpre-work activities are complete,the detailed work practices shouldbe performed in the order in whichmaterials are encountered.

4. Clean up and tear down proceduresshould also follow the most precau-tionary level of work practice beingused.

Work practices in this manual areintended to be the basis for developmentof facility specific work practices. Thework practices in this manual need to bemodified and validated for the facilitywhere O&M work will be performed. When work is to be performed, the finalwork practices should be given toworkers along with other referencedO&M forms. Repetition of certain stepsin different work practice levels is inten-tional in order to provide consistent andcomplete information to a worker for agiven work practice level.

Work Practice Levels The NIBSproject committee judged that up tothree levels were sufficient toencompass a broad range of situationswhich are likely to be encountered. Thelevels are simply a means of structuringthe guidance which the manualprovides. Up to three levels areincluded for each work practice toaddress different degrees of potentialasbestos fiber release. A differentnumber of levels might be selected byan O&M designer or designed into aspecific asbestos O&M program.

A change of level does not imply adifferent task to be accomplished. Itimplies a changed potential for asbestosfiber release, typically related to eitherthe condition of asbestos, nature of thework practice, skill of the workers or thebuilding context in which the task willbe performed.

The levels for each work practice in-cluded in this manual are definedprincipally in relation to the OSHAasbestos standards. There are threestandards that may apply. The OSHAconstruction standard, 29 CFR1926.1101, applies to most O&Mactivities, including cleaning that isassociated with construction. Normalcleaning, that is not associated withconstruction or other O&M work,including cleaning and buffing ofresilient flooring, is covered by theOSHA general industry standard, 29CFR 1910.1001. Work on ships or inshipyards is covered by the shipyardstandard, 29 CFR 1915.1001. Theshipyard standard is similar to theconstruction standard, and will not bediscussed separately in this manual.


The OSHA construction standard setsforth four classes of construction-relatedwork. Operations and maintenance andcleaning activities connected withconstruction work are defined as ClassIII and IV work. The principaldifference for O&M activities is thatClass III work disturbs the ACM andClass IV only contacts, but does notdisturb the ACM. This manual alsocontains some work practices that caninvolve housekeeping operations whichare subject to either the OSHAconstruction or the general industrystandard.

Activities that are not intended tocontact ACM and are not likely todisturb ACM are not given a leveldesignation, but require control to insurethat a disturbance does not occur. Areas where ACM is located and whereaccess can be controlled should bedesignated as “Controlled Areas.” ACM systems in the vicinity of workbut which do not need to be contactedshould be designated as “ControlledSystems.” Exposure monitoring is notrequired for these activities as ACM isnot being contacted. Awareness trainingis needed to inform workers about thelocation of the ACM, and to advise themto avoid contacting it, and to report anydamaged ACM they observe.

In general, an O&M program is easier toimplement and is more cost effective ifmaintenance work can be performedwithout the need for enclosures. Maintenance work that contacts ordisturbs ACM is governed by OSHA. To be able to perform maintenance workgoverned by the Construction Standard(1926.1101) without an enclosure andstill comply with OSHA, it is necessaryto make a negative exposure assessment

(NEA). This effectively makes theOSHA PEL a limit on the level ofairborne asbestos that can be generatedby a work practice before enclosure isrequired. In general, Level A and Bmaintenance activities related toconstruction are un-enclosed and as suchrequire a negative exposure assessment. Level C work practices are enclosed andas such may generate airborne fiberlevels above the OSHA PEL. Themethod of making a negative exposureassessment for most O&M activities isdiscussed in more detail in section 4 ofthis manual. Negative exposureassessment for resilient flooring removalis discussed in the introduction to theSection R “Resilient Flooring WorkPractices.” Note that a negativeexposure assessment alone does noteliminate the requirement for respiratoryprotection. Respiratory protection isrequired, even with an NEA, if ACM isremoved in a non-intact state, if wetmethods are not used, or for removal ofTSI or surfacing material. Intact isdefined by OSHA as ACM that has notcrumbled, been pulverized, or otherwisedeteriorated so that the asbestos is nolonger bound with its matrix.

Cleaning work not related toconstruction or dust and debrisgenerated by such activity is governedby the OSHA General Industry Standard(1910.1001). This standard does notcontain provisions for a negativeexposure assessment. Routine cleaningactivities are performed as Level Abased on a determination having beenmade that cleaning activities using thework practices in this manual (which arebased on those contained in the OSHAregulation) are not reasonably expectedto result in exposures exceeding thePEL.


Definition of Work PracticeLevels The three work practice levelsare defined as follows:

Level A: is work that may contactACM, but which will not disturb it. Level A is defined in terms of Class IVwork in the construction standard (29CFR 1926.1101). It is Class IV work(except for cleanup work) with anegative exposure assessment whichinvolves maintenance and custodialactivities during which employeescontact ACM and PACM, but do notdisturb it. Note that clean up ofasbestos-containing debris and wasteis not Level A work (Refer to Level Bfor this type of clean up work). It isalso Class II work (involving non-friable materials such as gaskets,roofing, and cement asbestos board)with a negative exposure assessment.Work on resilient flooring is treateddifferently by OSHA and is described inFigure 2 “OSHA Requirements forWork Practices for Resilient FloorCovering Materials.”

Work practices: required for Level Aare those set forth in paragraph (g) (10)of the OSHA asbestos constructionstandard for Class IV work and (g)(8)and (g)(11) for Class II work. SeeFigure 1 for checklist of requirements

Level B: is work that may disturbACM, but where the OSHA PEL is notexceeded and release of ACM, dust anddebris is confined to the immediatelocation of the disturbance. In theconstruction standard, it is Class IIIwork on TSI or Surfacing ACM with anegative exposure assessment, Class IV

work activities to cleanup waste anddebris containing ACM and PACM withan NEA. Class III asbestos workincludes repair and maintenanceoperations, where ACM, includingthermal system insulation and surfacingmaterial, is likely to be disturbed. Operations where TSI or surfacing areworked on using “aggressive” methods,such as drilling, cutting, abrading, etc.are Level C work, as OSHA requiresarea isolation for these procedureswhether or not a negative exposureassessment is made. In the generalindustry standard, clean up of ACMwaste, debris and accompanying dustthat are not from construction activities,and where the PEL is not exceeded isLevel B work. If the quantity ofmaterial disturbed during Class III workexceeds one 60 inch x 60 inch glovebagor waste bag, then the activity becomesClass I or II and exceeds the limitationof the work practices in this manual. Refer to the NIBS manual Model GuideSpecifications, Asbestos Abatement andManagement in Buildings for moreinformation.

Work practices: required for Level Bare those set forth in paragraph (g) (9) ofthe OSHA construction standard forClass III work and (g)(7, 8 and 11) forClass II work. These include O&Mtraining, respirators, engineeringcontrols and work practices, wetmethods, local exhaust ventilation(Note: A respirator is not required ifwork is on non-TSI or non-surfacingmaterial, there is a negative exposureassessment, wet methods are used, andthe material remains intact.). In theconstruction standard, asbestos-containing debris and waste fromconstruction activities(including O&M) are to be promptly


cleaned up and disposed of in leak-tightcontainers. The general industrystandard covers clean up of non-construction waste, debris andaccompanying dust. These must becleaned up with wet methods and HEPAvacuums. The construction standardrequires that in areas with accessible,friable TSI and surfacing material, wasteor debris must be presumed to containasbestos. See Figure 1 for checklist ofrequirements.

Level C: is work where ACM isdisturbed and the PEL may be exceededor ACM, dust, and/or debris may bescattered beyond the immediate locationof the disturbance. It is Class III workdescribed in the OSHA constructionstandard: paragraph (g)(9)(iii) wherethe disturbance involves drilling,cutting, abrading, sanding, chipping,breaking, or sawing of thermal systeminsulation or surfacing material; or(g)(9)(iv) where there is no negativeexposure assessment or where the PELis exceeded. It is also Class II workwithout an NEA.

Work practices: required for Level C

are mini-enclosures, glovebags andother enclosure devices set forth inparagraph (g)(5) of the constructionstandard as well as work practices setforth in paragraph (g)(9) of the OSHAconstruction standard for Class III work. These include O&M training,respirators, engineering controls andwork practices, wet methods, and localexhaust ventilation. Debris and wasteare to be promptly cleaned up anddisposed of in leak-tight containers. SeeFigure 1 for checklist of requirements.

A "disturbance" of ACM, as used in thelevel definitions, refers to any activitythat disrupts the matrix of ACM orPACM, crumbles or pulverizes ACM orPACM, or generates visible debris ordust from ACM or PACM..

Figure 1 which follows, summarizes theengineering controls and practicesrecommended for each level. The APMshould determine the appropriate level,based on the O&M program objectives,the O&M program elements, and levelof training needed for each level of workpractices used in a facility.

Figure 1: Guidelines for 3 Levels of Work Practices(See Figure 2 for Resilient Flooring)

ITEM (General Procedure Reference)1 LEVEL A2 LEVEL B2 LEVEL C2

Initial Exposure Assessment YES YES YESInitial Monitoring (W8) As Needed 3 As Needed 3 As Needed 3

Negative Exposure Assessment Required4 Required 4 Not Required5

Periodic Monitoring (W8) NO 6 NO 6 YESFiber Release Potential Low/Minimal Below PEL Above PELWorker Protection Basic Moderate Full O&MArea Protection Basic Moderate EnclosureTraining (APM5) O&M/

Awareness7O&M O&M+8

HVAC System Off (W3) NO9 As Needed YESVacate Area (W4, APM2) NO YES YESCritical Barriers (W5) NO NO10 YESRegulated Work Area (W4) NO YES YESRespiratory Protection (W6) NO YES11 YESProtective Clothing (W7, W15) NO YES YESPreclean (W9) NO As Needed 12 As Needed 12

Use HEPA Vacuum (W9) YES YES YESWet Methods (W9) YES YES YESWork Area Protection (W10)(W20) NO 13 Drop cloth Mini-Enclosure, Glovebag

Negative-Pressure System 14

Lockdown (W12) NO As Needed As Needed 12

Clean Tools and Work Area (W14) YES YES YESVisual Inspection (W16) NO As Needed As NeededAir Clearance (W16) NO 15 NO 15 As Needed 16

Personal Decontamination (W15) NO 17 HEPA Vac ShowerNotification NO YES YES


1. The general procedures in parentheses provideadditional information on the noted item.

2. The exact meaning of these three levels willvary depending upon the fiber releaseobjectives which are specified in the design ofthe O&M plan for a specific building (seeDesign of O&M Practices (Section 4) forfurther explanation). State and localrequirements may be different & some may bemore stringent than these guidelines.

3. Initial monitoring may be required whilemaking a negative exposure assessment(NEA). The NEA can be based on objectivedata, data from previous jobs, or initialmonitoring. For Level C an NEA may not bepossible.

4. A negative exposure assessment is requiredbecause the work practices in this manual forthis level are performed without enclosure.

5. Level C work is performed inside of anenclosure so that a negative exposureassessment is not required by OSHA. However, airborne fiber levels inside mini-enclosures should be maintained below theOSHA PELs if possible.

6. Level A and B in this manual require anegative exposure assessment during design ofthe work practice. For this reason periodicmonitoring is not required. However, aninitial exposure assessment and periodic

monitoring may be required in the future ifthere is a change in process, controlequipment, personnel, or work practices thatmay result in new or additional exposures.

7. Class IV work (contact but do not disturbACM) requires awareness training. Class IIwork on non-friable materials (e.g. roofing,siding, ceiling tiles, and cement asbestos board‘transite’) require a minimum of 8 hours ofO&M training including training in specificwork practices for the material, engineeringcontrols, hands-on training as well as theelements required in paragraph (k)(9)(viii) ofthe construction standard (see Appendix I“Regulations”).

8. Training beyond O&M should be provided forthe Level C work practices in this manual. This should include specific training inglovebag and mini-enclosure procedures. Themini-enclosure is a potentially contaminatedenvironment. At a minimum, mini-enclosureworkers should receive the same workerprotection, and personal and environmentaldecontamination training as abatementworkers.

9. Turn off HVAC if work will be performed onHVAC system(s).

10. Critical barriers may be necessary or bespecified for particular cases by the APM.

11. This manual presumes that respiratoryprotection will be provided for all Level Bwork. However, OSHA allows respiratoryprotection to be deleted for work on non-friable materials (non-surfacing and non-TSI)if a negative exposure assessment has beenmade, the material is removed intact, and wetmethods are used.

12. May be recommended - see work practices. Adequate training is necessary.

13. Drop cloth optional for dirty tools, equipmentand/or waste.

14. Work area protection may be revised ifalternate methods are used and historic dataare available.

15. Air clearance depends on air monitoringprogram specifications.

16. Clearance monitoring should be consideredduring development of mini-enclosureprocedures. After mini-enclosure use hasbeen validated (NEA after tear down) considerdiscontinuing clearance monitoring.

17. Personal decontamination may be specified byAPM or O&M program.

NOTES:

3 - 8 # O&M Work Practices # Asbestos O&M Work Practices # © 1996 # Page - 22

Resilient Flooring: Resilient flooring is treated differentlyby OHSA, and as such the leveldefinitions for these materials differsfrom that of other ACM. There are twodifferent types of Level A, and a LevelB+ that replaces both Levels B and C.

Level A1: Level A1 is defined interms of Class II work in theconstruction standard (29 CFR1926.1101). It is Class II work with anegative exposure assessment thatinvolves removal or repair of resilientfloor covering materials (refer to theintroduction to the resilient flooringwork practices section, Pages R-2through R-9, for information on therequirements for a negative exposureassessment with resilient flooring). SeeFigure 2 for checklist of requirements.

Work practices: required for Level A1are those set forth in paragraph (g) (8) ofthe OSHA asbestos constructionstandard for Class II work involvingresilient floor covering materials and inthe compliance directive (CPL 2-2.63Appendix D pages 34-36 November 3,1995). If more than a small quantity ofmaterial is disturbed during workcovered by the construction standard,then the activity exceeds the limitationof the work practices in this manual. Refer to the NIBS manual Model GuideSpecifications, Asbestos Abatement andManagement in Buildings for moreinformation.

Level A2: Level A2 is defined interms of “housekeeping” in the generalindustry standard (29 CFR 1910.1001)and in the construction standard (29CFR 1926.1101). It encompasses

routine housekeeping operationscovered by the general industrystandard, where a determination hasbeen made that cleaning buffing orpolishing activities using the workpractices in this manual (which arebased on those contained in the OSHAregulation) are not reasonably expectedto result in exposures exceeding thePEL. See Figure 2 for checklist ofrequirements. Note: When theseactivities are performed in relation to aconstruction operation, the constructionstandard (1926.1101) applies, and anegative exposure assessment isnecessary (refer to Appendix I).

Work practices: required for Level A2are those set forth in the OSHA generalindustry standard for non-construction-related housekeeping activities. Awareness training must be providedannually, in a manner that iscomprehensible to all employees. Paragraph (k) of the general industrystandard has specific requirements forstripping of finishes and burnishing ordry buffing asbestos-containingflooring. Note: If these activities areperformed as part of a constructionproject, the construction standard(1926.1101) would apply. Refer toAppendix I for more information.

Level B+: Level B+ is removal ofresilient flooring materials that are notintact, or will become non-intact duringremoval, or where a negative exposureassessment cannot be made. (Note:Material in this condition is described as“RACM,” under the EPA/NESHAPregulations. Refer to Appendix I formore information on NESHAP


requirements.) These augmented LevelB work practices can be used for workon resilient flooring where flooringmaterials become friable, if the OSHAPEL is not exceeded and release of ACM, dust and debris is confined to theimmediate location of the disturbance. To comply with OSHA, Level B workpractices used for this purpose requirecritical barriers, as well as therespiratory protection, air monitoringand other work practices normallyassociated with Level B work. If morethan a small quantity of material isdisturbed during the work, then theactivity exceeds the limitation of thework practices in this manual. Refer tothe NIBS manual Model GuideSpecifications, Asbestos Abatement andManagement in Buildings for moreinformation.

Work practices: required for Level B+are the same as those required for LevelB in figure 1, with the addition ofcritical barriers. OSHA requirementsfor Level B work are set forth inparagraph (g)(8) of the asbestosconstruction standard for Class II workinvolving resilient floor coveringmaterials. These work practices includeO&M training, respirators, engineeringcontrols and work practices, wetmethods, local exhaust ventilation,prompt clean-up of debris, and wastedisposal in leak-tight containers. LevelB+ adds critical barriers as required byparagraph (g)(7) of the standard. SeeFigure 2 for checklist of requirements.

Figure 2, which follows, summarizes theengineering controls and practicesrecommended for each level. The APMshould determine the appropriate level,based on the O&M program objectives,the O&M program elements, and levelof training needed for each level of workpractices used in a facility.

Figure 2: OSHA Requirements for Work Practices forResilient Floor Covering Materials

ITEM LEVEL A11,2 LEVEL A2 1 LEVEL B+3

Work Practices R1-A & R2-A4, 5 R5-A, R6-A,R7-A

R1-B, R2-B,R4-B, R8-B

OSHA 1926.1101 1910.10016 1926.1101Initial Exposure Assessment YES YES YESInitial Monitoring (W8) Not Required If Needed7 RequiredNegative Exposure Assessment Required Not Applicable8 Not RequiredPeriodic Monitoring (W8) NO NO YESFiber Release Potential Low/Minimal Low/Minimal Below PELWorker Protection NO NO ModerateArea Protection NO NO ModerateTraining 8 hr flooring specific9 Awareness O&MHVAC System Off (W3)10 NO NO As NeededVacate Area (W4, APM2) 10 NO NO YESSecuring the Work Area (W4) 10 NO NO YESRegulated Work Area (W4) YES11 NO YESRespiratory Protection (W6) 10 NO NO YESProtective Clothing (W7, W15) 10 NO NO YESPreclean (W9) NO NO As NeededUse HEPA Vacuum (W9) YES As Needed12 YESWet Methods (W9) YES13 As Needed 12 YESCritical Barriers (W5) NO NO YESLockdown (W12) NO NO NOClean Tools and Work Area (W13) YES YES YESVisual Inspection (W16) NO NO YESAir Clearance (W16) 10 NO NO NOPersonal Decontamination (W15) 10 NO NO HEPA VacNotification YES14 NO YES


1. Applies to Intact Resilient Flooring: “Intact” isdefined by OSHA as ACM that has notcrumbled, been pulverized or otherwisedeteriorated so that it is no longer likely to bebound within its matrix. The incidentalbreakage of flooring materials, or slicing ofsheet vinyl floor covering with a sharp edgedinstrument, during removal operationsconducted in accordance with theRecommended Work Practices does not meanthat the materials are not removed in an intactcondition. OSHA has stated that resilientfloor covering materials are considered non-friable if intact and generally do not emitairborne fibers unless subject to sanding,sawing, or other aggressive operations.

2. The EPA NESHAP regulation (40 CFR Part61, Subpart M) defines asbestos-containingresilient floor products as Category Inonfriable materials, which are not regulatedby the NESHAP unless they become friable orare subjected to sanding, grinding, cutting orabrading. Cutting in this instance includessawing, but not shearing, slicing or punching.

3. Asbestos-containing resilient flooringproducts that have become friable or arerendered friable during removal are RegulatedAsbestos-Containing Materials (RACM)under the EPA NESHAP regulation (40 CFRPart 61, Subpart M) and must be handled anddisposed of accordingly. Refer to Appendix I“Regulations” for information on NESHAPrequirements.

4. Work Practices R1-A and R2-A are governedby the OSHA Construction Standard, 29 CFR1926.1101.

5. Work practices R3-A and R4-A are in figure1.

6. Work Practices R-5A, R-6A and R-7A in thismanual are normally governed by OSHAGeneral Industry Standard (29 CFR1910.1001) when they are part of routinecleaning in public and commercial buildingswhere construction activity is not taking place,but are governed by the construction standard(29 CFR 1926.1101) if they are performed inrelation to construction activities. SeeCompliance Directive at C-18.

7. The employer may forgo initial monitoringwhere a determination has been made thatcleaning buffing or polishing activities usingthe work practices in this manual (which arebased on those contained in the OSHAregulation) are not reasonably expected toresult in exposures exceeding the PEL. Note: if these activities are performed as part of aconstruction project, the construction standard(1926.1101) would apply, and a negativeexposure assessment would be necessary(refer to Appendix I).

8. The general industry standard does not have aprovision for a negative exposure assessment.

9. Additional 4 hours of training required forcompetent person.

10. The designer may specify additional qualitycontrol measures, although these are notrequired by regulation. This may be specifiedby the owner because of a condition of the job,but may result in additional cost beingincurred.

11. Demarcation not required if access restricted(Vol. 60 Federal Register, page 33974, June,29, 1995).

12. Shoveling, dry sweeping and dry clean-up ofasbestos may be used only where vacuumingand/or wet cleaning are not feasible. [29 CFR1910.1001(k)(5)] Waste and debris andaccompanying dust in an area containingaccessible ACM and/or PACM or visiblydeteriorated ACM, shall not be dusted orswept dry, or vacuumed without using aHEPA filter. [29 CFR 1910.1001(k)(8)]

13. Wetting is not required when heat is used toremove intact floor tile.

14. Notification - See 29 CFR1926.1101(k)(2)(ii).

NOTES

4 - 1 # Design of O&M Work Practices # Asbestos O&M Work Practices # © NIBS 1996 # Page - 25

4. Design of O&M WorkPractices DESIGN OF THE O&M PROGRAMThe O&M program for a specific facilityneeds to be designed. Frequently, thisdesign will be developed cooperatively byan asbestos control designer and a facilityperson who then becomes the AsbestosProgram Manager (APM). The designerneeds to have specialized knowledge inasbestos control procedures and theapplication of these procedures tomaintenance activities and often isrequired to be licensed by State or Localregulations. The Asbestos ProgramManager has knowledge of the practicesand administrative procedures of thefacility. The Asbestos Program Managerimplements the program once it has beendesigned. This manual is concernedprimarily with the design of O&M workpractices for a facility’s asbestos O&Mprogram. The nature of these workpractices will depend on decisions madeby the facility owner in setting up anasbestos O&M policy. The steps theO&M designer and APM need to take toset up an asbestos O&M program include:

! Definition of Scope: The designerneeds to determine the type, locationand condition of ACM that need to becontrolled by the O&M program. This may require an inspection of thefacility. An existing inspection reportcan be used for this purpose if it issufficiently comprehensive andspecific. The inspection report needsto be the first O&M programdocument. It needs to be madeavailable and explained to all who willbe involved in implementing theO&M.

! Policy and Organization: The

designer needs to assist the buildingowner in making the necessary policydecisions to effectively implement theO&M program. The administrativeposition in the organization with theappropriate authority for the AsbestosProgram Manager (APM) must beidentified, and given the responsibilityfor implementing the program. TheAPM must have direct line authorityover any activity that could affectACM in the facility. This includesauthority over in-house cleaning andmaintenance staff, and contractedcleaning, custodial, maintenance, andrenovation work. The building owner, with the adviceof the designer, needs to establish theasbestos exposure goals of the O&Mprogram. To be useful in the designof O&M work practices these goalsneed to be stated in (or translatableinto) terms of permissible asbestoslevels for the facility, and for theworkers engaged in O&M work . Frequently the building owner willstate the goals in general terms suchas, “lowest possible,” “lowestfeasible,” or “as required byapplicable regulation.” In thisinstance the designer will need totranslate this into terms of permittedairborne concentrations of asbestos.

! Program Administration: Thedesigner needs to work with the APMin setting up a workable set ofadministrative procedures to insurethat O&M work practices will beroutinely and reliably applied whenneeded. The designer will provideinformation about asbestos control


and regulatory compliancerequirements, and the APM will knowhow existing administrative systemswork. Usually, the best proceduresresult from making minor additions toexisting administrative procedures. The APM will use theseadministrative procedures toimplement the O&M program.

! Documentation: The designerneeds to work with the APM in settingup a system that the APM can use todocument the operations of the O&Mprogram. This manual containsexample forms in the appendices thatcan be used as a starting point for adocumentation system. Thisdocumentation must include therecordkeeping required by OSHA andthe EPA. It should also includedocumentation sufficient todemonstrate that the effectiveapplication of controls overdisturbance of ACM.

! Controlled Area: The designer willassist the APM in designatingControlled Areas. A signage systemto notify a worker entering acontrolled area about the type andlocation of ACM present in the area,and work practices required by theO&M program needs to be devised,and signs posted. This system needsto meet requirements of OSHA (29CFR 1926.1101(k)(6)).

! Controlled Systems: The designerwill assist the APM in designatingcontrolled systems. A labeling systemto notify a worker that a systemcontains asbestos needs to be devised,and labels posted. This labeling mayalso include information about the

controls required by the O&Mprogram for each system. This systemneeds to meet requirements of OSHA(29 CFR 1926.1101(k)(8)(vii)).

! Work Practices: The O&Mdesigner can use the work practices inthis manual as the starting point fordeveloping work practices specific tothe facility. These work practices thenneed to be modified as required byconditions within the facility. Thework practices need to be tested orvalidated to determine if the airborneasbestos level goals have been met. The work practices need to beadjusted until these goals areefficiently and reliably met. TheAPM supervises the application ofthese work practices to maintenanceactivities that involve ACM.

! Training: The O&M designer assiststhe APM in determining the trainingrequirements for each participant inthe O&M program, and setting up theadministrative procedures necessary toinsure that training is provided,records of training kept. Moreinformation on training requirementscan be found in Appendix I“Regulations.”

! Communications: The O&Mdesigner assists the APM indeveloping standard notification formsand memos, and setting up theadministrative procedures necessary toinsure that notifications are made asrequired by the O&M program.

! In-house Personnel: The O&Mdesigner helps the APM set up theadministrative controls necessary toinsure that only persons with


equipment and training appropriate tothe work contact or disturb ACM.

! Contractors: The O&M designerhelps the APM develop the necessarynotification forms for contractors. Aprocedure must be developed to insurethat receipt of this notification isacknowledged by contractors in theform of a submission to the APMprior to the start of any work. The

O&M designer develops the contractdocument for a unit price contract ifthis is going to be used as part of theO&M program.

! Audit and Review: The O&Mprogram designer may review theO&M program on a periodic basis,and assist the APM to make anymodifications that are necessary.

DESIGN OF O&M WORK PRACTICES

Before an O&M work practice can bedesigned, it is necessary for the facilityowner/manager to determine the goals ofthe O&M program in terms of permittedairborne asbestos levels for the facility andworkers. A work practice is selected fromthe examples given in this manual. Thework practice is modified as necessary tomeet conditions in the facility. The workpractice needs to be tested and developeduntil it meets the asbestos level goals forthe facility.

Environmental Goals: The facilityowner/manager needs to establish a limitfor airborne asbestos levels that resultfrom O&M work. At a minimum thislevel must meet OSHA requirements andthe OSHA PEL’s must not be exceededfor building occupants. Some buildingowners/employers might choose to simplyachieve regulatory compliance. Othersmight establish O&M programs with moreprecautionary criteria for protection ofworkers and the building environment. Regulations do not set precise standardsfor the protection of buildingenvironments. Examples of building environment criteria

commonly used by owners are:! The OSHA permissible exposure limit

(PEL) - 0.1 f/cc by PCM as an 8-hourtime weighted average (TWA), and1.0 f/cc as a 30-minute excursionlimit. This standard must be met asthe maximum exposure level allowedby the regulation.

! 0.01 fibers per cubic centimeter of airby PCM (EPA Purple Book)

! The AHERA standard, or state stan-dards, requiring a comparison ofinside work area samples to outsidework area samples

! 70 structures per square millimeter forair samples of at least 1200 liters(AHERA level where comparison tooutside is not required)

! Outside ambient air levels

! Inside ambient air levels under condi-tions where there is no active distur-bance of ACM

! Indoor air standards for asbestos asregulated by state or local agencies.

Worker Exposure Goals: Thefacility owner/manager must establish anupper limit on the exposures to workersengaged in O&M work. Building owners


and/or employers must comply withOSHA and other applicable regulationswhich relate to maintenance proceduresand worker protection. This means that asa minimum requirement a worker’sexposure must not exceed the OSHAPELs during execution of O&M workpractices. Some building owners/em-ployers might choose to simply achieveregulatory compliance. Others mightestablish O&M programs with moreprecautionary criteria for protection ofworkers.

Examples of worker exposure limit criteriacommonly used by owners are:

! The OSHA permissible exposure limit(PEL) - 0.1 f/cc by PCM as an 8-hourtime weighted average (TWA), and1.0 f/cc as a 30-minute excursionlimit. This standard must be met asthe maximum exposure level allowedby the regulation

! 0.01 fibers per cubic centimeter of airby PCM as an 8-hour time weightedaverage

! Inside ambient air levels under condi-tions where there is no active distur-bance of ACM

! Standards for asbestos exposure asregulated by state or local agencies.

! Requirement that maintenanceworkers always be equipped withrespirators when working on ACM,regardless of measured exposurelevels.

Selecting Work Practices TheO&M designer should select the workpractices from this manual that are closestto conditions in the facility where thework will be performed. If situations exist

that are not covered by this manual, theO&M designer should develop workpractices based on the guidelines in thismanual and other sources. It might bedesirable to obtain assistance fromsources, such as qualified consultants,regulatory authorities, legal counsel, riskmanagers or insurance companies whenselecting appropriate work practices.

A number of determinations must be madein order to select the appropriate workpractice for a given situation. Theseinclude:

! The level of worker andenvironmental protection desiredbased on the O&M programobjectives.

! Whether O&M work will beperformed by staff personnel or anoutside contractor. The O&Mprogram could specify that someactivities or work practice levels bedone with in-house personnel, whileother activities or levels are done bycontractors. If O&M work is to beperformed by contractors, the APM'sresponsibilities and activities might bechanged to include contractadministration, submittal reviews, andverification that O&M work andmonitoring is being performed asrequired. Modifications to the WorkPractices, APM Checklist, WorkerChecklists and General Proceduresmight be needed.

! Regulatory compliance issues for thespecific facility and personnel whowill perform the work. These includeOSHA and EPA requirements forworker protection, work practices,exposure monitoring, notifications andadditional state or local requirements.

! Whether exposure monitoring dataand work evaluation forms (see


Appendix C) from past work indicatethat a given work practice or workpractice level accomplishes the O&Mobjectives.

! In a facility where the combinedadditive amount of regulated asbestoscontaining material (RACM) to beremoved or stripped during a calendaryear exceeds the EPA NESHAPrequirements, environmental agenciesmust be notified and area andenvironmental controls are required. (RACM is specifically defined by theNESHAP regulations and can befound in Appendix I, Regulations, orAppendix F, Glossary, of thismanual.) EPA's AHERA regulationsapply to any asbestos work conductedin schools. State and local regulationsmay have requirements that differfrom federal regulations and somemay be more stringent. Appendix Iincludes more information on OSHAand EPA regulations.

Modify the Work Practice: Thework practice selected should be modifiedas required by specific facilityrequirements. The materials in a givenfacility may react differently to beingworked on and may require more or lessasbestos control procedures to meet theairborne asbestos goals. Damaged or veryfragile materials may require great careand use of extensive asbestos controlprocedures. Intact, less fragile materialsmay require fewer controls. Characteristics of the ACM may requirethat different controls be applied. Forexample, local exhaust ventilation using aHEPA vacuum may be emphasized overwetting to prevent water staining of ACMarchitectural finishes. The following arefactors which should be considered whenmodifying a work practice for use in aspecific facility:

! Fiber release potential of material orO&M activity

! Condition and friability of ACM

! Exposure and air monitoring data

! Training, skill and experience ofworkers

! Quantity of ACM to be disturbed

! Type and percentage of asbestos

! Location and use of ACM

! Exposure potential for occupants andother personnel

! State and local regulations

! O&M and other management policies

! HVAC and ventilation systemconfigurations

! Presence of on-site supervision

! Asbestos-containing dust and debris

Users of this manual might haveoperations and maintenance programobjectives which are more protective thanthe minimum regulatory requirements. Accordingly, it might be appropriate, inthe development of work practices, toconsider more than just the OSHA andEPA regulatory requirements. Theconditions of the building and the O&Mprogram objectives will dictate the workpractice level necessary.

The work practices in this manual aregenerally limited to activities that arewithin the OSHA Class III limitation thatACM to be disturbed fit in one 60 inchglovebag or disposal bag. This is a fairlylarge amount of material, and definitivequantities of ACM below this level havenot been specified in the work practicelevel examples. This is to provide greaterflexibility and to emphasize that otherfactors might influence level selection bythe APM. For Class II work, such asflooring or roofing operations, the workpractices in the manual are limited to asmall quantity of material. The APM's


determination of the appropriate level willoften be based, at least in part, upon thequantity of ACM to be disturbed. The

work practices are generally designed fordisturbing small amounts of asbestos asrequired to perform O&M tasks.

TESTING AND VALIDATING THE WORK PRACTICE

The work practice needs to be tested to seeif it results in airborne asbestos levels thatmeet the exposure goals of the O&Mprogram. An initial exposure assessmentshould be made for the work practice. This assessment can be based on objectivedata, historic data from another job, or oninitial exposure monitoring collectedwhile the work practice is used. Areamonitoring may also be necessaryparticularly if the environmental exposurelimit specified by the owner or designer islower than the OSHA PEL. If the work isof very short duration, it may be necessaryto repeat it a sufficient number of times tocollect air samples that are large enough toprovide an detection limit that is lowenough to compare against the goals forairborne asbestos. Personal samples onthe workers will indicate if the exposure tothe workers is within the goal. Areasamples near the work will indicate if thegoal for the building environment hasbeen met.

Exposure Monitoring: Theeffectiveness of work practices subject tothe OSHA construction standard needs tobe validated by air monitoring where anegative exposure assessment cannot bemade based upon existing data. Suchexposure monitoring is required byOSHA and will be needed to demonstratethat each work practice level meets thegoals for airborne asbestos exposurelevels. Area monitoring will also benecessary, particularly if an airborneasbestos goal less than the OSHA PEL isestablished. To fit within the level

definitions, the following must hold true:

! Level A work practices should notresult in an elevation of airborneasbestos levels. Respiratoryprotection should not be necessaryduring Level A activities. If there is aquestion about the need for respiratoryprotection the work becomes Level B. A negative exposure assessment isrequired.

! Level B work practices may result inlocalized elevations of airborneasbestos levels, but these levels do notexceed the OSHA PELs, and onlyaffect the worker, but not the buildingenvironment. Respiratory protectionis required as a worker protectionmeasure. A negative exposureassessment is required, so thatenclosure is not required by theOSHA regulation. If a negativeexposure assessment is not possiblethe work must be enclosed and isLevel C.

! Level C work practices may result inelevations of airborne asbestos levelsabove the PELs, or involve drilling,cutting, abrading, sanding, chipping,breaking or sawing TSI or surfacingACM. Respiratory protection isrequired. A negative exposureassessment is not possible so that thework requires additional workerprotection, as well as isolation of thework area from the rest of the facility.


The only way that a work practice can bevalidated is to perform the procedure andmonitor airborne levels during the work. Personal monitoring is required todetermine worker protection requirements,and if work area isolation is needed. Inaddition, area monitoring may benecessary to demonstrate that theremaining building environment is notexposed to elevated asbestos levels. If nodisturbance of ACM will occur (such aswith many Level A work practices),monitoring requirements may be minimal. Meaningful exposure monitoring requiressufficiently long sample durations. Readings are not instantaneous. O&Mprocedures are small in scale and short induration, requiring that many proceduresbe repeated a number of times to enablethe collection of a sample with sufficientsensitivity.

OSHA requires that air monitoring beperformed to determine what level ofworker protection is necessary inconstruction related activities. OSHAspecifies requirements for thedetermination of airborne fiber levels andworker exposures in the Code of Federal Regulations (29 CFR 1926.1101 (f)). OSHA requires employers to determineinitially the level of airborne fibers towhich an employee will be exposedthrough an "initial exposure assessment." A “negative exposure assessment” can bemade by use of objective data, historicaldata from past jobs, or by initial exposuremonitoring. (OSHA treats intact removalof resilient flooring differently, refer to theintroduction to Section VII “O&M WorkPractices, Resilient Flooring,” for moreinformation.) OSHA then requiresperiodic monitoring of constructionactivities including O&M unless anegative exposure assessment is made,supplied air respirators are used, orstatistically reliable measurements indicate

that the PEL is not going to be exceeded. Monitoring must be resumed (unlesssupplied air respirators are used) if there isa change in workers, the activity, orequipment use occurs which might resultin exposures above the permissibleexposure limits (PELs). These airmonitoring requirements provide buildingowners and managers with the informationnecessary to determine what level ofprotection is required by the federalgovernment. State and local laws may bemore stringent. Refer to Appendix I“Regulations,” for more information onOSHA exposure monitoring requirements.

Personal monitoring should consist ofsamples to obtain an 8 hour time-weighted average (TWA), and excursionlimit (EL) monitoring samples. Allanalysis for OSHA compliance should beby phase contrast microscopy (PCM). Transmission electron microscopy (TEM)analysis will distinguish asbestos fibersfrom other fibers and might also be used ifdesired, although PCM data is required byOSHA. TEM data cannot substitute forOSHA required PCM data unlessapproved by the local OSHA office.

The Air Monitoring Program developedfor a specific facility needs to address howexposure monitoring will be conducted toprovide data for use in the design andvalidation of work practices. The programshould define exposure limits for bothworkers and the building environment.

Air monitoring and analysis by PCMrequired by OSHA for exposuremonitoring does not distinguish betweenasbestos and non-asbestos fibers andcannot measure the short or thin fibers thatmight be detected using TransmissionElectron Microscopy (TEM). Airmonitoring data for OSHA exposuremight not be an accurate predictor of TEM


results. Some TEM data indicate thatworkers might be exposed to short or thinfibers when performing O&M activities. O&M activities might create small fiberswhen work such as cutting or drilling ofACM is performed. TEM analysis ofclearance samples is required by thefederal government under AHERA forapplicable school projects involving ACMwhich is or becomes friable.

Initial Exposure Assessment: The monitoring required for an initialexposure assessment is discussed inparagraph (f)(2) of the OSHA constructionstandard 29 CFR 1926.1101: “(I) Eachemployer who has a workplace or workoperation covered by this standard shallinsure that a “competent person” conductsan exposure assessment immediatelybefore or at the initiation of the operationto ascertain expected exposures duringthat operation or workplace.”

Negative Exposure Assessment(NEA): Level A and B work practices areperformed in the open rather than insidean enclosure. To meet OSHArequirements this is possible only if anegative exposure assessment (NEA) ismade. During design and development ofa work practice the NEA must be made. Ifan NEA is not possible, then the workpractice is a Level C and must beperformed inside of an enclosure.

The OSHA construction standard setsforth the criteria that must be met todemonstrate that worker exposures will bebelow the PEL in 29 CFR1926.1101(f)(2)(iii). The followingbriefly outlines the highlights of thatparagraph. The standard should bereferred to when attempting to make anegative exposure assessment. (OSHAtreats intact removal of Resilient flooringdifferently. Refer to the introduction toSection VII, “O&M Work Practices,

Resilient Flooring,” for information on anNEA for resilient flooring.)

A negative exposure assessment can bemade based on exposure data thatconforms to any one of three criteria:

! Objective data: The data mustdemonstrate that a work practiceapplied to a particular product ormaterial cannot “release airbornefibers in concentrations exceeding theTWA and excursion limit under thoseconditions having the greatestpotential for releasing asbestos.” InCompliance Directive CPL 2-2.63OSHA states that, “The employer mayuse data derived from otheremployers’ jobs. The data shouldreflect worst case conditions in avariety of occupational settings.”

! Historical Data: Data from exposuremonitoring performed by theemployer during prior asbestos jobs inthe last 12 months (historic data) canbe used as the basis for an NEA. Thisdata must be from, “work operationsconducted under workplace conditions‘closely resembling’ the processes,type of material, control methods,work practices, and environmentalconditions used and prevailing in theemployer’s current operations, theoperations were conducted byemployees whose training andexperience are no more extensive thanthat of employees performing thecurrent job, and these data show thatunder the conditions prevailing andwhich will prevail in the currentworkplace these is a high degree ofcertainty that employee exposures willnot exceed the TWA or excursionlimit.”

! Initial exposure monitoring: Theresults of initial exposure monitoringfrom the current job can be used as the


basis for an NEA. The data used forthis purpose must be, “from breathingzone samples that are representative ofthe 8-hour TWA and 30-minute short-term exposures of each employeecovering operations which are mostlikely during the performance of theentire asbestos job to result inexposures over the PELs.” The datamust show that exposures areexpected to be below the PEL and EL. This initial monitoring usually occursduring the testing and developmentphase of an O&M work practice.

OSHA governs the employer of theworkers performing the O&M work. Thismeans that for an O&M program wherethe facility maintenance staff are doingwork on ACM, the facility owner ormanager that employs them must performthe negative exposure assessment forLevel A and B work practices.

If O&M work that disturbs ACM (Level Bor C work) is going to be performed by acontractor rather than by facilitypersonnel, then the owner will want toknow that the contractor is complyingwith OSHA. On one hand, it is importantthat the Contractor’s responsibility forworker protection not get confused ordiluted by actions by the Owner orDesigner. On the other, the Owner needsto be reassured that the Contractor isproperly protecting workers, and inparticular that a negative exposureassessment has been properly made. TheNIBS manual Model Guide Specificationsfor Asbestos Abatement andManagement in Buildings containsinformation on this issue. The NIBSGuide Specifications are structured so thata negative exposure assessment is acontract requirement established by theOwner for purposes of insuring that thebuilding is not contaminated by the O&Mwork. The Contractor is required to make

a submission demonstrating that theexposure goals of the specifications can bemet. This is accomplished by submittingdata from prior asbestos projects. Thesubmission on personal samples mustmeet the requirements of an OSHAnegative exposure assessment.

Dust and Debris: Dust and debrisby their nature are easy to disturb, and thedust can become airborne. If the dust anddebris contain asbestos, then thisdisturbance could result in an increasedairborne asbestos concentration. OSHArequires that "Waste and debris andaccompanying dust in an area containingaccessible thermal system insulation orsurfacing ACM/PACM or visiblydeteriorated ACM: shall not be dusted orswept dry, or vacuumed without using aHEPA filter." OSHA, in its November 3,1995 compliance directive, instructs that,“Employers who know, or shouldreasonably know that “unaccompanied”dust is asbestos-containing material(ACM) must also comply with theseprocedures, too. The fact that thestandards do not state explicitly when dustmust be considered as asbestos-containingdoes not mean such situations do not exist. For example, where visibly deterioratedACM is in close proximity to a dustaccumulation, and there is no similar dustaccumulation where ACM is not soproximate or damaged, a reasonableemployer must treat the dust as ACM orhave the situation evaluated by acompetent person.” This instruction isalso a strong inference that, absent anyreasonably discernable source of asbestosfibers, dust may just be dust, andinvestigation, sampling or analysis wouldnot be necessary. If, however, there is anydiscernable connection to nearby ACM,then it must be investigated or presumedto contain asbestos. Asbestos-containingdust and debris should be a controlled


system under the O&M program. If theO&M designer determines that there is apotential for increased asbestos exposuredue to disturbance of dust and/or debris,work practices should be designed forworking on these materials. These workpractices can then be tested using theprocedures in this section, and adjusted asnecessary to meet the exposure goals ofthe O&M program.

The American Society of Testing andMaterials (ASTM) committee D-22.07,Sampling and Analysis of Atmospheresfor Asbestos, has recently published twostandard methods for analysis of dust byTEM. One of these quantifies the numberof asbestos structures per unit area(D5755-95 Standard Test Method forMicrovacuum Sampling and IndirectAnalysis of Dust by TransmissionElectron Microscopy for AsbestosNumber Concentration), the otherdetermines the mass of asbestos per unitarea or the percentage of asbestos in thedust (ASTM method D5756-95 StandardTest Method for Microvacuum Samplingand Indirect Analysis of Dust byTransmission Electron Microscopy forAsbestos Mass Concentration). The

committee is at work on a “StandardGuide for Evaluation of Asbestos onSurfaces” that will give guidance on theinterpretation of results from the ASTMdust sampling methods. Until the guidedocument is complete, each investigatormust make his or her own determinationabout the applicability of data generated.

If the O&M designer is concerned thatthere could be exposures from asbestos indust and/or debris, then this conditionshould be evaluated using the proceduresof this section. An initial exposureassessment should be made, which mayinclude exposure monitoring conductedduring activities that disturb the dustand/or debris, and if possible a negativeexposure assessment should be made. Ifairborne asbestos levels generated duringwork (such as dry sweeping and dustingexceed the exposure goals for the O&Mprogram, then the work practices for theseactivities will have to be adjusted. Ifairborne asbestos levels above theexposure goals are generated by activities,then some remedial work (such as use ofthe cleaning procedures in this manual) isnecessary.


WORKER PROTECTIONThe negative exposure assessment isnecessary for compliance with OSHA forLevel A and B work practices. (Theexception to this requirement ishousekeeping activities under the OSHAGeneral Industries standard, which doesnot provide for a negative exposureassessment.) OSHA requires respiratoryprotection for workers involved withsurfacing and TSI ACM under allcircumstances, and for other materialsunder specified circumstances. However,the building owner can decide to makeworker protection and respiratoryprotection specifications more stringentthan OSHA requirements. Examples of

some requirements used in O&Mprograms that exceed OSHA requirementsinclude:

! Using a PEL of 0.01 f/cc as a TWA.

! Specifying that respirators be worn atall times that an ACM is disturbed.

! Specifying abatement worker training,particularly for Level C work.

! Specifying a wet decontaminationprocedure for O&M workers at theend of their shift.

! TEM analysis in addition to PCManalysis of some air samples.

ADJUSTING THE WORK PRACTICE Sometimes a work practice may be unableto achieve the levels required by theairborne asbestos goal, or it may beunnecessarily stringent. The intensity atwhich asbestos control techniques (carefulhandling, wetting, local area exhaust withHEPA vacuum, area exhaust) are appliedshould be adjusted until the airborneasbestos goals are met. Care should beused to be sure that the finalized workpractice is simple to apply, as fail-safe aspossible and that it will meet the goalsunder a variety of conditions and a rangeof care on the part of workers. The workmay be performed by different workersunder a variety of temperature and

humidity conditions with varying amountsof time pressure. In time some workersmay become jaded and less careful, ormore practiced and more proficient. Thework practice needs to reliably meet theairborne asbestos goals under a variety ofreal world conditions, and needs to besubjected to consistent and effectiveoversight and management. Unless anegative exposure assessment has beenmade, periodic exposure monitoring willbe necessary until a statistically reliablemeasurement demonstrating consistentsuccess of the work procedure isdeveloped.


NUMBER OF WORKERS

Each work practice summary includes arecommendation on how many workersare needed to perform the work. Anumber of factors should be consideredwhen determining how many workers areto be assigned to perform an O&Mactivity, such as:! Regulatory requirements! The amount of work to be done! Accessibility to the work area (height,

enclosure)! Worker skill, training and experience! Weight, size or length of objects

involved in the work! Worker safety or degree of risk! Work efficiency and cost effectiveness

One worker is recommended where the

work practice can be accomplished safelyand effectively with one worker. Two ormore workers are recommended for workpractices involving enclosures, glovebagsor where special conditions or otherfactors complicate the work. State or localregulations may dictate the number ofworkers needed. General ProcedureAPM5 includes additional information onassigning workers.


EXAMPLE The following is an example of the stepsneeded to design and test a work practicefor the XYZ Office Building in AnytownUSA. This example is intended to helpclarify the steps needed to develop anO&M work practice for a facility.

Policy and Organization: Upon theadvise of the O&M designer, the buildingowner established 0.01 f/cc by PCM as thepermissible exposure limit for the O&Mprogram for both workers and the buildingenvironment. In addition, regardless ofairborne exposure levels, workers arerequired to wear respirators and protectiveclothing for any activity that could disturbasbestos. Air in the building will besampled and analyzed by TEM on aperiodic basis. These are selected as beinga easily achievable goals that exceedregulatory requirements.

Selecting a work practice: The firstwork practice that is needed is one to usewhen gaining access through metal panceilings where there is debris on top of theceiling from asbestos-containingfireproofing on structural steel in theplenum space above the ceiling. There isknown to be asbestos debris on top of thetiles. The designer selects work practiceS-1 “Moving one non-asbestos-containingceiling panel below a plenum space thathas exposed surfacing ACM,” as being theclosest to the situation that exists in thebuilding.

Modify the Work practice: Workpractice S-1 is for a lift-out type of ceiling. Ceilings in the facility are metal pans thatsnap in and out of a grid (with somedifficulty). During the 30 years since thebuilding was constructed the ceiling hasbeen opened in all locations where there ismaintainable equipment above the ceiling. The ceiling tiles are easily damaged and

disfigured when removed. The facilityhas a specific procedure using specialtools for removing and replacing the metalpans so that they are not damaged. TheHEPA vacuum/ careful work practices ofS-1 are incorporated into the metal panremoval procedure. To make the O&Msimpler, the work practice is to be a LevelB work practice.

Testing the Work Practice: TheO&M designer has data from previousO&M programs that indicate that theairborne asbestos goals of the O&Mprogram can be met using Level B workprocedures. The O&M designer uses thisdata as the basis of an Initial ExposureAssessment that allows the work toproceed using Level B work practices. The O&M designer works cooperativelywith the workers who need to be trained inthe asbestos control procedures to usewhen removing ceiling pans. The workersknow how to remove ceiling pans in theparticular building, the O&M designerknows how control asbestos. Workingtogether they further develop theprocedure so that it accommodates fieldconditions. During the work, personalsamples are collected in the breathingzone of the workers performing the ceilingwork. High volume samplers are used tocollect area samples at each of the foursides of the drop sheet. The work ofremoving and replacing ceiling tiles andperforming necessary maintenance abovethe ceiling is continued for the day usingLevel B work practices. At the end of theday’s work, 16 area and 4 personalsamples have been collected and analyzed. The personal samples are all below theOSHA PEL (0.1f/cc), but above 0.05f/cc. The facilities worker exposure limit of0.01 f/cc can be met with the use of half-face negative pressure respirators. All


samples are below the OSHA PEL so thata negative exposure seems likely. Thedesigner decides that more personalsamples are necessary before there issufficient statistical certainty about theresults to make a negative exposureassessment. The area samples are allbelow the detection limit of the analyticalmethod. The O&M designer concludesfrom this that the exposure limit for thebuilding environment of 0.01 f/cc is beingmet.

Adjusting the Work practice: TheO&M designer and workers decide to tryan additional misting step to furtherreduce worker exposures. This succeedsin reducing exposures to just above 0.01f/cc in personal samples for workers usingthe procedure.

Negative Exposure Assessment: After two more days of personal samplingthe O&M designer is satisfied and makes anegative exposure assessment based on thethree days of exposure monitoring. Allmonitoring is discontinued. The workpractice is made a part of the asbestosO&M program for the building. Note thatin this example the negative exposureassessment is necessary to allow the workpractice to be used without enclosures, butis not used to determine workerrespiratory protection requirements. Thefacility’s limits for worker exposure is metby requiring the use of a negative pressurehalf face respirator.

5 - 1 # Use of O&M Work Practices # Asbestos O&M Work Practices # © NIBS 1996 # Page - 39

5. Use of O&M WorkPracticesLists of Work Practices andWork Practice Summaries Listsof the work practices in this manual areprovided in the Table of Contents and atthe beginning of each section of workpractices. The first page of each workpractice is a summary of the work practiceand lists examples of typical situations,associated general procedures, relatedwork practices and certain basicinformation about the practices. Arecommended minimum number ofworkers is listed for each work practice. A further discussion of the number ofworkers for O&M activities is includedlater in this section.

Using Work Practices Thissection describes one method of using thework practices that have been developedand validated in the previous section. TheAPM will select the work practices to beused. A decision tree illustrating thisselection process is shown in Figure 3. Guidance for selecting the appropriatework practice level is shown in Figures 1and 2. The process of using workpractices developed from this O&M WorkPractices Manual, or alternatives based onthis manual, for a given situation can besummarized as follows:

1. A Job Request Form (Appendix A)should be completed for work thatcould disturb ACM. (Note to APMs: Ifthe required work has been performed inthe past, it might not be necessary tocomplete an APM checklist for each O&Mactivity. Past checklists can be reused forthe selection of work practices.)

2. The Asbestos Program Managershould complete an APM checklist

(Figure 3) and evaluate the work to beperformed based upon the informationon a completed Job Request Form,available survey and assessment data,and data on past O&M activities (ifavailable). When reviewing data andcompleting the APM checklist, thefollowing should be determined:

! Whether the job requested isactually an asbestos O&Mactivity.

! The category(ies) of ACM thatmight be encountered during thework.

! The appropriate work practice(s)to address the situation. The workpractice summaries include asection of "related work practices"that are intended to aid the APMin the selection of the proper workpractice.

! The appropriate level of workpractice(s) to be used.

! Personal protective equipment, ifany, for the work.

3. All of the above information shouldbe recorded on a Maintenance WorkAuthorization Form (see Appendix B). The completed APM checklist shouldbe signed, dated and filed.

4. Copies of information as listed on theAPM checklist should be provided tothe workers who will perform thework, along with the appropriate workpractice checklist. If repetitive O&Mactivities using the same workpractices will be performed insequence over a short period of time, asingle Maintenance Work


Authorization Form may be completedto cover these situations for a singlebuilding. Note, however, that theNESHAP requirements apply to afacility if the combined additiveamount of Regulated AsbestosContaining Material (RACM) that willbe removed or stripped in repetitiveactivities exceeds the quantitiesspecified in NESHAP (260 linear, 160 square, or 35 cubic feet of ACM). Repetitive tasks might increaseexposure levels such that morestringent OSHA worker protectionand engineering control requirementsare triggered. Caution should be used to insure that each of the repeatedO&M activities is a discrete O&Mactivity. O&M work procedures arebased on disturbing a small amount ofmaterial over a short period of time. Care must be taken to avoid violatingthe intent by allowing contiguousactivities that add up to a larger scaleprocedure and a potentialaccumulation of contamination. If anumber of O&M activities need tooccur at one time in one location, itmight be preferable to treat the workas a larger scale, non-O&M activity. The APM can set limits appropriatefor a facility and O&M program thatare based on quantities of ACM to bepotentially disturbed in single andmultiple O&M activities. Exposuremonitoring procedures and methodsfor repetitive activities might need tobe more stringent than for singleactivities. The forms used inAppendices A, B and C of this O&MWork Practices Manual arereproduced from the EPA Green Bookfor use or guidance. Users of this

manual can use these as a basis fordeveloping forms for their O&Mprogram and work permit process. Itis recommended that O&M formsinclude the basic categories ofinformation that are used on the GreenBook forms.

5. An initial exposure assessment willhave been made during design of thework practices. However, in instanceswhere ACM could be disturbed,OSHA requires that personal airmonitoring (periodic monitoring) beperformed for work practices unlessemployee exposures, as indicated bystatistically reliable measurement, arebelow the OSHA permissibleexposure limits (see OSHAregulations for details). OSHArequires that employees be informedin writing of the results of exposuremonitoring either individually or byposting the data in a central locationthat is accessible to affectedemployees. Data generated duringthis periodic monitoring can be usedby the APM during futuredevelopment of work practices. IfO&M activity data are to be used toqualify for OSHA historical dataexemptions or for maintaining OSHAexposure records, it is necessary thatthe information be kept in strictaccordance with the requirements ofthe OSHA construction standards (29CFR 1926.1101(n) and 1926.33). Thework practice user is responsible forproving compliance with allapplicable federal, state and localregulations. Based upon the dataobtained, the APM might decide to


use a higher or lower level of workpractice for a specific task. Substantiallymore data are required to justify the use oflower level work practices. Any dataindicating higher exposures thananticipated warrant consideration ofmoving to higher level work practices. Work practice levels may be modified asnoted in Figure 1 based upon historical airmonitoring data (additional information onhistorical data is provided in GeneralProcedure APM6). Note also that state orlocal regulations may require morestringent work practices, higher levels ofprecaution or additional monitoring.

Work Practice Checklists Thework practice selection process outlinedabove and additional information relatedto the selection and use of the workpractices are compiled on the "AsbestosProgram Manager Checklist" shown inFigure 3.

Checklists to be used by workers for eachlevel of work practice are shown on"Worker Checklists" in Figures 4, 5 & 6. A checklist is to be provided to the workerwith each work practice in order to givethe worker complete information requiredto perform the work.

II. Asbestos Program ManagerGeneral Procedures

APM - 2 # Asbestos Program Manager General Procedures # © NIBS 1996 # Page - 44

Figure 4: APM Checklist Asbestos Program Manager (APM) Checklist for Operations andMaintenance Work Practice Use ~ Receive and review Job Request Form - See Appendix A.

Work to be performed:

~ Review or request survey data to determine whether ACM is affected.

~ Complete Maintenance Work Authorization Form, including: - See Appendix B. ~ Review historical air monitoring data for work practices to be used. ~ Work Practice(s) selected for all ACM to be encountered -

See Section I - Figures 1, 2. ~ Select personal protective equipment and decontamination requirements

to be used, if needed - See General Procedure APM1. ~ Select appropriate materials and review potential hazards (confined

spaces, scaffold use, etc.) - See General Procedures APM8 & APM9.

~ Schedule work when area is not in use or plan developed to isolate area (if necessary) -

See General Procedure APM2.

~ Federal, state and local notifications filed (if applicable) -


~ Notify personnel affected by work - See General Procedure APM4.

~ Assign workers (or contractor) with appropriate level of training. Verify currency of training,fit tests, and medical surveillance - See General Procedure APM5

~ Assign trained air monitoring person and determine air monitoring to be performed (if needed).Record air monitoring requirements on Maintenance Work Authorization Form -


~ Provide copies to workers/contractor of: ~ Maintenance Work Authorization Form ~ Work practice checklist for proper work level. ~ Work practice(s):_____________________________________________ ~ General Procedure(s) ~ Notifications ~ Schedule of work

~ As practical, review work practices during work for compliance with requirements and workergeneral procedures.

~ Complete Evaluation of Work Affecting ACM form - See Appendix C.

~ File all required records in proper files - See General Procedure APM7.

Signature: __________________________ Date: ___________________________


Section II Asbestos Program Manager General Procedures

All references in this manual to AsbestosProgram Manager (APM) refer to a persondesignated to perform the AsbestosProgram Manager's duties. This could bethe building manager, owner, or anotherperson reporting to the APM.

The Asbestos Program Manager or adesignee should review work practiceswith the workers who will perform thework. Workers should be notified toconsult with the APM or the APM’sdesignee if they have any questionsduring the work, if any problems occur, orif it appears to the workers that additionalprecautions might be necessary to safelyperform the work.

This section includes detailed proceduresfor steps that are common to many of thework practices. These general proceduresare referenced in the work practices and in

the APM checklist. The generalprocedures should be covered in O&Mtraining related to the use of this manual.

Not all of the general procedures are usedin every work practice. The workpractices and checklists refer the user toapplicable general procedures for detailedinformation on how to perform a certainportion of the work. Once a user isfamiliar with the general procedurerequirements, it might not be necessary toreview the general procedures each timean O&M activity is performed. However,the general procedures should be reviewedperiodically by the APM to verify that theproper procedures are being followed.

Users of the O&M Work Practices Manualshould also review the General SafetyConsiderations information in AppendixH.

APM Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

APM 1 Selection of Personal Protective Equipment & Decontamination Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

APM 2 Work Scheduling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47APM 3 Federal, State and Local Notification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47APM 4 Notification of Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48APM 5 Assigning Workers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48APM 6 Developing the Air Monitoring Program and Assigning Air

Monitoring Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49APM 7 Record keeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51APM 8 Confined Spaces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51APM 9 Selection of Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52APM 10 Emergency Work and Dry Removal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

Note: Not all of the general procedures are used in every work practice.


APM 1 Selection of PersonalProtective Equipment &Decontamination Procedures Selecting personal protective equipment(PPE) for O&M work includes theselection of respirators, protectiveclothing, gloves, boots, hardhats, and/orother equipment that might be necessaryfor a specific task. The information inAppendix H discusses general safetyconsiderations that may affect equipmentselection.

Respirators A respiratory protectionprogram is required for any work thatrequires the use or respirators. This mustbe a written program, and must includeworker training and medical surveillance. The program must clearly inform theworker about the type and level ofrespiratory protection required for eachactivity. The worker must be fit tested fora respirator and a respirator must beprovided. Th e worker must be trained inthe proper use, care and maintenance ofrespirators. The medical monitoring mustinclude a physician’s opinion that theperson is able to wear a respirator.

Respirators used for O&M activities mustbe selected based on the requirements ofregulations and a Respiratory ProtectionProgram developed in accordance withOSHA standards 29 CFR 1926.1101(h), 29 CFR 1910.134 or the EPA "WorkerProtection Rule" (40 CFR 763.120,121),as applicable, for the O&M workers. Appendix E of the Green Book includesEPA's recommendations on the types ofrespirators to be used for custodial andmaintenance tasks. Liability concerns,historical data and management policiesmight also influence whether respiratorsare used, and if so, the type of respiratorsfor O&M activities. NIOSH recommendsminimizing occupational exposure tocancer producing sub-stances, such asasbestos to the lowest feasible level. Inpractice, a maximum exposure level forworkers of 0.01 fibers per cubic

centimeter of air inside the respirator iscommonly used when respirators areselected using protection factors.

OSHA has stated that significant riskremains at the OSHA permissibleexposure limit. As such, OSHA requiresrespirator use in some situations (such aswhen working on Surfacing or TSI ACM)regardless of exposure levels. The EPA'sWhite Book and the Introduction andSection 01562 of the NIBS AsbestosAbatement Guide Specification containinformation regarding respirator selectionthat might be helpful to the APM. Reviewof this additional information is stronglyencouraged.

In certain situations, full face respiratorsmight be desirable to provide additionaleye and face protection for workers. Powered Air Purifying Respirators(PAPR's) are preferred by many workersinstead of negative pressure respirators. OSHA regulations 29 CFR 1910.1001 and29 CFR 1926.1101 require that anemployer provide a PAPR in lieu of anegative pressure respirator if anemployee chooses to use this type ofrespirator.

Depending upon the type of work andwork practices to be used, combinationrespirator filter cartridges or a differenttype of respirator might be necessary toprotect workers from other contaminantsor hazardous substances. Respiratoryprotection for asbestos work requires theuse of high efficiency particulate air(HEPA) filter cartridges.

Protective Clothing &Decontamination Procedures Protective clothing for O&M worktypically consists of disposable coveralls,gloves and/or boots. Protective clothingfor O&M work can be selected by theAPM or the worker, depending upon theO&M procedures. Protective clothingoptions that are typically used are


APM 1... continueddiscussed in Worker General ProcedureW7. The protective clothing optionselected might depend in part upon thedecontamination procedures to be usedand the type of work area preparation orenclosure.

Decontamination procedures typicallyused for O&M work include HEPAvacuuming on a drop cloth, changing in a

change room, or showering. WorkerGeneral Procedure W15 explains thedecontamination process for each option. The APM might also determine whetherboots, gloves, hardhats or other protectiveequipment is needed for O&M tasks. Protective clothing selections made by theAPM should be recorded on theMaintenance Work Authorization Form.

APM 2 Work Scheduling Level B and Cwork should be scheduled for a time whenthe work area will not be in use and can beclosed off to anyone other than trainedworkers, or other authorized personnel. Ifan area is always occupied, plans shouldbe made to isolate the work area frombuilding occupants using visual and/orphysical barriers. If a special work areaarrangement is required, it might bebeneficial to provide a sketch to theworkers showing how the area is to be setup. If respirators are used for Level Aactivities, it might be desirable to vacate

the area to avoid concerns resulting from aworker in a respirator working withinsight of unprotected workers/occupants.

Scheduling of work might be affected bynotification requirements. All notificationrequirements should be met before work isscheduled. Under certain circumstances,some emergency work can be performedprior to the filing of a notification. Review regulations and contact federal,state and local regulatory agenciesconcerning notification requirements foremergency work.

APM 3 Federal, State and LocalNotifications The Asbestos ProgramManager, or his designee, should file allnotices required by federal, state and localregulations prior to the start of any O&Mactivities that are governed by theseregulations.

Federal Notifications Federalrequirements for notification are set forthin the National Emission Standards forHazardous Air Pollutants (NESHAP) rulesand the EPA Worker Protection Rule. Fordemolition and renovation work, the latestNESHAP revisions are contained in 40CFR 61.145 (a) and (b). A ten workingday federal notification is required forrenovation work if the combined amountsof regulated asbestos-containing material(RACM - see glossary or NESHAP fordefinition) to be stripped, removed,dislodged, cut, drilled or similarlydisturbed is over 260 linear feet (80 linearmeters), 160 square feet (15 squaremeters) or 35 cubic feet (1 cubic meter)

for any single project. EPA’s NESHAPrules specifically warn that “singleprojects” cannot be subdivided intosmaller projects in an attempt to avoidnotification requirements.

Also, if the combined estimated quantitiesof RACM to be removed or stripped inindividual nonscheduled operations duringa calendar year (January 1 throughDecember 31) exceeds the amounts listedabove, a NESHAP notice must besubmitted at least ten working days beforethe end of the calendar year (e.g.December 15) preceding the year forwhich notice is being given. A newwritten notice must be filed with the EPAif the start date for a project is revised(earlier or later) from the date filed in theoriginal or a previous notice. A noticemust be updated if the amount of asbestosaffected changes by 20 percent or more.

If wetting of RACM during removal


APM 3... continued would unavoidably damage equipment orpresent a safety hazard, written approvalfrom the EPA is required for alternativeemission control methods (dry removal).

The NESHAP notification requirementsfor emergency renovation work are setforth in 40 CFR 61.145 (a) and (b). Moreinformation on emergency work isincluded in General Procedure APM10.

See Appendix I (2.B and 2.D) of thismanual and the NESHAP regulations fordetails on Federal notificationrequirements. Additional requirementsmight also be included in state or localregulations.

State and Local NotificationRequirements State and localnotification requirements vary greatly. Many states and localities havenotification requirements that are morestringent than the federal requirements. State and local requirements concerningpermits for any repair or renovation workmust be reviewed. State and localrequirements must be complied withbefore work is scheduled and commenced. The EPA Regional Contacts (listed onpage 37 in the Green Book) can provideinformation on obtaining copies of stateand local regulations.

APM 4 Notification of Personnel Persons who use, occupy, or are affectedby an area where ACM work will occurshould be notified prior to the start of thework. OSHA regulations includemandatory notification of certainpersonnel prior to the performance ofwork regulated by OSHA. The followingemployers should be notified about thepresence, location and quantity of ACM orPACM:

C Prospective employers applying for orbidding for work,

C employees of the owner,

C all employers on multi-employer worksites,

C tenants occupying areas.

This notification is required if theseemployers or their employees will beperforming work in or adjacent to areas

where ACM or PACM is located.

Notification of personnel is usually notnecessary for Level A O&M activities asthese activities do not disturb ACM. Personnel should be given informationabout the specific work to be performed,the work schedule, precautions beingtaken, what will be visible during thework, and that posted warning signs mustbe obeyed. Section 4 of the Green Bookincludes information on occupant, tenantand worker notification of the presence ofACM that might be helpful to the APM.

If O&M work occurs frequently, or forLevel A Tasks where notification isneeded, a general notice to affectedpersonnel might be more convenient thannotifying these personnel each time workoccurs. State and local regulations mayalso include personnel notificationrequirements.

APM 5 Assigning Workers Workersassigned to perform O&M work shouldhave training and experience in the skillsand techniques required for the type ofwork to be performed, training inapplicable asbestos O&M procedures, theO&M plan for the facility, and site-specific building conditions. The EPAGreen Book gives guidance concerning

the level of training recommended forconducting different types of O&Mactivities. EPA and OSHA offices mightbe able to direct the user to listings oftraining providers.

The AHERA regulation for schoolsincludes required O&M training andoutlines a minimum training program.


APM 5... continued The OSHA construction standardcontains

minimum training requirements forconstruction workers (includingmaintenance and custodial workers) whodisturb or contact ACM. Paragraph (k)(8)of 29 CFR 1926.1101 provides minimumtraining requirements for maintenanceworkers involved in Class III and IVwork, and for workers whose onlyinvolvement with ACM is Class II workencompassing resilient floor coveringoperations. State and local regulationsmay impose training requirements forO&M activities. Verify that state andlocal requirements are met beforescheduling work. Additional trainingmight be desirable for performing frequentO&M work or certain O&M tasks. Beforeworkers are assigned to O&M work, theAPM should verify that their training,respirator fit tests and medical surveillanceare current and in compliance with

regulations (where applicable) and therequirements of work practices to be used. Appendix I in this manual gives guidanceon where to find applicable regulatoryinformation and Green Book guidance onthese topics.

Depending upon applicable regulations(such as OSHA, and NESHAP, state orlocal), a designated trained or "competentperson" might be required to perform orsupervise certain aspects of the work (seeAppendix I for more information). OSHArequires that a competent person performthe initial exposure assessment and tomake frequent and regular inspection ofthe jobsite for all operations covered underthe standard. Section 4 of this manualdiscusses factors to consider whendetermining the number of workersrequired for an O&M activity. Onceworkers are selected for a task, the APMshould review the work practice with theworkers, if needed.

APM 6 Developing the Air MonitoringProgram and Assigning AirMonitoring Personnel Note: This section is not intended as asubstitute for a complete Air MonitoringProgram that is needed for O&M work. Thissection notes air monitoring issues that theAPM needs to address for O&M work.

Owners might choose to use an outsideconsultant to perform air monitoring forO&M activities. In certain cases, wherefrequent O&M activities are performed,the O&M program might include havingone or more designated trained workersperform air monitoring during O&Mactivities. In either case, an AirMonitoring Program should be developedby the air monitoring personnel orconsultant and the APM for O&Mactivities. The Air Monitoring Programshould specify when air monitoring willbe performed, the types of monitoring(personnel, background, area, clearance,periodic, and/or initial), analysis methods,training requirements for monitoring

personnel, and procedures for maintainingdata from O&M activities, including anydata required for a negative exposureassessment. Air monitoring data shouldbe considered when selecting the type ofrespirators for activities that userespiratory protection.

Training might be required by the AirMonitoring Program or state or localregulations, and could include a NIOSHair monitoring course, industrial hygienetraining or other requirements. Trainingfor persons performing air monitoringwork should include hands-on trainingwith the equipment to be used. Trainingfor air monitoring that is currentlyavailable consists primarily of coursesmeeting the National Institute forOccupational Safety and Health (NIOSH)582 requirements.

Air monitoring exemptions orrequirements for a given work practiceshould be based on the Air Monitoring


APM 6... continued Program and stated on the MaintenanceWork Authorization Form. Exposuremonitoring should be addressed in the AirMonitoring Program and is required foroperations covered by OSHA regulationsunless requirements for termination ofmonitoring have been met during programset up or after initial monitoring. Reviewthe applicable OSHA standards in detailwhen developing air monitoringprocedures for O&M work.

Exposure monitoring is required followingchanges in work practices, employees,employee skill levels, or other pertinentfactors which could lead to the OSHAaction level or exposure limits beingexceeded. Personal monitoring shouldconsist of samples to obtain an 8 hourtime- weighted average (TWA), ifpossible, and excursion limit (EL)monitoring samples. All analysis forOSHA compliance should be by phasecontrast microscopy (PCM) using theOSHA Reference Method (ORM) (29CFR 1926.1101 Appendix A) or NIOSHMethod 7400 Method. Transmissionelectron microscopy (TEM) analysis willdistinguish asbestos fibers from otherfibers and might also be used if desired tosupplement the PCM data required byOSHA. TEM analysis should beperformed in accordance with theanalytical method in the AHERAregulation (40 CFR Part 763 Appendix A)or Yamate Level II. TEM data cannotsubstitute for OSHA required PCM dataunless approved by the local OSHAoffice.

The air monitoring performed for OSHAexposure monitoring does not distinguishbetween asbestos and non-asbestos fibersand cannot measure the short or thin fibersthat may be detected using transmissionelectron microscopy (TEM) analysis. Short or thin fibers may be found inairborne asbestos levels generated duringdisturbance of asbestos-containingmaterials manufactured with such fibers(e.g. resilient flooring), or where the

disturbing process grinds fibers down(such as during sawing, sanding orgrinding). Air monitoring data for OSHAexposure may not be an accurate predictorof TEM results. Clearance monitoringusing TEM analysis is required by thefederal government only under AHERAfor applicable school projects involvingACM which is or becomes friable. SomeTEM data indicate that workers may beexposed to short or thin fibers, which arenot counted in air monitoring analysisunder the OSHA standard, when engagedin activities that disturb ACM. Ifclearance monitoring requiring TEManalysis is specified, the results can beaffected by short or thin fibers which maybe generated when attempting to followO&M procedures and/or by nearby joboperations involving ACM.]

The sampling and TEM analysis ofsettled dust to evaluate areas for cleaningor precleaning prior to an O&M activitymay be considered. Although currentregulations do not require this type oftesting, dust sampling is presented as anavailable analytical tool that may be usedto make recommendations for cleaningand other corrective measures. Settleddust sampling can also be used duringO&M activities to document disturbancesof ACM during the activity. Additionally,settled dust sampling might be used aspart of a clearance protocol for O&Mwork. Since no current regulatorystandards for asbestos dust sampling havebeen set by government agencies, an APMmight want to consult with experiencedlaboratories or consultants regarding thelatest settled dust sampling procedures andprotocols. Procedures in use to samplesettled dust include microvacuuming (seedust and debris paragraph), surface wipesampling, passive dust sampling and tapelift methods.


APM 7 Record keeping The Green Bookrecommends that the following records ofO&M work be retained in permanent files:

! Inspection and Assessment Reports! A copy of the O&M Program (initial

program and all updated versions)! The Work Practices Used! Respiratory Protection Program! Fiber Release Reports! Job Request Forms! Maintenance Work Authorization

Forms! Evaluations of Work Affecting ACM! Reinspection/Periodic Surveillance

Reports

For employers with employees engaged inasbestos-related work, federal regulationsrequire that the employer retain:

! Personal Air Sampling/Exposure Monitoring Records

! Historical Data (used to qualify forexemptions from OSHA's initialmonitoring requirements)

! Medical Records (for employeessubject to a medical surveillanceprogram)

! Employee Training Records! Fit Test Records (for employees that

use respirators)! Data to rebut presumption that

materials are asbestos-containing.

This O&M guidance manual alsorecommends that records be maintainedfor:

! Waste Tracking and Disposal- See Appendix D.

! Air Monitoring Data! Qualifications and Performance

Records for Outside Contractorsperforming O&M work

If settled dust sampling is used it isadvisable to maintain these records also.

OSHA requires that employers provide toeach employee their record of exposureand medical surveillance under theRecords Access Standard (29 CFR1910.20) and the Hazard CommunicationStandard (29 CFR 1910.1200 & 1926.59)and the construction asbestos standard (29CFR 1926.1101(n). Also see the OSHAAsbestos Construction Rule (29 CFR1926.1101), the EPA Worker ProtectionRule (40 CFR 763 Subpart G) and theGreen Book for details on Record keepingrequirements. Note that state and localregulations may require that additionalinformation be recorded and retained.

EPA recommends that building ownersmake available all written elements of theO&M program to the building's O&Mstaff as well as to tenants and buildingoccupants, if applicable. Building ownersare also encouraged to consult with theirlegal counsel concerning appropriateRecord keeping strategies as a standardpart of their O&M programs.

APM 8 Confined Spaces Confined spacesare often encountered in O&M work. Probably the most common areasencountered are crawlspaces, utility andpipe tunnels, manholes and chases. Special precautions are necessary forworking in confined spaces. A confinedspace program, including an entry permitsystem, must be developed for use whenPermit Required Confined Spaces must beentered. The APM or another staff person

should be able to identify and assesshazards associated with confined spaces. Procedures should be developed toaddress potential confined space hazards. NIOSH publication number 87-113 (July1987), entitled "Guide to Safety inConfined Spaces", includes a checklist forsafe entry into confined spaces, as well asgeneral information on confined spaceissues.


APM 8... continued Confined space hazards include, but arenot limited to:

! Oxygen deficiency or enrichment! Engulfment! Toxic atmospheres (gases, vapors and

dusts)! Hazardous chemicals! Explosive atmospheres! Heat stress! Fire! Retention of dust and smoke! Insufficient lighting! Flooding! Electrical shock hazards! Noise

Program elements should include:

! Entry and exit procedures! An entrant, an attendant, and a person

authorizing entry! Standby/emergency rescue procedures! Head protection (from bumps, scrapes,

cuts, abrasions)! Worker communication procedures! Entry permit system! Atmosphere monitoring! Ventilation! Isolation! Respiratory protection

Depending upon the hazards present,monitoring and special precautions mightbe needed during the work to maintain asafe work area. OSHA regulation 29 CFR1926.20(b) (General safety and healthprovisions, Accident preventionresponsibilities); and 29 CFR1926.21(b)(6) (Safety training andeducation, confined or enclosed spaces)are the regulations that cover confinedspaces on construction work sites. 29CFR 1910.146 governs requirements forconfined spaces in general industry. Thisstandard may be considered byOccupational Safety and Health ReviewCommission (OSHRC) and the courtswhen evaluating citation in theconstruction industry under the lessspecific construction standards. OSHA iscurrently considering extending thegeneral industry standard to construction. The user of this manual might wish toobtain and review a copy of regulationscited above if confined spaces will beencountered in O&M work.Appendix H includes general informationon safety considerations that should bereviewed if work will take place inconfined spaces.

APM 9 Selection of Materials TheAsbestos Program Manager should beresponsible for the selection of certainmaterials used for O&M activities. Thismanual will not attempt to give guidanceon the selection of all materials needed forO&M work. Information on selection ofthe following materials is provided: ! Polyethylene! Lockdown encapsulants

Guidance on the selection of othermaterials should be obtained in trainingcourses, or from reference materials, suchas the NIBS Guide Specifications forAsbestos Abatement.

Polyethylene Various thicknesses,colors and types of polyethylene areavailable. 6 mil actual not nominalthickness ( 0.15 mm) polyethylene should

be used for all asbestos work. State orlocal regulations may require that certainthicknesses or types of polyethylene beused, or that fire resistant polyethylene beused. Two and four mil (0.05 and 0.10mm) polyethylene is also available, butdoes not comply with OSHA requirementsand should not be used for asbestos O&Mwork. Polyethylene is also available infire retardant, anti-slip and anti-statictypes. Fire retardant polyethylene doesnot support flame as readily as standardpolyethylene. However, some tests haveshown only minimal differences in flamespread time between standard and fireretardant poly.


APM 9... ContinuedAnti-static polyethylene should be usedaround equipment sensitive to staticelectricity.

Lockdown Encapsulants Lockdown encapsulants selected shouldbe appropriate for the intended use. Usehigh temperature rated encapsulants forheating system components such aspiping, boilers & flues. Lockdownsshould also be compatible with anyreplacement materials, such as newfireproofing and flooring adhesive.

Compatibility should be verified prior tothe start of work.

It is particularly important to make surethat any encapsulant used as a lockbackwill not adversely affect the fire protectionrating of fireproofing materials. The fireprotections ratings of spray fireproofingare based on full-scale fire endurance testsof fireproofed steel. Anything that differsfrom the tested assembly voids the rating,and could result in a fireproofing failure. Refer to the introduction to the workpractices for surfacing materials for moreinformation on the use of encapsulantswith spray fireproofing materials. Someencapsulants have been tested with somefireproofing materials. Check with themanufacturer of the fireproofing that is tobe used to find out if it has been testedwith any lockback encapsulants. Select an

encapsulant and fireproofing material thathave been tested together. Beforeapproving use of an encapsulant get awritten certification from the fireproofingmanufacturer that the encapsulant iscompatible with the fireproofing. Somefireproofing systems use an adhesive onsteel before application of the fireproofingmaterial. This adhesive can be used inlieu of an encapsulant as a lockback.

Lockdowns are available in clear orcolored mixtures. Clear mixtures shouldbe used where a colored encapsulantwould be objectionable for appearancereasons. Colored encapsulants should beused (where possible) with a color chosento indicate that an area has been lockeddown. If applying two coats, two differentcolors can be used to make completecoverage by both coats more easilyobservable. The color also allows aworker to see where encapsulant has beenapplied during the application.

Certain lock-down encapsulants can posea problem in confined spaces and causethis work to require a confined space entrypermit. The PEL’s of certain componentsof lock-down encapsulants if appliedinappropriately on in quantities exceedingthe manufacturer’s directions may cause atoxic atmosphere.


APM 10 Emergency Work and DryRemoval O&M activities sometimesrequire that regulated asbestos O&M workbe performed immediately to maintainoperations and prevent other health orsafety hazards. Emergency work isacknowledged in regulations and ispermitted under certain conditions. TheNESHAP regulations specify that anotification for emergency renovationoperations must be postmarked ordelivered "as early as possible before, butnot later than, the following working day"(see regulation for full text). State or localregulations may have additionalrequirements.

Emergency work might involve activities(such as work around activated electricalequipment) where the use of wettingwould result in equipment damage or asafety hazard. NESHAP permits workwithout wetting regulated ACM undercertain conditions (see regulation fordetails). For facilities where dry removalwork might be required, the APM shouldreview regulatory requirements in advancewith authorities having jurisdiction overthe facility. OSHA requires the use of aself-contained breathing apparatus(SCBA) in emergency situation whereasbestos fiber concentrations areunknown.

III. Worker General Procedures

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W - 3 # Worker General Procedures # © NIBS 1996 # Page - 57

Section III Worker General ProceduresThis section includes detailed proceduresfor steps that are common to many of thework practices. These general proceduresare referenced in the work practices and inworker and APM checklists. The generalprocedures should be reviewed in detail byall personnel using this work practicesmanual. If possible, the general proceduresshould be covered in O&M training relatedto the use of this manual.

The work practices and checklists refer theuser to applicable general procedures fordetailed information on how to perform acertain portion of the work. Once a user isfamiliar with the general procedurerequirements, it might not be necessary to

review the general procedures each time anO&M activity is performed. However, thegeneral procedures should be reviewedperiodically by all workers and the APM toverify that the proper procedures are beingfollowed.

Workers should report any suggestions orproblems regarding these work practices totheir supervisor, the Asbestos ProgramManager (APM) or the APM's designee.

Users of the O&M Work Practices Manualshould also review the General SafetyConsiderations information in Appendix Hof this Manual.

Level A Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58Level B Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59Level C Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

W1 Tools, Equipment and Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61W2 Preparing Amended Water or Removal Encapsulant . . . . . . . . . . . . . . . . . . . . . . . 61W3 Shut-off and Lockout of HVAC and Electrical Systems . . . . . . . . . . . . . . . . . . . . 62W4 Securing Work Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62W5 Critical Barriers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62W6 Putting on Respirators and Performing Fit Checks . . . . . . . . . . . . . . . . . . . . . . . . 63W7 Putting on Protective Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63W8 Beginning and Conducting Air Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64W9 Wet Wiping, HEPA Vacuuming and Steam Cleaning . . . . . . . . . . . . . . . . . . . . . . 65W10 Polyethylene Drop Cloth . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66W11 Packaging and Labeling Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66W12 Applying Lockdown Encapsulant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68W13 Cleaning Tools, Equipment and Work Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68W14 Decontaminating Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69W15 Worker Decontamination and Removal of

Protective Clothing and Respirators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69W16 Visual Inspection and Completing Air Monitoring . . . . . . . . . . . . . . . . . . . . . . . . 70W17 Waste Transportation, Storage and Disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71W18 Glovebag Removal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71W19 Disposal of Contaminated Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74W20 Mini-enclosures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74

Note: Not all of the worker general procedures are used in every work practice.

W - 4 # Worker General Procedures # © 1996 NIBS # Page - 58

Figure 5: Level A Worker ChecklistOperations and Maintenance Work PracticesLevel A work may contact ACM but not disturb it. If you encounter damaged ACM, or if the work coulddamage the ACM, stop work and notify your supervisor.

Pre-Work ~ Obtain and review copies from Supervisor or Asbestos Program Manager of:

Activities ~ Completed Maintenance Work Authorization Form

~ Work practice(s) to be used including personal protective equipment options

~ Work Notification(s) (as applicable)

~ Schedule for work

~ Review work practices and General Procedure W1 and any other general procedures

used in work practice.

~ Inspect work area for visible dust or debris. If present, stop work

and notify APM.

~ Obtain recommended tools, equipment and materials as described in General

Procedure W1, work practice(s) item 2, and Maintenance Work Authorization Form.

~ Move tools, equipment and materials to work area.

~ Shut off and lock out any HVAC or electrical systems to be worked on.

~ If required on Maintenance Work Authorization Form, put on respirators and perform

fit checks - See General Procedure W6.

Work Practices Always use wet methods, HEPA vacuums, prompt clean-up and disposal of waste.

Prohibited practices: Do not dry clean-up dust and debris, or use compressed air orhigh-speed abrasive saws.

~ Perform work per steps in work practice(s).

Clean-Up ~ Remove lockout tags (if used) & restart any HVAC/electrical system(s) that were

and shut off.

Tear-Down ~ Return tools, equipment and remaining materials to storage area.

~ Notify Asbestos Program Manager or supervisor that work is completed & returndocuments to APM.


Figure 6: Level B Worker ChecklistOperations and Maintenance Work PracticesLevel B: is work that may disturb ACM, but where the OSHA PEL is not exceeded and release of ACM, dustand debris is confined to the immediate location of the disturbance.

Pre-Work ~ Obtain and review copies from Supervisor or Asbestos Program Manager of:Activities ~ Completed Maintenance Work Authorization Form

~ Work practice(s) to be used including personal protective equipment options~ Work Notification(s) (as applicable)~ Schedule for work

~ Review work practices and referenced general procedures used in work practice(s).~ Obtain recommended tools, equipment and materials -

See General Procedure W1 and work practice(s) item 2.~ Obtain required respirators as listed on Maintenance Work Authorization Form. ~ Move tools, equipment and materials to work area.~ Shut off and lock out HVAC and electrical systems serving work area -

See General Procedure W3.~ Vacate and secure work area, such as by locking doors and/or setting up temporary

barriers - See General Procedure W4.~ Put on respirators and perform fit checks - See General Procedure W6.~ Put on protective clothing - See General Procedure W7.~ Air monitoring personnel begins air monitoring work (if required) -

See General Procedure W8.~ Preclean work area if visible dust or debris is present - See General Procedure W9.

Work Area ~ Set up work area as required by work practice - See General Procedure W10.

Work Practices Always use wet methods, HEPA vacuums, prompt clean-up and disposal of waste.Prohibited practices: Do not dry clean-up dust and debris, or use compressed air orhigh-speed abrasive saws.


Clean-Up ~ Package and label asbestos waste for disposal - See General Procedure W11.and ~ Apply lockdown encapsulant, where required, using garden sprayer, to surfacesTear-Down where ACM was removed or disturbed - See General Procedure W12.

~ Perform ceiling panel replacement work or ceiling repair work if needed.~ Clean tools, equipment and work area using wet wiping and HEPA vacuuming as

appropriate and return tools and equipment to outside work area - See General Procedure W13.

~ Decontaminate packaged waste & move waste to outside work area - See General Procedure W14.

~ Workers decontaminate and remove protective clothing and respirators. Ifcontaminated, dispose of protective clothing as ACM - See General Procedure W15.

~ Complete visual inspection. Complete air monitoring work - See General ProcedureW16.

~ If feasible, get APM or designee to complete Evaluation of Work Form.~ Transport waste to designated asbestos waste storage area -

See General Procedure W17.~ Remove drop cloth, clean with HEPA/wet methods or properly dispose of as

contaminated.~ Return decontaminated tools, equipment and remaining materials to storage area.~ Remove lockout tags and restart HVAC/electrical system(s).~ Restore normal accessibility to work area.~ Notify Asbestos Program Manager or Supervisor that work is completed & return

documents to APM.


Figure 7: Level C Worker ChecklistOperations and Maintenance Work PracticesLevel C: is work where ACM is disturbed and the PEL may be exceeded or ACM, dust, and/or debris may bescattered beyond the immediate location of the disturbance. Level C work must take place in an enclosure(glovebag or mini-enclosure).

Pre-Work ~ Obtain and review copies from Supervisor or Asbestos Program Manager of:Activities ~ Completed Maintenance Work Authorization Form

~ Work practice(s) to be used including personal protective equipment options~ Work Notification(s) (as applicable)~ Schedule for work

~ Review work practices and referenced general procedures used in work practice(s).~ Obtain recommended tools, equipment and materials -

See General Procedure W1 and work practice(s) item 2.~ Obtain required respirators as listed on Maintenance Work Authorization Form. ~ Move tools, equipment and materials to work area.~ Shut off and lock out HVAC and electrical systems serving work area -

See General Procedure W3.~ Vacate and secure work area, such as by locking doors and/or setting up temporary

barriers - See General Procedure W4.~ Put on respirators and perform fit checks - See General Procedure W6.~ Put on protective clothing - See General Procedure W7.~ Air monitoring personnel begins air monitoring work (if required) -

See General Procedure W8.~ Preclean work area if visible dust or debris is present - See General Procedure W9.

Work Area ~ Perform all Level C work inside an enclosure (glovebag or mini-enclosure) Set up workarea and decontamination facilities as required by work practices - See GeneralProcedures W5, W10, W18, and W20.

Work Practices Always use wet methods, HEPA vacuums, prompt clean-up and disposal of wasteProhibited practices: Do not dry clean-up dust and debris, or use compressed air orhigh-speed abrasive saws.


Clean-Up ~ Package and label asbestos waste for disposal - See General Procedure W11.and ~ Apply lockdown encapsulant, where required, using garden sprayer, to surfacesTear-Down where ACM was removed or disturbed - See General Procedure W12.

~ Perform ceiling panel replacement work or ceiling repair work if needed.~ Clean tools, equipment and work area using wet wiping and HEPA vacuuming as

appropriate and return tools and equipment to outside work area - See General Procedure W13.

~ Decontaminate packaged waste & move waste to outside work area - See General Procedure W14.

~ Workers decontaminate and remove protective clothing and respirators. Ifcontaminated, dispose of protective clothing as ACM - See General Procedure W15.

~ Complete visual inspection. Complete air monitoring work - See General Procedure W16.

~ If feasible, get APM or designee to complete Evaluation of Work Form.~ Transport waste to designated asbestos waste storage area -

See General Procedure W17.~ Remove drop cloth and/or mini-enclosure, clean with HEPA/wet methods or properly

dispose of as contaminated.~ Return decontaminated tools, equipment and remaining materials to storage area.~ Remove lockout tags and restart HVAC/electrical system(s).~ Restore normal accessibility to work area.~ Notify Asbestos Program Manager or Supervisor that work is completed & return

documents to APM.

W - 7 # Worker General Procedures # © 1996 # Page - 61

W-1 Tools, Equipment andMaterials The following is a list oftools, equipment and materials that arereferenced in the work practices and arerecommended to perform the workpractices. Tools, equipment or materialsthat are unique to a certain work practiceare listed under item 2 in each workpractice. For frequent O&M work, itmight be helpful to maintain an "O&Mcart" containing the necessary tools,equipment and materials.

Tools and Equipment! Utility knife! Ground fault circuit interrupters

(GFCI's), Extension cords andadapters - GFCI's should be used onany electrical equipment or tools usedin O&M work where water might bein use or present in the work area.

! Lockout tags! Temporary work lights! Ladder or scaffold for elevated work! Wet wipes or bucket with clean water

for wet wiping ! Smoke test bulb and tubes! Bone saw! Wire cutters! Tin snips! Safety glasses

Abatement Equipment andMaterials! Polyethylene sheet! Duct tape! Disposal bags with labels! High efficiency particulate air (HEPA)

vacuum with hose, attachments andproper HEPA filter (wet/dry typeneeded for some work practices)

! Respirators (if required)! Disposable coveralls (if required)! Disposable towels or wet wipes! Asbestos barrier tape! Warning signs! Garden sprayer with amended water or

removal encapsulant (Level B and Cpractices) See general procedure W2.

! Aerosol cans or garden sprayer withlockdown encapsulant (Level B and Cpractices)

! Air monitoring pumps, cassettes andcalibration equipment (if required)

! Frame for mini-enclosure orprefabricated mini-enclosure (Level Cpractices)

! Negative pressure machine (HEPAfiltered exhaust fan) as required for sizeof enclosure (level C practices - couldbe negative pressure machine oradditional HEPA vacuum)

! Manometer (if pressure differentialmeasurements are desired)

! Glovebags (if required)

W-2 Preparing Amended Water orRemoval Encapsulant Amended water or removal encapsulantsolutions are prepared by mixing ameasured amount of surfactant orencapsulant with clean water inaccordance with the manufacturer'sinstructions. Surfactants and encapsulantsmaterials might be considered hazardoussubstances. Containers of amended wateror removal encapsulant should be labeledto identify the contents in accordance withthe OSHA Hazard Communication

Standard (29 CFR 1910.1200). Reviewand comply with Material Safety DataSheet (MSDS) before mixing and usingthese materials. Amended water orremoval encapsulant should be mixed in alabeled garden sprayer unit prior to thestart of an O&M activity. Somepractitioners have reported that liquiddishwashing detergent might be used as asurfactant for O&M work. They have useda mix of 8 parts water to one partdetergent.


W-3 Shut-off and Lockout of HVACand Electrical Systems Any electrical systems that might beworked on or affected by O&M activitiesshould be shut off, locked and tagged withelectrical lockout tags at the circuitbreaker panel or disconnect switch. Affected systems include systems thatcould create electrical hazards duringO&M activities that involve wetting.

HVAC systems in a work area, systemsthat serve a work area, or systems that willbe worked on should be shut down duringO&M activities. Level A activities

usually do not require HVAC shut downunless a work will occur on a system or adisturbance of asbestos will occur. Anyair-handling systems (supply, return andexhaust) required to be shut down shouldbe shut off, locked, and tagged withelectrical lockout tags at the circuitbreaker panel or disconnect switch.

Lockout tags should note when and whypower is shut down and the personnelperforming the lockout. There shouldonly be one key for each lock used onlockout tags to prevent accidentalreactivation of equipment.

W-4 Securing Work Area Whenasbestos fibers might be released, workareas should be vacated and secured(where feasible) by scheduling, lockingdoors (from inside the area if possible) orother means. If this is not feasible, accessto the work area should be restricted, suchas by asbestos barrier tape around theperimeter of the work area. If barrier tapeis used to denote a work area, it should beplaced 5 to 10 feet (1.5 to 3 meters)outside of any polyethylene protectionused in the work area. Install barrier tapeby taping or tying it to fixed objects.

Do not block access to any emergencyexits, and when asbestos fibers might bereleased, post OSHA required "danger"signs at all entrances to the work area. Forsuch projects, it might be desirable to havea visual barrier installed several feet infront of warning signs to avoid havingwarning signs readily visible to occupants. A "keep out of construction area" signshould be posted on visual barriers. Avisual barrier would be arranged so that aperson who goes past the visual barrierwill then see required warning signs.

W-5 Critical BarriersCompletely Separate the Work Area fromother portions of the building, and theoutside by closing all openings with sheetplastic barriers at least 6 mil (0.15 mm) inthickness, or by sealing cracks leading outof Work Area with duct tape.

Individually seal all ventilation openings(supply and exhaust), lighting fixtures,clocks, doorways, windows, convectorsand speakers, and other openings into theWork Area with duct tape alone or withpolyethylene sheeting at least 6 mil (0.15

mm) in thickness, taped securely in placewith duct tape. Maintain seal until allwork including Project Decontaminationis completed. Take care in sealing oflighting fixtures to avoid melting orburning of sheeting.

Provide Sheet Plastic barriers at least 6 mil (0.15 mm) in thickness as required to sealopenings completely from the Work Areainto adjacent areas. Seal the perimeter ofall sheet plastic barriers with duct tape orspray cement.


W-6 Putting on Respirators andPerforming Fit Checks The procedures described below are basedon the assumption that workers wearingrespirators have been trained in the use ofrespirators and, for negative pressurerespirators, fit tested, and enrolled in amedical surveillance program as part of aRespiratory Protection Program. Respirators used should be approved byNIOSH and/or MSHA. These proceduresare not a substitute for a RespiratoryProtection Program in accordance withOSHA standard 29 CFR 1910.134 orregulatory requirements regardingrespirators.

Wearers should inspect their respiratorsbefore each use of the respirator.

Respirators must not be damaged, havemissing parts or be deformed in any way. The straps must be intact and wellattached. Proper filter cartridges for thehazards to be encountered must beinstalled. Verify that filters have beenreplaced in accordance with theRespiratory Protection Program. Batteriesfor powered respirators should be fullycharged. The respirator should also becleaned if it was not cleaned after the lastuse. If any problems exist, the respiratorshould be repaired or replaced inaccordance with the RespiratoryProtection Program.

When putting on a respirator, the strapsshould be loosened before it is put on. Filter caps (such as those used on some

Powered Air Purifying Respirators) shouldbe taped to the filter body or stored whereit will not be lost. Powered respiratorsshould be turned on and flow checkedbefore the facepiece is put on. Therespirator should be put on and then thestraps tightened as recommended in themanufacturer's information provided withthe respirator. Fit checks should then beperformed.

Fit Checks Fit checks should beperformed in accordance with theRespiratory Protection Program by eachworker each time they put on a respirator. Both positive and negative pressure fitchecks should be performed. Whenfeasible, powered respirators should bechecked with the motor unit turned off. Anegative pressure fit check is done bydonning the respirator and pulling therespirator straps so the unit fits snugly. Inhale gently while placing hands overfilters to block off inhalation side. Respirator should pull to face and no airshould leak in around face seal.

A positive pressure fit check is done byexhaling gently (without breakingrespirator seal to face) breathing normallywhile blocking off the exhalation valve. The face piece should then expand awayfrom face while exhaling.

Adjust respirator straps as needed toobtain a good seal of the facepiece to theface. If a good seal cannot be obtained,obtain a new respirator and perform fittests again.

W-7 Putting on Protective ClothingProtective clothing for workers typicallyconsists of disposable coveralls, glovesand boots. Coveralls should have hoodsand booties attached. They should

provide complete coverage of the bodywith the exception of hands and face. Cloth coveralls that are cleaned by afacility equipped to launder asbestoscontaminated clothing might also be used. Do not modify coveralls.


W-7...CONTINUED Protective Clothing OptionsAvailable for O&M Work Include

LEVEL A & B: If level A or B work isto be performed and the potential forexposure to asbestos-containing dust anddebris is low and localized, use:

1. One disposable coverall with nostreet clothes, or

2. One disposable coverall overstreet clothes.

LEVEL C: Level C work is to beperformed inside of a mini-enclosure andif potential for exposure to asbestos-containing dust and debris is moderate ordispersed, use:

1. Two disposable coveralls with no streetclothes, or if street clothes are required,two coveralls should be worn over thestreet clothes. Preferably the street

clothes should be removed before thestart of work.

When possible, street clothes should beremoved in a changing area beforeprotective clothing is put on. Protectiveclothing should be put on after respirators. The coverall hood should cover respiratorstraps.

Workers are encouraged to wearprotective gloves that are duct taped at thecuffs to the protective coveralls. Eye,hearing, and head protection should alsobe used where needed. Rubber slip-resistant boots or other non-slip footwearis to be worn for all activities. (protectivebooties should cover feet inside the boots). Steel-toed boots should be used in areaswhere foot hazards exist. Do not usecoveralls with loose foot coverings foractivities that involve climbing ladders orworking on scaffold.

W-8 Beginning & Conducting AirMonitoring During WorkPractices Note: This section is not intended as asubstitute for a complete Air MonitoringProgram and specific protocols needed forO&M work. This section notes air monitoringissues that need to be addressed by the airmonitoring person.

Air monitoring during O&M activities canconsist of personal monitoring, areamonitoring and clearance monitoring. Airmonitoring required for the work practicebeing performed should be listed on theMaintenance Work Authorization Formand be conducted in accordance withapplicable regulations (such as 29 CFR1926.1101 Appendix A), the O&M Planand Air Monitoring Program. All airmonitoring work should be conducted bya trained person assigned by the APM.

The air monitor person should calibrate,adjust, and record the flow rate of all airmonitoring pumps to be used before airmonitoring is started for an O&M activity.

General procedure W16 covers visualinspections and the completion of airmonitoring at the end of the work.

Personal Monitoring To performpersonal monitoring, attach a personal airmonitoring pump to a belt worn by theworker. Attach an air sampling cassette tothe hose from the pump. Route the hoseup the worker's back and tape the hose tothe worker's protective coveralls usingduct tape. The cassette should be locatedwith the open end facing downwards atapproximately a forty-five degree angle inthe worker's "breathing zone" at aboutcollar level. Turn the pump on and recordstart time. The air monitoring person willretrieve or change the cassette whennecessary, or when work is completed.

Area Monitoring Area monitoring isusually performed using high volume airsampling pumps. Place pumps inside thework area and outside the work area inoccupied areas or areas where occupantscould be exposed if fibers are released


W-8...Continuedfrom the work area. Pumps should belocated where they obtain meaningfulmeasurements of potential workerexposure during monitoring as well asmeasure any area contamination. Attachsampling cassettes to the hoses from thepumps and attach the cassettes to the topof tripod stands or other stable structures(do not use the pump as a stand due to itsvibrations) to locate the sample at four tofive feet (1.2 to 1.5 meters) above thefloor. These cassettes should be located

with the open end facing downwards atapproximately a forty-five degree angle. The air monitoring person will retrieve orchange cassettes as needed or when thework is completed.

If any samples analyzed during the workexceed predetermined "stop work levels"specified in the O&M program, productivework shall be stopped, the area cleanedand additional engineering controlsimplemented, as necessary.

W-9 Wet Wiping, HEPAVacuuming, and SteamCleaning These work practices areused either to pre-clean the work areaprior to start of work, or for cleaningsurfaces as part of a work procedure.

Precleaning of work areas prior to the startof work is done to remove accumulateddebris and dust that could be disturbedduring the work. Precleaning mightinclude picking up dust and debris with aHEPA vacuum, wet wiping non-poroussurfaces, HEPA vacuuming surfaces thatcannot be wet wiped, and cleaning anycarpeted surfaces using steam extractionequipment. (Note: EPA has determined ina research study that HEPA vacuumingand steam cleaning of carpets does notcompletely remove asbestoscontamination.) Precleaning might reducethe extent of cleaning required after thework and for clearances (if required).

The following work procedures are beused for cleaning when required in a WorkPractice.

Wet Wiping The procedures to be usedfor wet wiping are as follows:

1. Immerse disposable towel inbucket containing amended water.

2. Wring out towel and fold intoquarters.

3. Wipe surface and refold to have aclean face exposed. Do not placetowel back into bucket or waterwill become contaminated and

will need to be replaced. 4. Repeat step 3 until all faces of

towel have been used. Obtain aclean towel if more wiping isneeded.

5. Dispose of used towels in disposalbags.

6. Dispose of contaminated water asrequired by applicable regulations -See general procedure W19.

HEPA Vacuuming The procedures tobe used for HEPA vacuuming are asfollows:

1. For floors, use a floor attachmentwith rubber floor seals andadjustable floor-to-attachmentheight. For furniture, fabrics orother surfaces use an upholsteryattachment or brush attachment.

2. Vacuum hard or smooth surfaces

with attachment about 1/16" (2mm) above the surface.

3. Vacuum carpet or fabrics withattachment just touching thesurface.

4. Vacuum all surfaces in parallelpasses with each pass overlappingthe previous one by one-half thewidth of the attachment.

5. Once surfaces are cleaned in onedirection, clean a second time atright angles to the first cleaning.


W-9...Continued6. Use crevice brush or other tools to

clean irregularly shaped surfaces.

Steam Cleaning Carpet Theprocedures to be used for steam cleaningcarpet are as follows:

1. Steam clean carpet using carpettool.

2. Steam clean all surfaces in parallelpasses with each pass overlappingthe previous one by one-half thewidth of the attachment.

3. Once surfaces are cleaned in onedirection, clean a second time atright angles to the first cleaning.

4. Water from cleaning processshould be treated in accordancewith applicable regulations - SeeW19.

(Note: EPA has determined in a researchstudy that HEPA vacuuming and steamcleaning of carpets does not completelyremove asbestos contamination.)

W-10 Polyethylene Drop ClothThe NIBS Asbestos Abatement andManagement in Buildings: Model GuideSpecifications Section 01527 "RegulatedAreas" provides information on thepreparation of "a regulated area" foroperations and maintenance work. Review of this additional information isencouraged.

Preparation of work areas for O&Mactivities typically involves demarcationof the work area, restricting access to thework area and the use of a polyethylenedrop cloth.

Polyethylene Drop Cloth Preparinga work area with a drop cloth requires thata single layer of polyethylene be spread onthe floor of the work area and taped orweighted in place. Do not use more than

one layer if ladders (or similar equipment)will be used, unless a hard surface, such asplywood is laid over the drop cloth. Iffloor is a soft material, such as carpet, usecaution to prevent tearing of polyethyleneunder equipment. The drop cloth shouldcover an area large enough to catch fallingdebris. If work is to be performed at anelevated level, the drop cloth should beplaced on the work platform, or extendedat ground level beyond the immediatework location to catch any debris thatmight be generated. Note that the use of adrop cloth introduces potential sliphazards in the work area. Non-slip footcoverings are recommended where dropcloths are used. Drop cloths should bethoroughly cleaned if they are moved fromone spot to another or reused.

W-11 Packaging and LabelingWaste Asbestos-containing waste material fromO&M activities should be adequately wetin accordance with the NESHAPrequirements (40 CFR 61.150). Verifywaste packaging and other waste disposalrequirements with the landfill that willreceive the asbestos waste. Pre-labeledasbestos disposal bags should be used forasbestos waste disposal where possible,appropriate and permissible. Disposalbags should be collapsed by evacuatingthe air from the bag with a HEPA vacuum

in the work area or enclosure. Oncecollapsed, twist the bag to form a neck andwrap it tight with duct tape. Fold neck ofbag over to form a loop, then again wrapduct tape around neck and loop.

Although not a federal regulatoryrequirement, asbestos waste is oftenplaced into second disposal bag and sealedas described above. Label disposal bagsas required by applicable NESHAP,OSHA and DOT regulations.


W-11...ContinuedAsbestos waste that does not fit intodisposal bags should be wrapped leak-tight in one or two layers of 6 mil (0.15mm) polyethylene sheet. Each layershould be sealed tightly with duct tape. Label outer layer as required byregulations.

Sharp objects that might puncturepolyethylene (such as floor tile) should beplaced into cardboard boxes beforewrapping in one or two layers of 6 mil(0.15 mm) polyethylene.

All waste should be labeled as required byfederal, state and local regulations. Federal regulations requiring labeling ofwaste include OSHA regulations 29 CFR1910.1200, 1910.1001 and 1926.1101,EPA's NESHAP regulation 40 CFR61.150, and the Department ofTransportation's Hazardous MaterialsRegulations 49 CFR 171 and 180. ACMpackaging, with some exceptions, mustmeet general DOT and EPA requirementsand be protective, marked and labeled. See Appendix I for further information. Review current labeling requirements withAPM and disposal site. The OSHArequirements apply regardless of theamount of waste or measured exposurelevels (see 29 CFR 1926.1101(k).

Label Requirements Include:

OSHA 29 CFR 1926. 1101(k)(8)requirement:

DANGER

CONTAINS ASBESTOS FIBERS

AVOID CREATING DUST

CANCER AND LUNG DISEASE HAZARD

Department of Transportation(DOT) requirement DOT's shippingpaper and marking format, used with someexceptions (see Appendix I) is:

RQ, Reportable Quantity, if 1 lb (.4kg) or more friable asbestos

WASTE For waste material, ifapplicable

ASBESTOS Shipping name; fordomestic transportation only.

MIXTURE For asbestos mixed witha binder or filler, etc.

9, Class 9, MiscellaneousHazardous Materials, includesasbestos

NA2212 North Americanidentification number; fordomestic transportation only.

PGIII Packing Group; for domestictransportation only

LTD QTY, Limited quantity, ifapplicable.

20OZ Total quantity of materialdescribe; may abbreviate unit.

NESHAP requirement NESHAPrequires that readily visible and legiblewarning labels as specified by OSHA beused on waste containers or wrappedmaterials (this is the same as the OSHA 29CFR 1926.1101 label listed above). Waste material to be transported off thefacility site must also be labeled with thename of the waste generator and thelocation at which the waste was generated.

OSHA requires leak-tight containers andlabeling for Class II materials (Note thatunder the EPA NESHAP regulation theseare Category I and II materials which arenot regulated as long as the materialsremain non-friable). For purposes of thisO&M program, treat OSHA Class IImaterials as EPA regulated waste. Maintain OSHA required labels in placeand dispose of as asbestos-containingwaste in accordance with the NESHAPregulation.


W-12 Applying LockdownEncapsulant A lockdownencapsulant should be applied to areaswhere ACM is removed. Lockdownencapsulants used should be tested per1978 Battelle/EPA report "Tests for theEvaluation of Encapsulants for FriableAsbestos-Containing Materials". Encapsulants should be water resistantafter curing and be Class "A" fire rated perASTM 84-81A "Standard Method forSurface Burning Characteristics ofBuilding Materials.

Lockdowns need to be compatible withany materials that will be installed overthe encapsulant. Note that manylockdown encapsulants will act as anadhesive and could be objectionable onsome surfaces when dry. Care should betaken to avoid getting encapsulant on or inHVAC units, HEPA vacuums, andnegative pressure machines.

Lockdown is typically applied for O&Mwork using a garden sprayer. It should beapplied in accordance with themanufacturers' recommendations in twolight coats sprayed from oppositedirections to seal all portions of surfacesincluding any exposed edges of remainingACM.

DO NOT APPLY LOCKDOWNENCAPSULANT ON FIREPROOFINGOR TO STEEL THAT IS GOING TO BEFIREPROOFED, WITHOUT PRIORAPPROVAL FROM THE APM. The useof spray fireproofing is based on full-scalefire endurance tests of fireproofed steel. Anything that differs from the testedassembly voids the test, and could result ina fireproofing failure. Fireproofing is anon-combustible insulator of steel. Coating it or saturating it with anencapsulant could render it combustibleand could reduce it insulating properties. This could cause the fireproofing to fail

and as such voids the fire rating. Theintroduction of an encapsulant betweenthe fireproofing and the steel could causethe fireproofing to fail. The bond of thefireproofing to the steel could beweakened causing the fireproofing to falloff, or the encapsulant could soften andallow the fireproofing to fall off during afire. Unless the encapsulant has beentested and approved for use by themanufacturer of the fireproofing used, itsuse will void the fire rating of thefireproofing material.

W-13 Cleaning Tools, Equipment,and Work Area Clean tools andequipment using HEPA vacuuming and/orwet wiping procedures. Special attentionshould be given to cleaning extensioncords, equipment wheels, vacuum hosesand other items that could pick up debrisduring the work. Tools and equipmentshould be placed outside of the work areaas soon as cleaning is completed. Dropcloths and mini-enclosures can be cleanedor disposed of as ACM. Any items thatcannot be fully cleaned (such as boots ortools) that might be used in another O&Mactivity should be placed into disposalbags, sealed and labeled as ACM. Thesebags should be wet wiped and then placed

outside of the work area with the othertools and equipment. Do not open bagscontaining contaminated tools, or openequipment such as a HEPA vacuum,except during another O&M activity or ina designated work area. HEPA vacuumhoses can be sealed with tape over bothends if the outside of the hose is clean.

Cleaning of the work area where an O&Mactivity is conducted consists of HEPAvacuuming and/or wet wiping (asappropriate) all surfaces in the area. HEPA vacuuming and wet wiping shall beperformed as described in generalprocedure W9 above.


W-14 Decontaminating Waste Packaged waste should be HEPAvacuumed and wet wiped before it ismoved out of the work area. Use the wetwiping and HEPA vacuuming proceduresin general procedure W9. Packaged waste

should be placed on a sheet ofpolyethylene when it is moved outside ofthe work area. This polyethylene can bethe outer portion of a drop cloth, if a dropcloth is being used.

W-15 Worker Decontamination andRemoval of ProtectiveClothing and Respirators Removal of Protective Clothing(if used) Decontamination and removalof protective clothing following O&Mactivities should use the applicableprocedure(s) described below:

LEVEL B REQUIREMENTS -(Removal of Protective ClothingWhen Drop Cloth Work AreaProtection, or no Work AreaProtection, is Used) HEPA vacuumall parts of protective clothing whilestanding at perimeter of drop cloth. Leaving respirator in place, removeprotective clothing and fold inside out as itis removed. Place clothing, ifcontaminated, into a disposal bag andlabel as ACM waste.

LEVEL C REQUIREMENTS WHEREWORK IS PERFORMED INSIDE AMINI-ENCLOSURE OR OTHERPHYSICAL BARRIER - (Removal ofProtective Clothing If A Mini-Enclosure and Change Room isProvided) HEPA vacuum all parts ofprotective clothing while inside work areaenclosure.

If two disposable coveralls are used,remove outer coveralls in work area whileleaving respirator in place. Fold coverallsinside out as they are removed. Move tochange room, HEPA vacuum protectiveclothing, and remove second set ofcoveralls in the same manner.

If only one set of disposable coveralls isworn, remove in change room while

leaving respirator in place. Fold coveralls

inside out as they are removed.

Place protective clothing, if contaminated,into a disposal bag and label as ACMwaste. Wash hands, face and surface ofrespirator with clean water and disposabletowels. Use caution to avoid breaking sealbetween respirator facepiece and face. Place disposable towels into a disposalbag. Remove respirator and followprocedures specified in RespiratoryProtection Program for cleaning andstoring respirator. Change respiratorfilters if needed or required and dispose ofused filters as ACM. Put street clothes onand exit change room.

LEVEL C REQUIREMENTS -(Removal of Protective Clothing ifan enclosure or mini-enclosure isused and a Shower is Available) HEPA vacuum all parts of protectiveclothing while inside work area enclosure. Remove outer coveralls in work areawhile leaving respirator in place. Foldcoveralls inside out as they are removed. Move to change room. Wash hands andwet wipe face and respirator, HEPAvacuum protective clothing. Put on aclean set of protective coveralls over thecoveralls already being worn to preventany ACM debris or dust that may be onthe coverall from falling off on the way tothe shower. Proceed to shower withrespirator still in place. At showerfacility, remove protective coveralls,folding inside out during removal. Placeclothing, if contaminated, into a disposalbag and label as ACM waste. Showercompletely, and remove and cleanrespirator while showering as describedbelow.


W-15...Continued Street Clothes If street clothes areworn under protective clothing and arecontaminated during the work, the streetclothes should be HEPA vacuumed,removed during decontamination andplaced into a labeled disposal bag. Thesestreet clothes should then be disposed ofas ACM or taken to a facility that hasequipment designed for cleaning asbestos-contaminated clothing.

Removal of Respirator Theprocedures described below are based onthe assumption that workers wearingrespirators have been trained in the use ofrespirators and, for negative pressure

respirators, fit tested, and enrolled in amedical surveillance program as part of aRespiratory Protection Program.

Remove respirator after removingprotective clothing (if used). Beforeremoving respirator, wash hands, face andsurface of respirator with clean water anddisposable towels. Use caution to avoidbreaking seal between respirator facepieceand face. Avoid getting water into filtercartridges of respirator. Place disposabletowels into a disposal bag. Removerespirator and follow procedures specifiedin Respiratory Protection Program forcleaning and storing respirator.

W-16 Visual Inspection andCompleting Air Monitoring Visual Inspection Conduct a visualinspection prior to the start of clearanceair sampling. The person performing theinspection can be a worker if authorizedby the APM. Verify that there is nodebris or residue from removed ACM andthat all visible dust or debris in the workarea has been cleaned up. If visibleresidue, dust or debris remains, it must becleaned up using wet wiping and/or HEPAvacuuming before clearance sampling isstarted.

Perform the visual inspection usingprocedures approved for use in the facilityby the APM. If you have not been trainedin visual inspection procedures notify theAPM. The EPA's Purple Book and theAmerican Society for Testing andMaterials (ASTM) "Standard Practice forVisual Inspection of Asbestos AbatementProjects" (Document E1368-90) providevisual inspection procedures that might behelpful in developing O&M inspectionprocedures.

Air Samples Complete air monitoringwork in accordance with Air MonitoringProgram and requirements noted on aWork Authorization Form. Verify thatremoval areas have been encapsulated("locked down"), that the work area, tools,and equipment have been cleaned, andthat the area has passed a visualinspection. When air sampling cassettesare retrieved, the air monitoring personshould record the stop time for thesamples and check and record the flowrate of the air monitoring pumps. Samplesshould be analyzed on-site (for PCManalysis) if possible, or sent to alaboratory for analysis. When sampleresults are received, compare results to AirMonitoring Program criteria for workrelease or clearance. If sample resultsexceed criteria, the work area should berecleaned, reinspected, and then additionalair samples should be obtained. Ifsamples are equal to or below releasecriteria, tear down work can proceed. Collect air sampling pumps and equipmentfrom work area and other locations whenair sampling work is completed.


W-17 Waste Transportation, Storageand Disposal Transport asbestoswaste from O&M activities to adesignated storage area or an approvedlandfill after the work is completed. Workers transporting waste should followRespiratory Protection Programrecommendations concerning respiratorrequirements for transporting asbestoswaste. Do not drag packaged waste. Allwaste should be lifted and carried, ortransported in wheeled carts, when movedfrom one area to another. Packaged wasteshould be placed, not thrown or dropped,into vehicles, storage areas and thelandfill.

Any asbestos waste that is not taken to alandfill should be stored in a secure,lockable area. Signage in accordance withNESHAP should be posted at the storagearea and on vehicles used to transport

asbestos-containing waste material duringloading and unloading. When asbestoswaste in the storage area is taken to alandfill, it should be transported inaccordance with all applicable federal,state and local regulations. Asbestoswaste shipment records should becompleted in accordance with therequirements in NESHAP Section 61.150.

The workers conducting the O&M activityshould fill out part 1 of the waste trackingform included in Appendix D or anequivalent form. Once part 1 is completedand the waste is stored or taken to alandfill, the form should be turned over tothe APM to complete part 2 and file withO&M records. NESHAP waste shipmentrecords must also be completed (whereapplicable) and filed with waste disposalrecords.

W-18 Glovebag Removal (Also includesother types of prefabricated removalenclosures) Remove asbestos-containingmaterial inside a glove bag according tothe following procedures. Glovebagsshould be used only once and should notbe moved to another location to performadditional removal work, or reused in anyway. Use only 60" X 60" standardglovebags. Do not use glovebags onsurfaces or equipment that is over 150°F. If you encounter a situation that requires aspecial type or size of glovebag, or if hotsurfaces are involved, notify APM.

Other types of prefabricated removalenclosures include "glovebox" typeenclosures, glovebags with self-supportingframes, and glovebags that funnel wasteinto standard disposal bags. Check withequipment suppliers for information onthese enclosures.

Glovebags might be used with aframework for O&M work on flat areassuch as surfacing materials. Note thatsignificant asbestos exposures to workerscan result from the improper use of

glovebags. Workers should obtaininformation on current regulatoryrequirements on glovebag use from theAPM.

Procedure A. Glovebag RemovalProcedures

Check area where the work will beperformed. If damaged ACM is present(broken lagging, hanging, etc.), wrap inpolyethylene and cover polyethylene withstrips of duct tape for reinforcement. Placeone layer of duct tape around the removalarea where the glove bag will be attached. Also protect any damaged ACM outsidethe glovebag area that could be disturbedduring the work.

Slit top of the glove bag open (ifnecessary) and cut down the sides toaccommodate the removal area.


W-18...ContinuedPlace necessary tools into pouch locatedinside glove bag (or into a sleeve turnedinside out). Tools needed typicallyinclude: scraper, bone saw, utility knife,disposable towels, nylon brush, abrasivepads, wire cutters, tin snips and pre-wettedlag cloth. Cut lag cloth to sizes needed tocover any ACM that will remain afterglovebag work is completed.

Place one strip of duct tape along the edgeof the open top slit of glove bag forreinforcement.

Place the glove bag around area to beworked on and staple top together throughreinforcing duct tape. Provide 8-12" (200-300 mm) of space inside glovebagbetween removal surface and glovebag forworking room. Secure glovebag to ducttape previously installed around removalarea.

Use smoke tube and aspirator bulb to testseal. Place tube into water sleeve(two-inch [50 mm] opening to glove bag)squeezing bulb and filling bag with visiblesmoke. Remove smoke tube and twistwater sleeve closed. While holding thewater sleeve tightly, gently squeeze glovebag and look for smoke leaking out,(especially at the top and ends of the glovebag). If leaks are found, tape closed usingduct tape and re-test.

If a negative pressure glovebag with asupporting framework and HEPA filteredmakeup air port is being used, attach hosefrom an operating HEPA vacuum toglovebag to provide negative pressure inglovebag. Follow equipmentmanufacturer's instructions on use ofnegative pressure equipment.

Insert wand from garden sprayer withamended water through water sleeve. Duct tape water sleeve tightly around thewand to prevent leakage.

Insert arms into glovebag sleeves.

Remove any metal jacketing or coveringover the area where removal is requiredusing tin snips and/or wire cutters. Fold in

any sharp edges to avoid cutting the bag.Pierce any painted coverings to permitwater to soak into the ACM.

Adequately wet material to be worked onwith amended water and allow to soak in. Wet adequately to penetrate and soakmaterial through to substrate.

Cut insulation section to be removed usingbone saw or utility knife. Use caution toavoid cutting glovebag. Lift glovebagaway from cutting area if necessary.

Throughout this process, spray amendedwater or removal encapsulant on thecutting area to keep dust to a minimum.

Remove insulation using scraper or othertools. Place pieces in bottom of bagwithout dropping. Rinse all tools withamended water inside the bag and placeback into pouch or a sleeve of theglovebag turned inside out.

Using nylon brush, scrub pads, disposabletowels and amended water, scrub and wipedown the removal area.

Seal exposed ACM around removal areausing pre-wetted lag cloth or encapsulatewith a bridging encapsulant. Encapsulateremoval area with an appropriatelockdown encapsulant. Use suitable hightemperature encapsulants for hot piping.

Wash down inside of glovebag withamended water and wipe as necessary tomove all debris and residue to lower partof glovebag (below where bag will betwisted and cut).

Remove water wand from water sleeve,twist water sleeve closed and seal withduct tape.

From outside the bag, pull the tool pouchor sleeve away from the bag and twistpouch to seal it from rest of bag. Placeduct tape over twisted portion and then cutthe tool bag from the glove bag, cuttingthrough the twisted/taped section.


W-18...ContinuedContaminated tools might then be placeddirectly into another glove bag withoutcleaning. Alternatively, tool pouch withthe tools can be placed in a bucket ofwater, opened underwater, and toolscleaned and dried. Discard disposabletowels and nylon brush with asbestoswaste. Dispose of contaminated water asset forth in general procedure W19 below.

Evacuate air from glovebag using HEPAvacuum. With HEPA vacuum operatingand removed insulation in the bottom ofthe bag, twist the bag several times andtape it to keep the material in the bottomduring removal of the glove bag from theremoval area.

Slip a 6 mil (0.15 mm) disposal bag overthe glove bag (still attached to removalarea). With the hose of an operatingHEPA vacuum inserted in the upper partof glovebag, remove tape or cut bag andopen the top of the glove bag and fold itdown into disposal bag.

Procedure B. Use of a Glovebagwith Self-Supporting Frame Glovebags on self-supporting frames canbe used for some O&M activities onsurfacing materials, and might be able tobe adapted for other types of ACM. Thegeneral procedures for using these unitsare as follows:

Construct a rectangular or square frame of1 ½" (38mm) diameter PVC or ABS pipe. Supporting legs can be made of lengths ofpipe and fittings as needed to achieve therequired height. Proprietary frames withtelescoping legs are available.

To install glovebag on the frame, fold topedge of bag over the frame sides andextend the open edge of the bag at least10" (25 cm) beyond the frame. Secure theopen edges to the rest of the bag usingduct tape. Place tools and supplies neededprocedure above) in tool pouch insideglovebag.

Place frame and glovebag assembly belowwork location so that frame is close to, butnot touching, ACM. Location andproximity of frame to ACM should allowfor some movement without disturbingACM during the work.

Insert wand of garden sprayer withamended water into bag and seal in place.

Cut hole in glovebag for negative pressureequipment hose. Negative pressureequipment could be a HEPA vacuum orsmall negative pressure machine. Installhose and seal in place. A prefilter mightbe needed to prevent any gross ACMdebris from being drawn into the negativepressure device.

Install a hose from an operating HEPAvacuum into the bag in a position where itcan be used during the work. Turn onnegative pressure device and smoke testall sides of glovebag frame unit to verifythat negative pressure is present. Ifsufficient negative pressure is not present,reduce clearance between ACM and frame(if possible), or add additional negativepressure device(s).

Insert hands into glove arms and wetACM where work is required. Performwork as needed. Caution: If bag isoverloaded with tools or other materials,bag might break or release from frame.

HEPA vacuum and wet wipe tools andinside of bag. Adequately wet any ACMdebris in glovebag.

Slowly lower frame to allow tools to beremoved from bag.

Gently remove glovebag from frame andtwist to form a neck. Evacuate air frombag using HEPA vacuum and tape bagclosed.

Remove garden sprayer wand, negativepressure device hose, and HEPA vacuumhose and seal holes with duct tape.

Place glovebag into a labeled 6 mil (0.15mm) asbestos disposal bag and seal bag.


W-19 Disposal of contaminatedwater Contaminated water from O&Mactivities should be disposed of inaccordance with all applicable federal,state and local regulations. Filteringmight be required. If filtering is required,water should typically be filtered througha maximum 5 micron (5 :m) water filterbefore discharging water into a sanitarysewer system, if permitted. If a filter unitis not available at the work location,contaminated water can be put into

leaktight drums and transported to alocation with filtering equipment. If aportable shower unit with filteringequipment is available, contaminatedwater can be emptied into the shower andfiltered through the shower filter system. The NIBS Asbestos Abatement andManagement in Buildings: Model GuideSpecifications Section 01563"Decontamination Units" includes aspecification for filtering equipment.

W-20 Mini-EnclosuresNote: Polyethylene work area protectionis not to be used in place of otherengineering controls and good workpractices. Work practices such as wettingACM, careful handling, local collection byHEPA vacuum and local exhaustventilation should be the primary means offiber control during O&M work. Mini-enclosures are intended to protect theenvironment, workers are protected bywork procedures and engineering controlsthat prevent elevated airborne fiber levels,and by respiratory protection, protectiveclothing, decontamination procedures andother worker protection methods. State orlocal codes might require that fireretardant polyethylene be used forasbestos related work.

The NIBS Asbestos Abatement andManagement in Buildings: Model GuideSpecifications 01529 "Mini-Enclosuresand Glovebags" of the NIBSspecifications provides information on theset up of a mini-enclosure. Review of thisadditional information is encouraged.

Preparation of work areas for O&Mactivities sometimes involve the use of amini-enclosure. Other techniques, such asthe use of a glovebag taped over a self-supporting framework might be used as asubstitute for a mini-enclosure whereappropriate. For small amounts ofremoval work (such as removing a smallamount of fireproofing, or cutting a hole

in asbestos-containing plaster) where anenclosure is desired or needed, a glovebagcan be used in lieu of a full mini-enclosure.

Mini-Enclosure A mini-enclosure isusually a polyethylene enclosure around awork area. Mini-enclosures are sealedenclosures used to protect the facilityenvironment as a secondary means to help,or attempt to, contain fibers or debrisgenerated during the work.

Mini-enclosures also serve to provide avisual barrier between the workers andany other personnel around the work area. As noted above, careful work practicesshould be the primary means of fibercontrol during the work in order to preventgross contamination of the mini-enclosure.

It is sometimes appropriate to extendmini-enclosures above ceilings, such as byusing polyethylene sheet and framingtaped together to provide enclosure aroundthe work area. The mini-enclosure shouldnot contact ACM covered surfaces. Theconstruction will vary depending onwhether the enclosure will be attached topipes, conduit, metal hangers, or someother form of existing construction.

There are a variety of commerciallyavailable types of mini-enclosures,including prefabricated pop-up boxes andadjustable framework assemblies to


W-20...Continued permit different sizes of enclosures to beconstructed. Disposable liners for mini-enclosures (to facilitate set up anddismantling of the enclosure) are availablefrom some manufacturers. It might bebeneficial to construct or purchase aportable mini-enclosure unit that worksfor the typical conditions found in a givenfacility.

It is recommended that two workers beused to set up and operate mini-enclosures. To construct a mini-enclosure,erect a framework of wood, PVC piping ormetal framing that will enclose the workarea and be large enough for one person towork inside. The minimum width anddepth of the enclosure should be at least 3feet (1 meter). The height of the enclosurewill vary depending upon the work to beperformed and the height of the work area. A larger enclosure is preferable wherespace permits. However, if the enclosureis too large, the final cleaning process willrequire more time. A mini-enclosure caninclude a separate 3 foot by 3 foot by 7foot (1 x 1 x 2.1 meters) change room,with curtain doorways, attached to themini-enclosure for changing and removingprotective clothing.

If an entire room will be enclosed forperforming work, the framework isusually not necessary, unless wall surfaceswill be damaged by tape used to supportpolyethylene. A room can be enclosed forO&M work by installing one layer ofpolyethylene sheet on the walls and floorof the room.

If the work to be performed is in anelevated location, the enclosure (andchange room, if used) should be erectedon a scaffold platform large enough tosupport the enclosure, change room (ifused), and a step off area outside theenclosure.

Refer to OSHA regulations 29 CFR1910.28 and 29 CFR 1926.451 concerningscaffold requirements. Any laddersand/or scaffolds used must be built andused in conformance with the OSHA

construction standards, and applicablestate and local standards. See Appendix Iof this manual.

Cover the floor and the framework for theenclosure and change room with one layerof polyethylene attached using duct tape. A second layer of polyethylene laid on thefloor might facilitate clean up work, orreduce the possibility of tearing thepolyethylene if equipment is used (do notuse two layers under the legs of ladders). Construct curtain doorways between thechange room and the enclosure andbetween the change room and the areaoutside the change room. A curtaindoorway is made of three overlappingsheets of polyethylene. Attach sheets toframework at top and one side. Themiddle sheet should be attached on oneside, and the inner and outer sheetsattached on the other side. A sheet ofpolyethylene approximately 5 feet by 5feet (1.5 meters by 1.5 meters) or largershould be installed outside the changeroom for use as a step off area and as aplace to put decontaminated materialsremoved from the work area.

Mini-enclosures should be constructedwith a ceiling of polyethylene if work willnot be performed above the enclosure. Ifwork is to be performed above theenclosure and the ceiling is not ACM, theenclosure should extend to and be sealedto the ceiling or grid system. If theenclosure is below an ACM finishedsurface, use one of the following methods:

1. If ACM cannot be contacted, theenclosure should be separated fromthe ceiling by a narrow space.

2. If ACM will withstand contactwithout damage and is in goodcondition, foam tape (1" (25mm) orthicker) can be placed on the topedge of the enclosure. Gently liftenclosure into place until sufficient


W-20...Continued contact is made to provide a seal tothe surface.

After enclosure is in place, check for, andclean up any debris generated byenclosure installation.

Mini-enclosures should be set up with anegative pressure system as describedbelow to reduce the possibility of fibersbeing released from the enclosure and tofilter the air inside the enclosure.

Negative Pressure Systemand HEPA Filtered LocalExhaust Ventilation:

Note: Certain configurations of negativepressure systems (pressure differentialsystems) are covered by patents. The APMshould review applicable patent informationregarding use of these systems. This manualuses the term "negative pressure system" as asynonym for "pressure differential system".

Mini-enclosures should be provided with anegative pressure system to reduce thepossibility of fibers being released fromthe enclosure during the work, and to filterinside air discharged from the enclosure. Negative pressure inside mini-enclosuresis commonly provided by a HighEfficiency Particulate Air (HEPA) filteredvacuum or by negative pressure machines,depending upon the size of the enclosure. Pressure differential systems andsuggested rates of air circulation in termsof air changes per hour are discussed inthe “Evaluation” for specification Section01513 "Temporary Pressure Differential &Air Circulation System" of the NIBSAsbestos Abatement and Management inBuildings: Model Guide Specifications. A HEPA vacuum will usually providesufficient negative pressure for a small

enclosure. Larger enclosures mightrequire a small negative pressure machine(HEPA filtered fan unit) to achieve anegative pressure inside the enclosure.

A negative pressure system for a mini-enclosure most commonly locates theHEPA vacuum or negative pressuremachine outside the enclosure. The intakeside of the unit is ducted to the enclosurethrough the vacuum hose or flexible ductmaterial taped to a hole in the enclosureon the side opposite from the change roomor as close as possible to where the workwill be performed. The filtered exhaustside of the unit should be ducted to theoutside if possible. However, mostvacuum units do not provide a connectionfor an exhaust duct, and are commonlyexhausted to the inside. Additionalprotection might be desirable for an areawhere air is exhausted inside a building. A work practice is provided for changingfilters in HEPA vacuums and negativepressure machines (HEPA filtered exhaustfans) when needed. Filters should not bechanged without following these workpractices.

When HEPA filtered local exhaustventilation is used in a work practice, thiscan be in addition to, or in place of, anegative pressure system. A HEPAfiltered local exhaust ventilation systemmight replace a negative pressure systemif the ventilation system provides adequatenegative pressure in the work area. Somework practices use HEPA filtered localexhaust ventilation for fiber control wherean enclosure is not used. A HEPAventilation system can use a HEPAvacuum or negative pressure machine. The hose attached to the HEPA unitshould be kept as close as possible to thelocation where ACM might be, or is,disturbed.


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IV. Surfacing MaterialsWork Practices

S-3 # Surfacing ACM # Asbestos O&M Work Practices # © NIBS 1996# Page -79

Section IV Surfacing Materials Work PracticesSurfacing Materials Location Illustration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78Code Levels DescriptionS1 A B C Moving one non-asbestos-containing ceiling panel below a

plenum space that has exposed surfacing ACM . . . . . . . . . . . . . . . . . 87S2 A B Attach component to an ACM finished surface that is

above a ceiling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95S3 B C Remove a small amount of ACM surfacing above a ceiling . . . . . . . . 99S4 A B C Work in ceiling plenum space where exposed surfacing

ACM is present . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105S5 A B C Install wiring in plenum space where exposed surfacing

ACM is present . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 113S6 A B C Attach item to ceiling finished with ACM . . . . . . . . . . . . . . . . . . . . . 121S7 A B C Repair or replace item in surface finished with ACM . . . . . . . . . . . . 129S8 B C Cut or drill hole in surfacing ACM . . . . . . . . . . . . . . . . . . . . . . . . . . 136S9 A B Replace bulbs in light fixture attached to or in surface

finished with ACM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 141S10 A Clean room with exposed surfaces finished with ACM . . . . . . . . . . 145S11 A B C Repair damaged surfacing ACM . . . . . . . . . . . . . . . . . . . . . . . . . . . . 147S12 A B C Accessing through an ACM finished surface . . . . . . . . . . . . . . . . . . 152S13 A B C Painting surfacing ACM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 158

Figure 8 illustrates typical applications of these work practices.

GENERAL NOTESUse of these procedures is limited tosituations where the amount of wastegenerated is not greater in size than theOSHA limit on Class III work (operationwill generate no more waste than will fitinto one 60 inch by 60 inch glovebag ordisposal bag).

The three primary types of surfacing ACMidentified in developing work practiceexamples are fireproofing, acousticalplaster, and decorative textured finishes. Definitions of all three are included in theglossary in Appendix F.

Fireproofing

Fireproofing is one of the more importantlife safety systems in a buildings. Anyaction that compromises the fireproofingcould, in the event of a fire, result ininjury or death to building occupants orfirefighters. The design of an asbestosO&M program that affects fireproofingmust have as its starting point the stepsnecessary to maintain the fire safeintegrity of the fireproofing system.

Fireproofing maintenance: The facility

may have in place a program formaintaining the fireproofing system. Ifthis is the case, the asbestos O&M needsto add the necessary asbestos control andworker protection elements to this existingprogram. The program for maintainingthe fireproofing should includeinformation on:

C The required fire rating of eachfireproofed building element.

C The thickness of the existing spray


fireproofing material that must bepreserved in order to provide theneeded fire rating.

C Specific application requirements (e.g.requirement for wire lath, bondingadhesive, or surface coatings) thatmay need to be preserved during workthat impacts the system.

Patching Fireproofing: The system usedto patch any locations where the existingfireproofing is removed during amaintenance activity needs to be designed. There may be separate requirements foreach required fire rating and each buildingcomponent. The design for the patchingsystem should include: C The type of fireproofing patch

material to be used. The materialshould be specifically designed as afireproofing patch material, or at leastapproved by the manufacturer for thatpurpose. The material needs to have aUL fire endurance test for theparticular application. It must becompatible with the existingfireproofing system. The designationof a patching material should made bya specific brand name rather than ageneric designation.

C Thickness required for each neededfire rating.

C Surface preparation requirements. This needs to include consideration ofcompatibility with paints and primersthat already exist in the building orthat may be added as part ofmaintenance activities, and asbestosencapsulants that may be applied aspart of the asbestos O&M.

C Application instructions. The materialshould be approved for application byhand.

Design of the fireproofing maintenanceand patching requirements affect the lifeand safety of building occupants, and assuch should be designed by a licensedarchitect or engineer. These should be putin the form of a work practice andincluded with the asbestos O&M.

The asbestos O&M should add thenecessary asbestos control and workerprotection measures to the program tomaintain the facility’s fire protection.

Wetting: Wetting or surface misting withamended water is one of the most commonasbestos control procedures. Mostfireproofings materials are fairly forgivingof being wetted. However, fireproofing isan essential life-safety system and shouldnot be carelessly tampered with. Duringdesign of the O&M program check withthe manufacturer of the fireproofing aboutthe wisdom of wetting the material withwhat is essentially soapy water. If themanufacturer is not available then followthe cautious route and restrict wetting to asurface misting. Care should also be usedto avoid wetting materials so much thatproblems with the HEPA vacuum arecreated. Many HEPA vacuums havepaper bags as their first filter. Wetmaterial can cause this bag to fail creatingproblems with emptying the HEPAvacuum, and possibly prematurelyclogging the secondary filter, or evencompromising it. In no case should aremoval or penetrating encapsulant beused for this purpose unless it has aspecific UL test rating. See UnderwritersFire Resistance Directory, current edition,for further information and ratings.

Lockback encapsulants: Beginning withits 1989 edition, UnderwritersLaboratories requires all components of afireproofing system to be subjected to anE-119 burn test. This includes anyprimers (an encapsulant is a primer in thisapplication). A primer (encapsulant)incompatibility could cause thefireproofing to fall off and leave the steelexposed and unprotected. If theencapsulant affect the bond of thepatching material, it could fall off. If theencapsulant softens too much whenheated, it can cause the fireproofing to falloff during fire conditions. Someencapsulant manufacturers have testingtheir products with common fireproofing


materials. The designer must select afireproofing patching material andencapsulant that have been tested together.Otherwise there is a real possibility of afireproofing failure, and the installationwon’t conform to the test criteria and theinstallation will not have a UL rating. Since so many local codes and FireMarshall requirements refer to the ULcriteria, the liability consequences ofinstalling an unrated system could bedevastating. C If the steel in the building was primed

prior to fireproofing, The patchingmaterial must be compatible with boththe existing primer and any primerthat may be applied duringmaintenance activities. In thisinstance the primer can be used for thelockback.

C Some fireproofing systems have aadhesive/sealer that can be used as alock-back. This is preferable to use ofa lock-back encapsulant as it avoidsencapsulant compatibility issuesaltogether.

Acoustical Plaster

Acoustical plasters have both anengineering and aesthetic function. Thesefunctions should be preserved andmaintained by the O&M program.

Acoustical: The typical asbestos-containing acoustical plaster has arelatively open composition that allowssound waves to penetrate into and throughthe plaster. If the plaster is on a solidsubstrate such as a scratch coat or deck,then the sound reflects around inside theacoustic plaster and is absorbed (actuallyturned to heat). This affects primarilyhigh frequency sounds. This affect can bemeasured and is expressed in terms of anoise reduction coefficient (NRC) rating. The noise reduction coefficient and theparticular frequencies affected areimportant in the design of public assemblyand performance spaces. Theintelligibility of speech and clarity ofmusic are impacted if the NRC rating ischanged. If the surface is painted, thepaint may seal the surface of the plaster sothat sound can no longer penetrate as well. This will reduce the absorption of higherfrequency sounds and allow greaterreflection of these sounds. The change isnormally described as being more live,brittle, bright, or harsh. A simple changelike painting or application of an asbestosencapsulant can dramatically change the

space.

Aesthetic: Acoustical plasters typicallyhave a sandy or textured surface. Evenwhen painted the texture of these materialsusually echoes through the paint film. During O&M activities and patching andpainting should be conducted in a mannerthat matches the original surface. This canbe accomplished by specifying a particularpatching material and method ofapplication. It is possible that theapplication of the patching material couldsufficiently impact on the asbestos-containing plaster that this could affect theO&M Level appropriate for the activity. For example, the blending of a sand finishpatch into an existing asbestos-containingacoustical plaster could disturb the ACMenough to turn a Level B work practiceinto a Level C.

Wetting: Many of the work practicerequire that the acoustical plaster bemisted with amended water. If not donecarefully this could stain the surface. Stains result from two processes. Iflightly dampened, impurities left behindwhen the water evaporates can stain thesurface. If the surface is over wetted, finematerial in the acoustical finish can besuspended by the water, or water solublecomponents may dissolve in the water.


These suspended materials migrate to themargins of the wet spot and are depositedin a ring-like stain as the water evaporates. Staining can be avoided by restricting theamount of water used to what is necessaryfor asbestos control purposes. Duringdesign of an O&M procedure wettingprocedures should be tried out on asurface in a hidden or inconspicuous placeto determine how wetting can beaccomplished without staining. Ifstaining is a problem the O&M designermay want to experiment with the use ofdistilled or demineralized water to

eliminate staining from impurities in thewater.

When selecting work practices for asurfacing material it is important todistinguish between situations where thematerial is in its original condition andthose where it has been encapsulated orcoated with layers of paint. Differentwork practices may be necessary for eachsituation. This should be clearly describedin each work practice.

Decorative Textured Finishes

Decorative textured coatings do not havean acoustical function. The appearance ofthese materials should be maintained inthe same manner as for work on acousticalplasters.

Designing and Implementing Work Practices

An O&M program will be easier and morepractical to implement and more costefficient if it is designed so that themajority of work can be performedwithout enclosures. For this to happen,each work practice needs to be developedto the point that there is no airborneexposure to asbestos (as defined byOSHA). In terms of the OSHAconstruction standard this means that aNegative Exposure Assessment (NEA)must be made.

In general, developing asbestos controlprocedures used during the work to theextent that Level A and B controls canreliably control airborne fiber levels andcontrol the spread of ACM dust and debriswill result in a safer and more economicalO&M program. Limit the use of Level Cwork practices to outside abatementcontractors unless these procedures will beused on a routine basis.

The work practices given in this manualare examples of procedures that aretypically useable for the situationsdescribed. The level of training,experience and skill of the staffperforming the work, and the exact type ofmaterial and material conditions will varyfrom facility to facility. The O&Mdesigner needs to adjust the work practicesin the example to work for the specificmaterials and workers in a facility.

Paint usually needs to be removed prior towelding operations. Usually paint onstructural steel is lead-based. Lead-basedpaint O&M work practices will need to bedeveloped for this work and coordinatedwith the asbestos O&M program. Refer tothe NIBS publication “Operation andMaintenance of Lead-Based Paint” forinformation on setting up an O&Mprogram and for appropriate workpractices.


Work that occurs in the vicinity of anACM surfacing treatment, but does notcontact it and will not disturb it, is notgiven a level designation but requirescontrol to insure that a disturbance doesnot occur. This control can beaccomplished by designating spaces suchas above ceiling plenums as “ControlledAreas.” ACM surface treatments in thevicinity of work but which do not need tobe contacted should be designated as“Controlled Systems.” Exposuremonitoring is not required for theseactivities as ACM is not being contacted. Awareness training is needed to informworkers about the location of the ACM,and to advise them to avoid contacting it.

Level A work is an OSHA Class IVactivity, where an ACM surfacingtreatment is contacted but not disturbed,and a negative exposure assessment(NEA) has been made. Careful handling,wet methods, HEPA vacuums, promptclean up and disposal, and awarenesstraining for workers is required. Respiratory protection is not required byOSHA for this level of work, but is anoption that the designer should consider. No area protection is required for thislevel of work.

During design of the O&M procedure, aCompetent Person (as defined by OSHA)must make a determination that theexposed surfacing ACM is in goodcondition and that contact with thematerial without disturbance will notcause an exposure to a worker that isabove the PEL.

For work above ceilings or a similarlyinaccessible space a competent personmust make a determination that theexposed surfacing is in good condition,and that there is no ACM, debris or duston top of the ceiling tiles or elsewhere inthe plenum where it might be disturbed.

! Design: During design of the O&Mprocedure, the designer (who must be

a Competent Person as defined byOSHA) must make a determinationthat the ACM is in good condition andthat it will not be disturbed by thework, and that there is no debris ordust on top of ceiling tiles or otherlocations where it could be disturbedduring the work.

! Implementation: The AsbestosProgram Manager (APM) orsomebody designated by the APMshould be qualified as a competentperson so that someone is availablewhen new situations come up. Ideallythe person that is currently in chargeof assigning work to the maintenancestaff should be this competent person.

Level B work is an OSHA Class IIIactivity on an ACM surfacing treatmentwhere the material is disturbed but anegative exposure assessment has beenmade. Level B work practices should beused for work that can be accomplishedwithout generating airborne fiber levels inthe breathing zone of workers that areabove the PEL, that does not spreadvisible dust and debris from the ACM, andthat is accomplished without TSI orsurfacing ACM being drilled, cut,abraded, sanded, chipped, broken orsawed. The “disturbance” of the ACM inthis instance is usually the removal of asmall quantity of material to permit repairor maintenance work, or penetration by afastener. OSHA requires respiratoryprotection for work that disturbs surfacingtreatments even if the PEL is notexceeded. Drop cloths are not required byOSHA, but are a practical necessity forthis type of work.

WARNING: The Level B workpractices in this manual cannot beused until a negative exposureassessment has been made. Level Bwork practices are performed withoutan enclosure. OSHA does not allowwork that disturbs surfacing ACM to


be performed outside of an enclosureunless there has been an NEA.

! Design: Work practices such ascareful handling and wetting, are usedto reduce fiber release. Local exhaustventilation using a HEPA vacuum isused to collect fibers at the point ofgeneration. Frequently, the wand ofan operating HEPA vacuum is used asa tool to remove the ACM. TheHEPA vacuum not only collects theremoved material and contains itinside the vacuum, but also collectsany released airborne fibers. TheHEPA vacuum accomplishedlocalized cleaning of the air in thevicinity of the work when used in thismanner, or if held near the location ofwork that disturbs ACM.

The designer selects the work practicein this section that most closelymatches the work to be accomplished. The work practice is modified asnecessary to accommodate conditionsin the facility. If the work is onfireproofing, the specific requirementsfor maintaining integrity of thefireproofing are added. The workpractice must then be tested. Thisshould be done by having the workersthat will be performing the workfollow the procedure. Normally,unless there is exposure data isavailable, this testing will have to beperformed inside an enclosure. During the test, the work practices areadjusted as necessary until exposuresare reliably kept below the OSHAPELs. The designer, who must be acompetent person, can then make anegative exposure assessment. If thefacility has requirements for areasamples, these are monitored duringthe test.

! Implementation: Each time thatwork is assigned the asbestos programmanager (APM) (who must also be acompetent person) must evaluate the

work area make a determination thatthe conditions at the specific job siteare equivalent to those that existingduring development of the workpractice, so that the work practice isapplicable.

Level C work is an OSHA Class IIIactivity on an ACM surface treatmentwhere the work includes drilling, cutting,abrading, sanding, chipping, breaking, orsawing; or there is no negative exposureassessment (the PEL may be exceeded). In this instance careful handling, wetting,and use of HEPA vacuums is notsufficient to prevent the escape of airbornefibers, dust and debris, and some sort ofenclosure is needed to protect theenvironment. Note that a mini-enclosureprotects the environment, but requires thatwork be performed in a contaminatedenvironment and as such may actuallyincrease the exposure to workers. Glovebags reduce exposures to bothworkers and the environment. Workersneed to be protected with respirators,protective clothing and decontaminationprocedures. OSHA requires respiratoryprotection, an enclosure and other workerprotection measures for this type of work.

Training as abatement workers is moreadequate for those performing Level Cwork in a mini-enclosure where exposureto elevated asbestos levels and the needfor a wet decontamination is possible. Frequently, O&M programs will avoid theuse of level C work practices. If level Cwork is infrequently encountered, it is bestto limit this type of work to outsideabatement contractors who have workersaccustomed to working in environmentswith elevated asbestos levels.

! Design: Initial monitoring needs tobe conducted to determine whatrespiratory protection and otherworker protection requirements willbe.


! Implementation: Periodicmonitoring must be performed tovalidate the selection of respiratory

protection.

Work Practices

Careful work practices should be theprimary means used to prevent releases ofasbestos fibers during O&M work. Suchpractices include control measures such ascareful handling, wetting and localexhaust using HEPA vacuums that controlor collect fibers at the source. The goal ofall asbestos O&M work should be toprevent any exposure of the worker andunnecessary contamination of the workarea, drop cloths, mini-enclosures andother secondary control devices. Mini-enclosures should never be used to excusesloppy work or creation of "bigger"messes.

Some work practices in this manual callfor wet ACM to scraped directly into thenozzle of a HEPA vacuum or to even usethe nozzle as a tool to remove wettedACM. This is very effective in controllingthe release of airborne fibers or ACMdebris. To use this type of procedure the aHEPA vacuum that can handle wet waste(wet/dry vacuum) and that has enoughcapacity to hold waste generated duringremoval operation should be used. Insome O&M programs, the HEPA vacuum

is used as the primary storage facility forremoved ACM. Sucking ACM down aHEPA vacuum hose has a tendency toleave residue on the inside of the hose. This is alright if workers are trained toseal the hose before turning off thevacuum as routine procedure. Thereshould be a periodic washing out of hehose with amended water. This can serveto add extra water to the collected waste atthe time the HEPA vacuum is emptied.

If there is frequent need for work in alocation where ACM will be disturbed bythe work, (for example passing cablesbeneath a fireproofed beam that is close tothe ceiling) it is prudent to install a barrier,sleeve or conduit to allow easier futureaccess past the ACM. If this is done in areturn air plenum the barrier, sleeve orconduit should be metal to avoid addingcombustible material which may create afire safety and code issue.


Limits

The amount of material disturbed byO&M activities should be limited. LevelA work should generate no waste at all. Level B activities should be limited towork that will disturb a very small amountof material. Level C work should belimited to situations where the amount ofwaste generated is not greater in size than

the OSHA limit on Class III work(operation will generate no more wastethan will fit into one 60" by 60" glovebagor disposal bag). It is standard industrypractice not to fill these bags more thanone-third full, to allow for proper sealingand to guard against breakage.


S1 . SummaryMoving one non-asbestos-containing ceilingpanel below a plenum space that has exposedsurfacing ACM.

SummaryThese work practices cover situationswhere access is needed into a plenumabove a non-asbestos-containing ceilingwhich is installed below exposedsurfacing ACM. If debris and/or dust hasfallen from the ACM and has collected ontop of ceiling tiles, it could be disturbedwhen a tile is lifted out. This disturbancecould release asbestos into the air. If thetile impacts ACM when it is lifted thiscould release debris, dust and airborneasbestos. The work practices are intendedto prevent these disturbances. Differentlevels of work practice will be neededdepending upon the amount of debris anddust that is on top of the ceiling:

Maintenance staff employees should beinstructed not to remove ceiling tilesbelow asbestos-containing materials(ACM) without wearing the properrespiratory protection, clearing the area ofother people, and observing asbestoswaste disposal procedures. Personnelperforming this work should be properlytrained and protected.

Level A: Level A work practices shouldonly be used in situations where: the ACMsurface material is in good condition, thereis no ACM dust and/or debris on top ofceiling tiles, and ACM above the ceilingwill not be disturbed when the tile islifted. The O&M program designer (whomust be an OSHA competent person) willneed to make a determination that liftingout a ceiling tile could not cause anexposure to a worker. This determinationshould be made based on the training, skilland experience of the workers; thecondition of the ACM surfacing material;and current or future activities that might

affect the ACM. The material should beperiodically observed to determine if therehas been a change in condition. If there ischange in the activity impacting the ACM (For example, a roof rip off mightdislodge some fireproofing from theunderside of a roof deck) conditions in theceiling plenum should be re-evaluated. This evaluation needs to be made by anOSHA competent person.

Note : Maintenance staff employeesshould be instructed: not to removeceiling tiles below ACM without wearingthe proper respiratory protection, clearingthe area of other people, and observingasbestos waste disposal procedures. Personnel performing this work should beproperly trained and protected.

Level B: If there is ACM dust or debrison top of the ceiling tiles or if ACM isgoing to be disturbed when the ceiling tileis lifted, but airborne fiber levelsgenerated during the work can bemaintained below the OSHA PEL, thenLevel B procedures are appropriate. LevelB procedures for this purpose consistmainly of carefully lifting tiles tominimize disturbance, and use of a HEPAvacuum to pick up debris and collect anyairborne fibers at the point of release. During design of the O&M program, anegative exposure assessment (NEA) mustbe made. Refer to the introduction fordetails on making an NEA. The O&Mdesigner will have to determine if theconditions that prevailed during the NEAare representative of those in the facility.In general, an NEA is possible with LevelB work practices as long as ACM debrisdoes not freely fall to the floor when a tile

S1 . Summary ... continued


is lifted out. Level B procedures arecapable of controlling small amounts ofdebris on top of the ceiling. However, thiswill be dependent on the skill, experienceand patience of the worker. At somepoint, there will be enough debris that thecontrols cannot be depended on. Thispoint will differ for each facility and workforce. Usually, Level C procedures areresorted to when conditions are such thatLevel B procedures cannot be relied uponto control the fall of debris. The O&Mdesigner will need to experiment duringthe performance of the NEA to determinewhere the cut off is for a specific facility. Level B procedures are OSHA Class IIIwork and as such are limited to activitieswhere only a small amount of material isdisturbed.

Level C: If there is enough ACMdebris on top of the ceiling tiles that LevelB work practices cannot reliably maintainairborne fiber levels below the OSHAPEL or if fallout of debris or dust can notadequately be controlled, then anenclosure will help protect the buildingenvironment, and Level C proceduresshould be used. Level B proceduresshould be used inside of a mini-enclosureas the primary control mechanism overfiber release. Airborne asbestos isreleased at the ceiling line when debris isdisturbed by a lifting tile. The use of aHEPA vacuum at the point of disturbancewill collect these airborne fibers. Thenegative pressure inside a properly

installed mini-enclosure helps drawairborne fibers away from the plenum. Asbestos is also released into the air at thefloor line when debris lands on the floor(prompt clean up will prevent additionalrelease from the ACM being walked on). The mini-enclosure helps contain thesefibers, and the HEPA vacuum used toform a negative pressure will help collectthem. Limit the use of Level C workpractices to individuals with the propertraining and experience.

These work practices are for individualsmall maintenance activities where theamount of debris involved can becontained in one 60" by 60" disposal bag. It is standard industry practice not to fillthese bags more than one-third full, toallow for proper sealing and to guardagainst breakage. They should not be usedfor work such as replacing all ceilingpanels in a room. The work practices arebased on “T-bar” ceilings with lift outpanels, but can be easily modified for Z-spline and other sorts of ceilings thatprovide plenum access.

Maintenance staff employees should beinstructed not to remove ceiling tilesbelow ACM without wearing the properrespiratory protection, clearing the area ofother people, and observing asbestoswaste disposal procedures. Personnelperforming this work should be properlytrained and protected.



ExamplesThe work practices in this section are examples. They should be edited as necessary tosuit the requirements of the O&M program for the specific facility.

Level A: Move a non-ACM ceiling panel to make observations above a lay-in ceiling belowexposed surfacing ACM in good condition, where a competent person has determinedthat there is no ACM dust or debris on top of the ceiling tiles.

Level B: Move or replace non-ACM ceiling panels in a lay-in ceiling below exposed surfacingACM in good or fair condition where there may be dust or debris on top of the ceilingtile.

Level C: Move non-ACM ceiling panels to access plenum area where plenum space containsexposed surfacing or other ACM in poor condition and there is ACM dust and debrispresent on top of ceiling.

Related Work PracticesS 2 Attach item to an ACM finished surface that is above a ceiling.S 3 Work in ceiling plenum space where exposed surfacing ACM is present.S 4 Install wiring in plenum space where exposed surfacing ACM is present.M 2 Remove asbestos-containing ceiling panels in lay-in ceiling system.M 4 Remove asbestos-containing ceiling tiles in spline ceiling system.

Worker Recommendations One worker for Levels A and B. Two workers for Level C. A person with air monitoringtraining might be required. This person can be one of the workers.


S1 . Level AMoving one non-asbestos-containing ceilingpanel below a plenum space that hasexposed surfacing ACM

ExampleThe following are examples of work that can be performed using the procedures of thisLevel A work practice. If job conditions vary from the examples stop work and notifyyour supervisor.

A. Move a non-ACM ceiling panel to make observations above a lay-in ceiling belowexposed surfacing ACM in good condition, where a competent person hasdetermined that there is no ACM dust or debris on top of the ceiling tiles.

NotesThe space above the ceiling is a “controlled area.” Do not enter this area, or disturbceiling tiles unless authorized by facility management

Do not enter the space above the ceiling using this work practice unless you know thatthere is no ACM debris on top of ceiling. If you do not know if there is debris on top ofthe ceiling then use Level B procedures to open ceiling.

Work Practice1. Perform Pre-work activities on Level A Worker Checklist.

2. See General Procedure W1 for standard tools, equipment and materials list.

3. Place ladder or scaffold in work area.

4. Carefully lift up ceiling panel. If lifting is obstructed by wires, ducts, conduit, etc.,move to another panel. Keep panel as flat as possible while lifting panel. Lift panelslightly above grid system and slowly slide panel to one side, leaving panel on top ofan adjacent panel.

5. Wet wipe or HEPA vacuum the underside of the panel which was moved. Carefullyreplace ceiling panel and complete applicable steps on Level A Worker Checklist tocomplete work.


S1 . Level BMoving one non-asbestos-containing ceilingpanel below a plenum space that has exposedsurfacing ACM

ExampleThe following are examples of work that can be performed using the procedures of thisLevel B work practice. If job conditions vary from the examples stop work and notifyyour supervisor.

A. Move or replace a non-ACM ceiling panel in a lay-in ceiling below exposedsurfacing ACM in good or fair condition where there may be a small amount ofdebris or dust on top of the ceiling tile.

NotesThe space above the ceiling is a “controlled area.” Do not enter this area, or disturbceiling tiles unless you have been authorized by facility management.

Use this work practice where there is debris or dust on top of the ceiling tiles, but theceiling can be opened using the procedures in this work practice without generatingvisible dust or debris from material on top of the ceiling.

Do not use this procedure if more than a very small amount of debris will be disturbed. Ifmore than a very small amount of debris is found, stop work, close ceiling and notifyyour supervisor.

Work Practice1. Perform Pre-work activities on Level B Worker Checklist.

2. Tools, equipment and materials:

a. Tools as needed from the lists in General Procedure W1

b. Tools and materials needed for work on ceiling

c. HEPA vacuum with a long enough hose to sit on the floor with the nozzle beingused above the ceiling.

3. Prepare work area with drop cloth. See General Procedure W10.

4. Place tools, equipment and materials needed onto drop cloth.

5. Put on respirator and perform fit check.

6. HEPA vacuum around edges of all panels to be removed.

7. While holding nozzle of HEPA vacuum in vicinity slowly lift one edge of centerceiling panel. Immediately HEPA vacuum space at lifted edge. Lift entire panelstraight up and HEPA vacuum all four sides.

8. Place panel on top of adjacent ceiling.

9. Note that the operation of the HEPA vacuum is intended to clean the air in thelocation of the work. As such the nozzle should be kept above the ceiling as much aspossible and the canister on the floor.

S1 . Level B ... continued


10. Climb to a position which permits access to the top of the ceiling adjacent to theremoved panel.

11. Working in the space above the ceiling, HEPA vacuum both sides of the ceiling panelfirst removed and hand it down into a 6 mil (0.15 mm) polyethylene bag for storage.

12. Remove loose material hanging from the friable ACM with the suction from theHEPA vacuum.

13. Pass wand of operating HEPA vacuum through air between ACM and top of ceiling.

14. HEPA vacuum the tops of all ceiling panels which are in reach.

15. Carefully HEPA vacuum the crack between the suspension system and ceiling panelsfrom the top for all ceiling panels within reach.

16. Remove ceiling panels as required while constantly HEPA vacuuming all four edgesof panel and suspension system.

17. Working in space above ceiling HEPA vacuum both sides on each panel removedand hand each down into a 6 mil (0.15 mm) polyethylene bag.

18. Maintain HEPA vacuum in operation with nozzle above ceiling and exhaust at floorfor the entire time that the ceiling is open and work is being done above the ceiling.

19. When above-ceiling work is complete replace ceiling panels.

20. HEPA vacuum worker's head, arm, and shoulders before climbing down fromceiling.

21. HEPA vacuum ladder while climbing down.

22. While standing on plastic sheet thoroughly HEPA vacuum ladder and pass it toperson standing off sheet.

23. Complete applicable steps on Level B Worker Checklist.


S1 . Level CMoving one non-asbestos-containing ceilingpanel below a plenum space that has exposedsurfacing ACM.

ExampleThe following are examples of work that can be performed using the procedures of thisLevel C work practice. If job conditions vary from the examples stop work and notifyyour supervisor.

A. Move non-ACM ceiling panels to access plenum area where plenum space containsexposed surfacing or other ACM in poor condition and there is ACM dust or debrispresent on top of ceiling.

Note:The space above the ceiling is a “controlled area.” Do not enter this area, or disturbceiling tiles unless authorized by facility management

These procedures involve working in an environment where there could be elevatedlevels of airborne asbestos. Do not attempt to use this work practice unless you havebeen trained as an asbestos abatement worker including training in the use of respiratorsand personal and area decontamination procedures.

Do not use this procedure if more debris will be disturbed than will fit comfortably intoone 60" by 60" disposal bag. If more than this amount of debris is found, stop work,close ceiling and notify your supervisor.

Work Practice1. Perform Pre-work activities on Level C checklist.



b. Tools and materials needed for work on ceiling

3. Complete Worker General Procedure W4 “Secure Work Area”

4. Put down drop sheet and complete Worker General Procedure W10 “PolyethyleneDrop Cloth”

5. Erect mini-enclosure and set up negative pressure system and/or HEPA filtered localexhaust ventilation according to General Procedure W20 “Mini-Enclosure”

6. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuuminside enclosure for vacuuming areas above ceiling.

7. Enter enclosure

8. Put on respirator and perform fit test, and put on protective clothing. Enterenclosure.

9. Carefully lift up ceiling panel while HEPA vacuuming around edges of panel. Remove any ACM debris and dust from the top of the ceiling panel or adjacentpanels with the HEPA vacuum. Keep panel as flat as possible while lifting panel. Lift panel slightly above grid system and slowly slide panel to one side, leaving panel

S1 . Level C ... continued


on top of an adjacent panel. Maintain nozzle of HEPA vacuum in operation aboveplane of the ceiling at all times that the ceiling is open.

10. Lightly mist plenum space and top side of ceiling where work will occur usinggarden sprayer with amended water.

11. Pick up any bulk debris on top of ceiling panels where work will occur and place intodisposal bags.

12. HEPA vacuum ceiling suspension system and top side of ceiling where work willoccur.

13. Wet wipe or HEPA vacuum the underside of the panel which was moved. Carefullyreplace ceiling panel and perform clean-up and tear-down steps on Level C WorkerChecklist to complete work.


S2 . SummaryAttach component to an ACM finished surfaceabove a ceiling.

SummaryThis work practice covers the procedures for attaching components to an ACM finishedsurface (such as a steel beam with a covering of spray-applied fireproofing) that islocated above a ceiling.

ExamplesThe work practices in this section are examples. They should be edited as necessary to tosuit the requirements of the O&M program for the specific facility

Level A: A. Mount a “rosettes” with bedding adhesive to the surface of fireproofing above asuspended ceiling. Attach device to “rosettes.”

The O&M designer or APM must determine that the adhesion and cohesion of thefireproofing is strong enough to support the load of the device being installed. Thiswork practice is most useful for small light devices such as sensors for a fire alarm orenergy management system.

Level B: A. Clamp a bracket onto the flange of a beam that is covered with spray appliedasbestos-containing fireproofing.

Related Work PracticesS1 Moving one non-asbestos-containing ceiling panel below a plenum space that has

exposed surfacing ACM.S5 Attach component to ceiling finished with ACM.

Worker Recommendations One worker is usually sufficient for Level A and B. More workers may be needed forLevel A and Level B to increase efficiency or for additional health and/or safetyconsiderations. A person with air monitoring training might be required. This personcan be a worker.


S2 . Level AAttach component to an ACM finished surfaceabove a ceiling.

ExampleThe following is an example of work that can be performed using the procedures of thisLevel A work practice. If job conditions vary from the examples stop work and notifyyour supervisor.

A. Mount a “rosettes” with bedding adhesive to the surface of fireproofing above asuspended ceiling if a competent person determines that the fireproofing will supportthe load of the device being installed. Attach device to “rosettes.”

NotesThe ceiling is a “controlled system.” Do not contact or work on ceiling unless authorizedby facility management

Work Practice1. Perform Pre-work activities on Level A checklist.




4. Place tools, equipment and materials needed in work area.

5. Put bedding adhesive on bottom of rosette and press against ceiling.

6. Install device by attaching to rosette.

7. Perform clean-up and tear-down steps on Level A checklist to complete work.


S2. Level BAttach component to an ACM finished surfaceabove a ceiling.


A. Clamp a bracket onto the flange of a beam that is covered with spray appliedasbestos-containing fireproofing.

NotesA Negative Exposure Assessment must have been made by a Competent Person beforethis work practice is used. If a negative exposure assessment (NEA) has not been made,stop work and notify your supervisor.

The space above the ceiling is a “controlled area.” Do not enter this area, or disturbceiling tiles unless you have been authorized by facility management. Coordinate workwith proper O & M work practice for accessing type of ceiling present in work area. SeeWork Practices S1, M2, and M4.

Do not spray encapsulant on fireproofing or steel to which fireproofing is to be appliedwithout specific authorization from your supervisor. An inappropriate encapsulant couldcause the fireproofing to fail and result in a life threatening situation.

Work Practice1. Perform Pre-work activities on Level B checklist.



b. Bracket to be clamped to surface

3. Complete General Procedure W4 “Secure Work Area”


5. Place tools, equipment and materials needed into work area. Include a HEPAvacuum.

6. Obtain access through ceiling using O & M work practice selected (see note abovestep 1).

7. HEPA vacuum area above ceiling within reach from access hole.

8. Mist surface of fireproofing in location where bracket is to be installed with amendedwater. DO NOT SATURATE FIREPROOFING.

9. Hold bracket against surface of fireproofing and secure by tightening clamp throughfireproofing. Use care not to dislodge any fireproofing.

S2. Level B ... continued


10. Use a HEPA vacuum to remove any fireproofing material that has been loosened bythe clamp.

11. Repair any damage to the fireproofing with new fireproofing patching material that isapproved by its manufacturer for hand application. Install in accordance withmanufacturer’s instructions.

12. Carefully install item on bracket without disturbing fireproofing material. Performmaintenance work, repair area with new non-ACM surfacing, and perform clean-upand tear-down steps on Level B checklist to complete work.


S3 . SummaryRemove a small amount of ACM surfacingabove a ceiling

SummaryThis work practice covers the procedures removing a small amount of asbestos-containing fireproofing structural steel above a ceiling.

ExamplesThe work practices in this section are examples. They should be edited as necessary to tosuit the requirements of the O&M program for the specific facility

Level B: A. Remove up to one square foot of fireproofing from structural steel above a ceiling toattach a bracket.

Level C: A. Removing ACM fireproofing from a beam to permit new structural steel reinforcingand bracing to be welded in place to reinforce a floor under a new file room..

Paint usually needs to be removed prior to welding operations. Usually paint onstructural steel is lead-based. Lead-based paint O&M work practices will need to bedeveloped for this work and coordinated with the asbestos O&M program. Refer to theNIBS publication “Operation and Maintenance of Lead-Based Paint” for information onsetting up an O&M program and for appropriate work practices.

Related Work PracticesS1 Moving one non-asbestos-containing ceiling panel below a plenum space that has

exposed surfacing ACM.S8 Cut hole in surfacing ACM.

Worker Recommendations One worker is usually sufficient for Level B. Two workers for Level C. More workersmay be needed for Level A and Level B to increase efficiency or for additional healthand/or safety considerations. A person with air monitoring training might be required. This person can be a worker.


S3. Level BRemove a small amount of ACM surfacingabove a ceiling


A. Remove up to one square foot of fireproofing from structural steel above a ceiling toattach a bracket.


The space above the ceiling is a “controlled area.” Do not enter this area, or disturbceiling tiles unless you have been authorized by facility management. Coordinate workwith proper O & M work practice for accessing type of ceiling present in work area. SeeWork Practices S11, M2 or M4.

Do not spray encapsulant on fireproofing or steel to which fireproofing is to be appliedwithout specific authorization from your supervisor. An inappropriate encapsulant couldcause the fireproofing to fail and result in a life threatening situation.



3. Tools as needed from the lists in General Procedure W1

a. Bracket to be attached to beam.

b. Scraper 2-3" (50-75 mm) wide stiff blade

c. Stiff nylon bristle brushes

d. Replacement fireproofing patching material

4. Complete General Procedure W4 “Secure Work Area”


6. Place tools, equipment and materials needed into work area. Include a HEPAvacuum.

7. Obtain access through ceiling using O & M work practice selected (see note abovestep 1).


9. Wet fireproofing that is to be removed with amended water. Allow water to soakthrough fireproofing to substrate. Apply more water as required to saturatefireproofing that is to be removed.

S3. Level B ... continued


10. Scrape wetted fireproofing from steel. Hold a pan immediately under area beingscraped to catch debris. If dry fireproofing is encountered, stop scraping, re-wet andallow water to soak in. Remove all wetted material. Promptly place removedfireproofing in a disposal bag. Spray pan with amended water and wet wipe toremove all fireproofing debris and residue.

11. After fireproofing is removed, wet surface of steel with amended water and wet wipesurface with paper towels. Wet wipe until all residue is removed. After all residue isremoved wet wipe surface with clean water without surfactant. Dispose of papertowels as asbestos waste.

12. HEPA vacuum surface of steel and edge of remaining fireproofing.

13. Perform work as necessary to attach bracket to steel.

14. Replace removed fireproofing with new fireproofing patching material. Installfireproofing patch material in accordance with facility’s fireproofing repair workpractices, and manufacturer’s instructions.

15. Carefully install item on bracket without disturbing fireproofing material.

16. Perform clean-up and tear-down steps on Level B checklist to complete work.


S3 . Level CRemove a small amount of ACM surfacingabove a ceiling


A. Removing ACM fireproofing from a beam to permit new structural steel reinforcingand bracing to be welded in place to reinforce a floor under a new file room.

NotesDo not use this procedure if more material will be removed than will fit comfortably intoone 60" by 60" disposal bag. If more than this amount of material is involved, stop work,close ceiling and notify your supervisor.

The space above the ceiling is a “controlled area.” Do not enter this area, or disturbceiling tiles unless authorized by facility management Coordinate work with proper O &M work practice for accessing type of ceiling present in work area. See Work PracticesS1, M2, or M4.







d. Maintenance item(s) to be attached to surface

e. Replacement fireproofing patching material




6. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuumoutside of but with hose extending inside enclosure with for vacuuming areas aboveceiling.

7. Put on respirator and perform fit test, put on protective clothing

S3 . Level C... continued


8. Enter enclosure and obtain access through ceiling using appropriate O&M workpractice.


10. Extend mini-enclosure above ceiling, if feasible, using polyethylene sheet andframing taped together to provide enclosure around the work area without contactingACM covered surface. Vary construction of the extended mini-enclosure dependingon the existing construction above the ceiling. Polyethylene and framing may besecured to pipes, conduit, and metal hangers if they are not covered with ACM. If anextended mini-enclosure is not feasible, mist area above ceiling and lay apolyethylene drop cloth below the area where removal is required. If drop clothcannot be used, suspend polyethylene below immediate work area to catch ACM tobe removed. Worker should be located to one side of removal area (inside enclosure)during removal.

11. Wet fireproofing that is to be removed with amended water. Allow water to soakthrough fireproofing to substrate. Apply more water as required to saturatefireproofing that is to be removed.

12. Scrape wetted fireproofing from steel. Hold a pan immediately under area beingscraped to catch debris. If dry fireproofing is encountered, stop scraping, re-wet andallow water to soak in. Remove all wetted material. Promptly place removedfireproofing in a disposal bag. After completing removal of fireproofing spray panwith amended water and wet wipe to remove all fireproofing debris and residue.

13. After fireproofing is removed, wet surface of steel with amended water and wet wipesurface with paper towels. Wet wipe until all residue is removed. After all residue isremoved wet wipe surface with clean water without surfactant. Dispose of papertowels as asbestos waste.

14. HEPA vacuum surface of steel and edge of remaining fireproofing.

15. Perform work as necessary to attach bracket to steel.


17. Remove sufficient materials to permit installation of new structural steelreinforcement and braces. Remove sufficient material, from both sides of beam asnecessary, in areas of steel that will be heated sufficiently by the welding to causedelamination of fireproofing.

18. Remove paint on the steel in locations where welding is to occur, or where paint maybe overheated or burned during welding. Use paint removal procedures from thefacility’s Lead Based Paint O&M program, unless you know that paint has beentested and found to be lead-free. If you have not been trained and equipped toremove lead based paint, stop work and notify your supervisor.

19. Install new structural steel.

20. If the original steel installations was painted, repaint those areas from which paint hasbeen removed a primer approved for use with the patching fireproofing material.

21. If the replacement fireproofing requires an adhesive, apply a coating of fireproofingmanufacturer’s adhesive/sealer in accordance with manufacturer’s applicationinstructions.

S3 . Level C... continued


22. Do not spray encapsulant on fireproofing or steel to which fireproofing is to beapplied without specific authorization from your supervisor. An inappropriateencapsulant could cause the fireproofing to fail and result in a life threateningsituation.

23. Install new fireproofing in areas where fireproofing was removed and on all new steelwork. Install fireproofing in thickness as indicated on work order. Followmanufacturer’s directions for correct application of fireproofing.

24. Perform clean-up and tear-down steps on Level C checklist to complete work.


S4 . SummaryWork in ceiling plenum space where exposedsurfacing ACM is present.

SummaryThis work practice covers situations wherework must be performed in a ceilingplenum space that has exposed surfacingACM.

Use of these procedures is limited to asituation where the amount of wastegenerated is not greater in size than the

OSHA limit on Class III work (operationwill generate no more waste than will fitinto one 60" by 60" glovebag or disposalbag). It is standard industry practice notto fill these bags more than one-third full,to allow for proper sealing and to guardagainst breakage.

ExamplesWork above a ceiling where there is ACM fireproofing could result in contact with ofdisturbance of ACM. Maintenance of an HVAC mixing box is used an example toillustrate the use of these work practices.

Level A: Work above ceilings where there is ACM surfacing material but it is in good conditionand can be avoided during the work, and there is no ACM dust or debris on the mixingbox. Controls are needed to insure that a disturbance of the ACM does not occur. Thiscan be accomplished by designating the area above the ceiling as a “controlled area,” andallowing access to only those who have been given awareness training. The awarenesstraining needs to inform workers of the locations and need to avoid contact with theACM. Examples of this type of work are:

A. Replace HVAC mixing box: above ceiling, below asbestos-containing fireproofingin good condition, where there is no ACM dust or debris on the mixing box or any ofthe systems in the area of the work. The fireproofing is near to the mixing box andmay be contacted during the work.

B. Open or close one valve above ceiling where exposed fireproofing in good conditionis present.

C. Inspect HVAC mixing box below asbestos-containing fireproofing in good condition.

Level B: Work above ceilings where there is ACM surfacing material that is in good condition andcan be avoided during the work, but there is some loose ACM debris on top of the mixingbox. This debris needs to be removed before the box is worked on. This can beaccomplished by picking up the ACM with a HEPA vacuum and then wet wiping thesurface. The workers performing this work need to have at least O&M training. Anegative exposure assessment has to be made to demonstrate that airborne fiber levelsduring the work remain below the PELs. The types of work in this category include:

A. Replace HVAC mixing box: above ceiling, below asbestos-containing fireproofingin good condition. There is dust or debris from surfacing ACM is present on top ofbox, that is accessible and easily removed.



B. Install new conduit (attached to existing supports) in plenum space where exposedfireproofing in good condition is present.

C. Repair leak in non-ACM insulated water line above ceiling where exposed surfacingACM is present.

D. Maintain HVAC mixing box below asbestos-containing fireproofing in goodcondition.

Level C: This example pre-supposes that the situation is more difficult, and the top of the unit isinaccessible so that overspray cannot be removed before the unit is removed. It isassumed that overspray and debris will be dropped as the unit is maneuvered down out ofthe ceiling. This work practice requires that the wetting of fireproofing overspray. Thisis fine as this is not part of the fireproofing life safety system. Training as abatementworkers is more adequate for those performing Level C work in a mini-enclosure whereexposure to elevated asbestos levels and the need for a wet decontamination is possible. This project could probably be accomplished as a Level B task if all surfaces of themixing box were accessible and all ACM overspray was carefully removed prior toperforming the work (after a “remove overspray” work practice that did not exceed thePEL was developed).

Use of this procedure is limited to a situation where the amount of waste generated is notgreater in size than the OSHA limit on Class III work (operation will generate no morewaste than will fit into one 60" by 60" glovebag or disposal bag).

Frequently, O&M programs will avoid the use of Level C work practices. If Level Cwork is infrequently encountered, it is best to limit this type of work to outside abatementcontractors who are accustomed to working in environments with elevated asbestoslevels.

A. Replace HVAC mixing box above ceiling where the equipment, duct, hangers, andsurrounding conduit and piping are covered with loose ACM fireproofing overspray,debris and bounce back. Material on top of mixing box is inaccessible and cannot beremoved before box is lowered. Overspray on surrounding systems will be dislodgedif not removed before work is performed on the mixing box.

Related Work PracticesS1 Moving one non-asbestos-containing ceiling panel below a plenum space that

has exposed surfacing ACM.S2 Attach component to an ACM finished surface that is above a ceiling.S4 Install wiring in plenum space where ACM is present.M19 Remove HVAC filters in unit serving plenum space with exposed ACM.

Worker Recommendations: One worker is usually sufficient for Level A and Level B. Two workers for Level C. More workers may be needed to increase efficiency or for additional health and/or safety



considerations. A person with air monitoring training might be required. This personcan be a worker.


S4 . Level AWork in ceiling plenum space where exposedsurfacing ACM is present.


A. Replace HVAC mixing box: above ceiling, below asbestos-containing fireproofingin good condition, where there is no ACM dust or debris on the mixing box or any ofthe systems in the area of the work. The fireproofing is near to the mixing box andmay be contacted during the work.


Do not enter the space above the ceiling using this work practice unless you know thatthere is no ACM debris on top of ceiling. If you do not know if there is debris on top ofthe ceiling then use S-1 Level B procedures to open ceiling.

Coordinate work with proper O & M work practice for accessing type of ceiling presentin work area. See Work Practices S1, M2, or M4






5. Obtain access above ceiling using appropriate O & M work practice.

6. Perform maintenance work required.

7. Complete applicable steps on Level A checklist to complete work.


S4 . Level BWork in ceiling plenum space where exposedsurfacing ACM is present.


A. Replace HVAC mixing box: above ceiling, below asbestos-containing fireproofingin good condition. There is a small amount of dust or debris from surfacing ACM ispresent on top of box, that is accessible and easily removed.


The space above the ceiling is a “controlled area.” Do not enter this area, or disturbceiling tiles unless you have been authorized by facility management.

Coordinate work with proper O & M work practice for accessing type of ceiling presentin work area. See Work Practices S2, M2, or M4.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1

b. Maintenance item(s) required to perform work in plenum space.



5. Place tools, equipment and materials needed onto drop cloth


7. Pick up any bulk debris within reach on top of ceiling and place into disposal bags.

8. Remove debris from top of mixing box with HEPA vacuum. Thoroughly wet wipesurface to remove all residue of ACM.

9. HEPA vacuum top side of ceiling within reach from access area.



10. HEPA vacuum and wet-wipe surfaces that will be contacted or item to be maintainedor repaired.

11. Perform maintenance work required and clean-up and tear-down steps on Level 2checklist to complete work.


S4 . Level CWork in ceiling plenum space where exposedsurfacing ACM is present.


A. Replace HVAC mixing box above ceiling where the equipment, duct, hangers, andsurrounding conduit and piping are covered with loose ACM fireproofing overspray,debris and bounce back. Material on top of mixing box is inaccessible and cannot beremoved before box is lowered. Overspray on surrounding systems will be dislodgedif not removed before work is performed on the mixing box.

Notes

The space above the ceiling is a “controlled area.” Do not enter this area, or disturbceiling tiles unless authorized by facility management







b. Maintenance item(s) required to perform work in plenum space.




6. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuumlocated outside of this inclosure with hose and nozzle extended inside enclosure forvacuuming areas above ceiling.



7. Put on respirator and perform fit test, put on protective clothing

8. Enter enclosure and obtain access through ceiling using appropriate O&M workpractice.

9. HEPA vacuum top side of ceiling within reach from access area, and HEPA vacuumand wet-wipe item to be repaired or replaced.

10. Extend mini-enclosure above ceiling, if feasible, using polyethylene sheet andframing taped together to provide enclosure around the work area without contactingACM covered surface. Vary construction of the extended mini-enclosure dependingon the existing construction above the ceiling. Polyethylene and framing may besecured to pipes, conduit, and metal hangers if they are not covered with ACM. If anextended mini-enclosure is not feasible, mist area above ceiling and lay apolyethylene drop cloth below the area where work will occur. If drop cloth cannotbe used, suspend polyethylene below immediate work area to catch ACM that mayfall.

11. Remove accessible overspray on mixing box, duct work, hangers, conduit, etc. thatmay be disturbed by the work. Remove overspray by dampening with amendedwater and collecting with the nozzle of the HEPA vacuum where possible. Inlocations that the material cannot be collected directly with the HEPA vacuum, wetthoroughly with amended water and manually collect into an asbestos disposal bag. After bulk overspray is removed, wet newly exposed areas and use scraper and nylonbrush to remove remaining visible residual ACM. Thoroughly wet wipe surface toremove all residue of ACM. Allow surfaces to dry and spray with an asbestos lock-back encapsulant.

12. Remove sufficient materials to permit installation of new hangers. Adequately wetarea of surfacing to be removed using garden sprayer containing amended water andallow water to soak in for several minutes. Wet removal area frequently duringremoval of bulk material and residual material. Using scraper with HEPA vacuumwithin several inches of removal area, scrape off ACM to at least 3" (75 mm) beyondarea where item will be attached. When bulk material is removed, wet newlyexposed areas and use scraper and nylon brush to remove remaining visible residualACM. Place removed ACM into disposal bags. Thoroughly wet wipe exposedsurface to remove all residue of ACM.

13. Perform maintenance work required.




S5 . SummaryInstall wiring in plenum space where exposedsurfacing ACM is present

SummaryThis work practice covers situations wherewiring and/or conduit are being installedin a ceiling plenum space that has exposedsurfacing ACM. The procedures assumethat the ACM will not intentionally bedisturbed during the work.

Routinely, the installation of computer andtelephone cables is done without removingenough ceiling tile. Consequently, thecable is dragged long distances on top ofthe ceiling, rattling the ceiling. Thisvibration shakes the ceiling’s hangingsystem, and may vibrate the fireproofingoverhead. Depending upon the extent ofoverspray that is has coated the hangers,and how well it bonded, a worker canshake this oversprayed fireproofing loose,without ever touching the material, simplyby causing the ceiling to vibrate. If thesurface upon which the fireproofing issprayed is “bouncy” this vibration candisturb the fireproofing itself.

Use of these procedures is limited tosituation where the amount of wastegenerated is not greater in size than theOSHA limit on Class III work (operationwill generate no more waste than will fitinto one 60" by 60" glovebag or disposalbag.

Level A: work practices should only beused in situations where the ACM surfacematerial is in good condition and well outof reach of the work, and there is no ACMdust and/or debris on top of ceiling tiles. During design of the O&M procedure, aCompetent Person (as defined by OSHA)must make a determination that theexposed surfacing ACM is in goodcondition and that there is no dust ordebris on top of the ceiling tiles that could

cause an exposure to a worker that isabove the PEL.

Level A work practices should be usedonly in situations where access throughthe ceiling is frequent enough that thecondition of any ACM in the space isknown, and it is known that: there is nodebris on the ceiling, the fireproofing isout of reach of the work, and that thevibration of the ceiling during cableinstallation will not dislodge oversprayedfireproofing from hanger or disturb thefireproofing.. If access through the spaceis infrequent or it cannot be known withconfidence that there is no debris on top ofthe ceiling tile, or the vibration of theceiling during cable installation maydisturb overspray of fireproofing, thenLevel B procedures should be used.

Level B: work practices should be used ifthere is dust or debris from the ACMsurfacing treatment or other ACM materialon top of the ceiling tiles or if the ACMsurfacing material is close enough to thework that it could be disturbed. If there isconsiderable ACM debris on top of theceiling tiles or the ACM surfacingmaterial is near enough to the work that itis inevitably going to be disturbed andabraded by the cable installation in amanner that could release asbestos fibersor visible dust and debris into the air, thenan enclosure is needed and Level Cprocedures should be used. Limit the useof Level C work practices to outsideabatement contractors unless theseprocedures will be used on a routine basis.

Level B work practices should be usedwhere there is some debris on top of theceiling tiles, but the debris can be removed



using the procedures in this work practicewithout generating airborne asbestoslevels above the OSHA PEL, and withoutreleasing visible dust or debris frommaterial on top of the ceiling tiles. LevelB work practices should be used if accessthrough the ceiling is infrequent enoughthat it cannot be known with confidencethat there is no debris on top of the ceilingtiles

Use of this procedure is limited to asituation where the amount of wastegenerated is not greater in size than theOSHA limit on Class III work (operationwill generate no more waste than will fitinto one 60" by 60" glovebag or disposalbag.

Level C: Training as abatement workers

is more adequate for those performingLevel C work in a mini-enclosure whereexposure to elevated asbestos levels andthe need for a wet decontamination ispossible. Level C work practices shouldbe used where ACM will be disturbed bythe cable installation, there is debris on topof the ceiling tiles, and it is problematicwhether Level B procedures will be ableto prevent the generation of airborneasbestos levels above the OSHA PEL, orprevent the spread of visible debris and/ordust. Frequently, O&M programs willavoid the use of Level C work practices. If Level C work is infrequentlyencountered, it is best to limit this type ofwork to outside abatement contractorswho are accustomed to working inenvironments with elevated asbestoslevels.

ExamplesLevel A: During design of the O&M procedure, a Competent Person (as defined by OSHA) must

make a determination that the exposed surfacing ACM is in good condition and that thereis no dust or debris on top of the ceiling tiles that could cause an exposure to a workerthat is above the PEL.

A. Installing new plenum rated computer or telephone cables that will lay on top ofceiling, where the ACM surface material is in good condition and well out of reachof the work, and there is no ACM dust and/or debris on top of ceiling tiles

Level B: A. Installing new plenum rated computer or telephone cables that will lay on top ofceiling, where there is a small amount of dust or debris from ACM surfacingtreatment or other ACM material on top of the ceiling tiles or if the ACM surfacingmaterial is close enough to the work that it could be disturbed.

Level C: A. Installing new plenum rated computer or telephone cables that will lay on top ofceiling, where there is considerable ACM debris on top of the ceiling tiles or theACM surfacing material is near enough to the work that it is inevitably going to bedisturbed and abraded by the cable installation in a manner that could releaseasbestos fibers or visible dust and debris into the air.

Related Work Practices



S1 Moving one non-asbestos-containing ceiling panel below a plenum space that hasexposed surfacing ACM.

S2 Attach component to an ACM finished surface that is above a ceiling.S3 Work in ceiling plenum space where exposed surfacing ACM is present.

Worker RecommendationsOne worker for Level A and Level B. Two workers may facilitate pulling wires betweentwo locations. Two workers for Level C. A person with air monitoring training might berequired. This person can be one of the workers.


S5 . Level AInstall wiring in plenum space where exposedsurfacing ACM is present.


A. Installing new plenum rated computer or telephone cables that will lay on top ofceiling, where the ACM surface material is in good condition and well out of reachof the work, and there is no ACM dust and/or debris on top of ceiling tiles.






b. Wiring and related tools



5. Obtain access through ceiling using appropriate O & M work practice.

6. Observe top of ceiling in direction that cables are to be run. Determine conditions atthe next location where access above the ceiling is required to determine the level ofwork practice required for entry. If there is any ACM debris or dust on top of ceilingtiles use level B work procedures, and locate the next ceiling access so that all partsof the ceiling top can be cleaned.

7. Open enough ceiling tiles that the cables can be passed by hand from opening toopening.

8. Install cable(s) by passing leading end of cable(s) from opening to opening. DONOT TOSS CABLES OR ANY OTHER OBJECT ABOVE THE CEILING.

9. Run wiring as required. Do not contact exposed ACM surfacing and minimizedisturbance of ceiling system and other components above ceiling while runningwiring.



S5 . Level BInstall wiring in plenum space where exposedsurfacing ACM is present.


A. Installing new plenum rated computer or telephone cables that will lay on top ofceiling, where there is a small amount of dust or debris from ACM surfacingtreatment or other ACM material on top of the ceiling tiles or if the ACM surfacingmaterial is close enough to the work that it could be disturbed.


The space above the ceiling is a “controlled area.” Do not enter this area, or disturbceiling tiles unless you have been authorized by facility management.







4. Prepare work area with drop cloth. See General Procedure W10 “PolyethyleneDrop Cloth” Set up multiple work areas if needed.

5. Install a continuous drop cloth under area where cabling is to be run. Securecontinuous drop cloth in place to minimize slipping hazards.

6. Install a second drop cloth at each ceiling opening on top of the continuous dropcloth. Secure drop cloths in place to minimize slipping hazards.


8. Obtain access through ceiling using appropriate O & M work practice.

9. HEPA vacuum top side of ceiling within reach from access area.

10. Observe top of ceiling in direction that cables are to be run. Determine conditions atthe next location where access above the ceiling is required to determine the level ofwork practice required for entry. If there is any ACM debris or dust on top of ceilingtiles use level B work procedures, and locate the next ceiling access so that all partsof the ceiling top can be cleaned.



11. Remove any ACM debris in the path to be followed by cables. If there is any ACMdebris remove with a HEPA vacuum. Spray a lock back encapsulant on ceiling tiletops wherever debris is removed.

12. Open enough ceiling tiles that the cables can be passed by hand from opening toopening.

13. Install cable(s) by passing leading end of cable(s) from opening to opening. DONOT TOSS CABLES OR ANY OTHER OBJECT ABOVE THE CEILING.

14. Run wiring as required by passing the cable from opening to opening. Do not dragcable across ceiling. Do not drag cables from floor up into ceiling plenum. Do notcontact exposed ACM surfacing above ceiling. Minimize disturbance of ceilingsystem and other components above ceiling while running wiring.



S5 . Level CInstall wiring in plenum space where exposedsurfacing ACM is present.


A. Installing new plenum rated computer or telephone cables that will lay on top ofceiling, where there is considerable ACM debris on top of the ceiling tiles or theACM surfacing material is near enough to the work that it is inevitably going to bedisturbed and abraded by the cable installation in a manner that could releaseasbestos fibers or visible dust and debris into the air.

Notes

The space above the ceiling is a “controlled area.” Do not enter this area, or disturbceiling tiles unless authorized by facility management



Coordinate this work with proper O & M work practice for accessing type of ceilingpresent in work area. See Work Practices S1, M2, or M4.







5. Erect mini-enclosure and set up negative pressure system and/or HEPA filtered localexhaust ventilation according to General Procedure W20 “Mini-Enclosure.” Set upmultiple enclosures if needed.



6. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuumoutside of the enclosure with the hose and nozzle extending inside enclosure forvacuuming areas above ceiling.

7. Enter enclosure and obtain access through ceiling using appropriate O & M workpractice.

8. HEPA vacuum top side of ceiling within reach from access hole.

9. Observe top of ceiling in direction that cables are to be run. Determine conditions atthe next location where access above the ceiling is required to determine the level ofwork practice required for entry. If there is any ACM debris or dust on top of ceilingtiles use level B work procedures as a minimum. If the ACM fireproofing is likely tobe disturbed during cable installation then use Level C procedures. Locate the nextceiling access so that and disturbance of ACM fireproofing occurs in a mini-enclosure and so that all parts of the ceiling top can be cleaned.

10. Prior to installation of cable past ACM: Mist any fireproofing that is to be disturbedwith amended water, and install a drop cloth at ceiling level to catch debris fromfireproofing. During cable installation hold the HEPA vacuum nozzle under thepoint of disturbance, if possible. Wet wipe cable after it is run past ACM. Runcomplete length of cable needed and coil on other side of ACM. Saturate any debrison drop cloth with amended water and mist the air between the ACM and the dropcloth. Fold drop cloth with debris inside and place in an asbestos disposal bag. Clean up any other debris and place in an asbestos disposal bag.

11. Remove any ACM debris in the path to be followed by cables. If there is any ACMdebris remove with a HEPA vacuum. Spray a lock back encapsulant on ceiling tiletops wherever debris is removed.



S6 . SummaryAttach item to ceiling finished with ACM

SummaryThis work practice describes the workrequired to attach an item to a ceilingfinished with surfacing ACM, such asacoustical plaster or a decorative sprayed-on surface texture material.

When selecting work practices for asurfacing material it may be necessary todistinguish between situations where thematerial is in its original condition andthose where it has been encapsulated orcoated with layers of paint. Different

work practices may be necessary for eachsituation. This should be clearly describedin each work practice.

Use of this procedure is limited tosituation where the amount of wastegenerated is not greater in size than theOSHA limit on Class III work (operationwill generate no more waste than will fitinto one 60" by 60" glovebag or disposalbag.

Examples

Level A: A. Mount a “rosettes” with bedding adhesive to the surface of a suspended acousticalplaster ceiling. Attach device to “rosettes.”

Level B: OSHA requires that during Class III (O&M) operations that involve, “drilling, cutting,abrading, sanding, chipping, breaking, or sawing of thermal system insulation orsurfacing materials, the employer shall use impermeable dropcloths, and shall isolate theoperation using mini-enclosures or glove bag systems ...or another isolation method.” This work practice relies on the HEPA exhausted collar on the drill as, “another isolationmethod.” During design of the O&M program the designer must be a competent personand must determine that the use of the HEPA exhausted collar as described in the workpractice effectively isolates the drilling work. This evaluation should be based on an,“Initial exposure assessment,” leading to a “Negative Exposure Assessment,” (NEA) asdescribed in the OSHA construction standard 29 CFR 1926.1101(f)(2). Duringimplementation of the program, the APM must also be a competent person, and mustmake a determination that conditions at a specific job site are equivalent to those existingduring development of the work practice, so that the work practice is applicable. Thework order issued to the person performing the work should inform them of the NEA andany conditions that are attached to the NEA. It is possible that after there has been someexperience with the OSHA regulation the manufacturers of the type of equipment used inthis work practice will make the proper evaluations and submissions to OSHA andprovide a copy of this to the O&M program designer. In any case as a minimumrequirement the supervisor that assigns work to maintenance staff should be a competentperson able to evaluate the applicability of a dust collection collar with HEPA vacuum toa particular situation.

A. Attach a battery-powered smoke detector to a suspended acoustical plaster ceilingwith two toggle bolts.



B. Attach track lighting to an ACM finished ceiling where experience has proven aminimal disturbance will occur.

Level C: A. Remove a small amount of acoustical plaster using a glove box or frame mountedglovebag, to permit the installation of a junction box.

B. Install smoke detector in suspended acoustical plaster ceiling by cutting a 2" X 4"hole and installing a junction box.

C. Attach track lighting system to ACM finished ceiling.D. Install exposed conduit, junction boxes and light fixtures to ACM finished ceiling.E. Attach new folding door to acoustical plaster where structural modifications are not

needed for support.

Related Work PracticesS1 Move one non-asbestos-containing ceiling panel below a plenum space that has

exposed surfacing ACM.S2 Attach component to an ACM finished surface that is above a ceiling.S8 Cut or drill hole in Surfacing ACM.S9 Replace bulbs in light fixture attached to or in surface finished with ACM.

Worker RecommendationsOne worker for Level B Two workers for Level C More workers may be needed forcertain Level C tasks. A person with air monitoring training might be required. Thisperson can be one of the workers.


S6 . Level AAttach item to ceiling finished with ACM


A. Mount a “rosettes” with bedding adhesive to the surface of an acoustical plasterceiling. Attach device to “rosettes.”







5. Put bedding adhesive on bottom of rosette and press against ceiling.



S6 . Level BAttach item to ceiling finished with ACM


A. Attach a battery-powered smoke detector to a suspended acoustical plaster ceilingwith two toggle bolts.

B. Attach track lighting to an ACM finished surface where experience has proven aminimal disturbance will occur.


A Negative Exposure Assessment must have been made by a Competent Person beforethis work practice is used. If a negative exposure assessment (NEA) has not been made,stop work and notify your supervisor.




b. Item to be attached to ceiling and related tools




6. Wet area on ceiling where item will be attached using garden sprayer with amendedwater.

7. Drill holes through ceiling with one of the following procedures:

a. Drill hole with drill equipped with dust collection collar attached to a HEPAvacuum. Maintain HEPA vacuum in operation during entire process of drillingholes.

b. Using hand tools and HEPA vacuum near attachment location, or power toolswith attached HEPA vacuum, attach item to ceiling. If small holes are beingdrilled, drill through a wet sponge or shaving cream to control fiber release.

c. Scrape away surfacing to at least ½" [13 mm] beyond where hole is needed. Keep the hose of an operating HEPA vacuum within 6" [150mm] and below areawhere scraping is occurring. Adequately wet scraping area and any dust ordebris generated. Drill hole through substrate after ACM is removed.

8. Immediately place all debris into ACM disposal bags.



9. Spray holes with a clear penetrating encapsulant to stabilize disturbed edges.



S6 . Level CAttach item to ceiling finished with ACM


A. Remove a small amount of acoustical plaster using a glove box or frame mountedglovebag, to permit the installation of a junction box.

B. Install smoke detector in suspended acoustical plaster ceiling by cutting a 2" X 4"hole and installing a junction box.

C. Attach track lighting system to ACM finished ceiling.D. Install exposed conduit, junction boxes and light fixtures to ACM finished ceiling.E. Attach new folding door to acoustical plaster where structural modifications are not

needed for support.

Notes The ceiling is a “controlled system.” Do not contact or disturb ceiling unless authorizedby facility management

Do not use power tools inside glovebags.



Work Practice (Frame supported Glovebag)1. Perform Pre-work activities on Level C checklist.




c. Glovebags

d. Frame to support glovebag or glove box



5. Set-up frame supported glovebag using Worker General Procedure W18 “GlovebagRemoval.” Place tools, equipment and materials needed into glovebag.

6. Thoroughly wet material to be removed with amended water.



7. Using a small scraper remove acoustical plaster from scratch coat to a point ½" backfrom opening required for junction box.

8. After acoustical plaster is removed wet surface of scratch coat and remove all residuewith a stiff nylon brush. After all visible residue has been removed, remove 1/16"from surface of scratch coat

9. Spray scratch coat and edges of acoustical plaster with clear penetrating encapsulant.

10. Perform clean-up and tear-down steps on Level C checklist, leave drop cloth in place.

11. Mark location for junction box installation. Drill starter holes in opposite corners.

12. Cut through scratch coat and wire lath between starter holes with pneumatic shear, orheavy tin snips. Keep scratch coat dampened with amended water during cutting.

13. Install old-work junction box.

14. Dispose of all non-asbestos waste as normal construction debris, do not place inasbestos disposal bag.

15. Clean any debris from drop cloth. Fold drop cloth toward center and dispose of asnormal construction debris, do not place in asbestos disposal bag.



Work Practice (mini-enclosure)1. Perform Pre-work activities on Level C checklist.







6. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuumoutside enclosure with hose and nozzle extending inside enclosure for vacuumingareas above ceiling.

7. Enter enclosure and wet area on ceiling where item will be attached using gardensprayer with amended water. Allow amended water to sink in. Add additional wateruntil area to be removed is saturated.

8. Using a small scraper remove acoustical plaster from scratch coat to a point ½" backfrom opening required for junction box. Hold a pan immediately under area to catchdebris while scraping.

9. After acoustical plaster is removed wet surface of scratch coat and remove all residuewith a stiff nylon brush. After all visible residue has been removed, remove 1/16"from surface of scratch coat

10. Spray scratch coat and edges of acoustical plaster with clear penetrating encapsulant.

11. Mark location for junction box installation. Drill starter holes in opposite cornerswith drill equipped with dust collection collar attached to an operating HEPAvacuum.

12. Cut through scratch coat and wire lath between starter holes with pneumatic shear, orheavy tin snips. Keep scratch coat dampened with amended water during cutting.

13. Install old-work junction box.

14. Immediately put all asbestos and non-asbestos waste and debris in an asbestosdisposal bag.



S7 . SummaryRepair or replace item in surface finished withACM

SummaryThis work practice covers the procedures for repairing or replacing an item that isinstalled in or attached to a surface finished with ACM, such as an acoustical plasterceiling or fireproofed deck or beam.

ExamplesLevel A: This example pre-supposes that the construction of the light fixture permits the diffuser to

be removed without touching or disturbing the ceiling. Workers performing this taskshould at a minimum have awareness training so that they are informed of the asbestos-containing ceiling, and know to avoid disturbing it. During design of the O&Mprocedure, the designer ( who must be a Competent Person as defined by OSHA) mustmake a determination that the surfacing ACM is in good condition and that it will not bedisturbed by the work.

A. Replace diffuser that is completely surrounded by the metal frame of a light fixturerecessed in a ceiling finished with ACM acoustical plaster, where the diffuser can beremoved without any disturbance of ACM.

Level B: This example pre-supposes that the light fixture is constructed so that is clamped in ahole in the ceiling and can be removed by taking out a few screws and sliding the entireunit out. Workers performing this task should at a minimum have O&M training andsufficient electrical knowledge to be able to disconnect the light fixture.

A. Removal of a light fixture that is recessed in a ceiling finished with ACM acousticalplaster, where the light fixture has an escutcheon so that it can be unfastened anddropped out.

Level C: This example pre-supposes that the light fixture is constructed so it is an integral part ofthe ceiling construction and has to be cut out of the ceiling. The mini-enclosure in thisinstance is a miniature asbestos abatement work area. Workers performing this taskshould at a minimum have O&M training and preferably abatement worker training. Thissort of work is better left to an outside abatement contractor unless facility personnelroutinely perform abatement work.

A. Removal of a light fixture that is recessed in a ceiling finished with ACM acousticalplaster, where the fixture frame is integral with the ceiling and plaster must beremoved and cut to free the fixture.



Related Work Practices S1 Moving one non-asbestos-containing ceiling panel below a plenum space that has

exposed surfacing ACM.S5 Attach item to ceiling finished with ACM.S8 Cut or drill hole in Surfacing ACM.S9 Replace bulbs in light fixture attached to or in surface finished with ACM.S11 Repair damaged surfacing ACM.

Worker RecommendationsOne worker is usually sufficient for Level A and Level B. Two workers for Level C. More workers may be needed to increase efficiency or for additional health and/or safetyconsiderations. A person with air monitoring training might be required. This personcan be a worker.


S7 . Level ARepair or replace item in surface finished withACM


A. Replace diffuser that is completely surrounded by the metal frame of a light fixturerecessed in a ceiling finished with ACM acoustical plaster, where the diffuser can beremoved without any disturbance of ACM.

NotesThe ceiling is a “controlled system.” Do not contact or disturb ceiling unless authorizedby facility management




b. Repair and/or replacement parts and tools as needed.



5. Carefully open diffuser without touching the ACM acoustical plaster ceiling. Unhook diffuser from light fixture and remove. Do not touch ACM or rattle lightfixture.



S7 . Level BRepair or replace item in surface finished withACM


A. Removal of a light fixture that is recessed in a ceiling finished with ACM acousticalplaster, where the light fixture has an escutcheon so that it can be unfastened anddropped out.


The ceiling is a “controlled system.” Do not contact or disturb ceiling unless you havebeen authorized by facility management.




b. Repair and/or replacement parts and tools as needed



5. Place tools, equipment and materials needed in work area or on drop cloth.

6. Lightly mist area of ACM acoustical plaster around frame of light fixture usinggarden sprayer containing amended distilled water and allow water to soak in forseveral minutes.

7. Completely remove screws holding light fixture in place, while holding fixture sothat it does not move.

8. Gradually lower one side of fixture while removing any loose ceiling material with aHEPA vacuum. Lower other side while continuing with HEPA vacuum. Use HEPAvacuum to remove any ceiling material as fixture is lowered from the ceiling. Disconnect wire from fixture and coil above ceiling so that it does not contact theacoustical plaster.



9. HEPA vacuum and then wet wipe all surfaces of light fixture.

10. Collect any surfacing debris from repair/replacement work using HEPA vacuum.



S7 . Level CRepair or replace item in surface finished withACM


A. Removal of a light fixture that is recessed in a ceiling finished with ACM acousticalplaster, where the fixture frame is integral with the ceiling and plaster must beremoved and cut to free the fixture.







b. Repair and/or replacement parts and tools as needed




6. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuumoutside of enclosure with hose and nozzle extending inside enclosure for use duringthe work.

7. Enter enclosure and wet area of surfacing within 6" [150 mm] of light fixture usinggarden sprayer containing amended water and allow water to soak in for severalminutes. Apply additional water as necessary until acoustical plaster is saturated inarea adjacent to light fixture.

8. Using a small scraper, carefully remove wetted ACM acoustical finish down toscratch coat for 2" on all sides of light fixture. Hold a pan immediately under


scraping area to catch debris. At frequent intervals place ACM debris in asbestosdisposal bag and spray with amended water.

9. After all acoustical plaster is removed, wet scratch coat and remove any residue witha stiff nylon brush. Hold pan under brushing area to catch any debris. After allvisible residue is removed, wet surface and scrape off 1/16" of scratch coat into pan. Frequently empty pan into asbestos disposal bag.

10. Drill a starter hole at each corner of fixture using a drill equipped with a dustcollection collar attached to an operating HEPA vacuum.

11. Use a pneumatic shear or large tin snips to cut through scratch coat and wire lath onall sides of light fixture.

12. Drop down light fixture, disconnect electrical and coil above ceiling. Wrap cutedged on light fixture with duct tape. Double bag in asbestos disposal bag anddispose of as asbestos waste.

13. Collect any surfacing debris from repair/replacement work using HEPA vacuum.



S8 . SummaryCut or drill hole in surfacing ACM

SummaryThis work practice covers the work required to cut or drill a hole through surfacingACM, such as acoustical plaster or fireproofing. If possible, ACM should be removedbefore holes are drilled. If holes are drilled in an ACM wall surface with a cavity behindthe wall, labels or record keeping information should note that ACM might be present inthe cavity.

Examples

Level B: A. Drill a hole through asbestos-containing decorative texture finish.

Level C: A. Drill or cut hole for pipe or duct chase using tools with or without HEPA filtereddust collection in an enclosure.

B. Install few new conduits through fireproofed metal deck.

Related Work Practices S1 Move one non-asbestos-containing ceiling panel below a plenum space that has exposed

surfacing ACM.S2 Attach component to an ACM finished surface that is above a ceiling.S6 Attach item to ceiling finished with ACM.S7 Repair or replace item in surface finished with ACM.

Worker RecommendationsOne worker is usually sufficient for Level B. Two workers for Level C. More workersmay be needed to increase efficiency or for additional health and/or safety considerations. A person with air monitoring training might be required. This person can be a worker.


S8 . Level BCut or drill hole in surfacing ACM


A. Drill a hole through a substrate after removing an asbestos-containing decorativetexture finish.






b. Scraper (if used)



5. Place tools, equipment and materials needed onto drop cloth. If access above ceilingis required, obtain access using appropriate O & M work practice.

6. Install polyethylene sheet below location of work to catch any falling debris.

7. Drill a hole through a substrate after removing an asbestos-containing decorativetexture finish using the following procedures:

a. Adequately wet area where hole is to be drilled. Wet sufficiently so that ACM iswetted completely. Allow amended water to soak into material so that ACM iswetted through to substrate in spot where ACM it to be removed.

i. If the surface is coated with paint, mist surface and scarify paint sufficientlyfor ACM to be wetted. Remove paint by peeling or scraping off asnecessary. Wet surface of exposed ACM. Allow amended water to soak intomaterial so that ACM is wetted through to substrate in spot where ACM it tobe removed.

b. Remove ACM surfacing material using one of the following procedures.

i. Scrape away surfacing material to at least ½" [13 mm] beyond where hole isneeded. Hold a pan immediately under area to catch debris while scraping. If any dry ACM is encountered stop scraping and wet ACM. Maintainscraping area and any dust or debris generated wet at all times.



ii. Scrape away surfacing material to at least ½" [13 mm] beyond where hole isneeded. Scrape material directly into the nozzle of an operating HEPAvacuum or use nozzle of HEPA vacuum directly as tool to remove ACM. Continuously maintain HEPA vacuum nozzle within 6" [150mm] of wherework is occurring. If any dry ACM is encountered stop scraping and wetACM. Maintain scraping area and any dust or debris generated wet at alltimes.

c. After acoustical plaster is removed wet surface of substrate and remove allresidue with a stiff nylon brush. Remove water and residue from surface withpaper towels. Immediately dispose of towels in an asbestos waste bag. Repeatbrushing and paper towel process three (3) times. If substrate is a scratch coat,wet substrate and scrape off 1/16" of scratch coat to remove any residual ACMthat may be trapped in the texture of the scratch coat.

d. Spray substrate and edges of acoustical plaster with clear penetratingencapsulant.

e. Drill hole through substrate after ACM is removed.

f. If hole is being drilled through a surface, such as acoustical plaster, where backside is inaccessible, place HEPA vacuum hose near or through hole and run forseveral minutes to clean air on backside of surface.

8. If hole is being drilled through a surface, such as a suspended ceiling, where backside is inaccessible, place HEPA vacuum hose near or through hole and run forseveral minutes to collect any airborne dust air on backside of surface.

9. If hole is drilled from top side of deck, adequately wet ACM on underside and installpolyethylene sheet or enclosure below ACM on underside that will catch any fallingdebris, including material from hole (such as a concrete cylinder). Drill hole throughsurface. Adequately wet drilling area while drilling. Wet any debris on drop cloth orin enclosure on underside, package up debris and drop cloth/enclosure and dispose ofas ACM.



S8 . Level CCut or drill hole in surfacing ACM


A. Drill or cut hole for pipe or duct chase using tools with or without HEPA filtered dustcollection in an enclosure.

B. Install a few new conduits through fireproofed metal deck.







b. Scraper

c. Hand or power drill or saw with HEPA vacuum attachment.




6. Place tools, equipment and materials needed into enclosure. Include a HEPAvacuum inside enclosure for use during the work. IF access above a ceiling isrequired, obtain access using the appropriate O & M work practice. If surface to bedrilled is above a ceiling, extend enclosure (if feasible) to within approximately ½"[13 mm] of surfacing ACM.



Cut Hole through a Wall1. Inside of mini-enclosure, install polyethylene sheet below removal location to catch

any falling debris.2. Adequately wet area where hole is to be cut.3. Remove ACM from entire area of hole and to at least ½" [13 mm] beyond where hole

is needed. Keep the hose of an operating HEPA vacuum within 6" [150 mm] ofwhere scraping is occurring. Adequately wet, any dust or debris generated. Cut holethrough scraped area after ACM is removed.

4. Drill small holes using a drill with dust collection collar attached to a HEPA vacuum. Maintain HEPA vacuum in operation during entire process of drilling holes.

Core Drill Through Deck:1. Install mini-enclosure on top of deck. Set up core drill inside mini-enclosure

2. Install drop cloth and local enclosure (such as a frame supported glove-bag) onunderside of deck.

3. Arrange pan to support local enclosure, use pan large enough to contain falling waterand debris if sheet plastic of local enclosure tears. Support pan to accommodateweight of water and debris including concrete cylinder cored out of deck.

4. Wet ACM on underside of deck with amended water.

5. Core drill hole through Deck. Wet drilling area during operation so that site ofdrilling is continuously wet.

6. After hole is complete, remove core drill and wash down hole to remove any residueof fireproofing.

7. Fill enclosure with sufficient absorbent to soak up any loose water.

8. Fold up local enclosure with debris and place in asbestos disposal bag.

9. Wet wipe interior of pan.

10. If hole is drilled from underside of deck, install mini-enclosure below deck, andinstall local enclosure on floor above.

Clean-up and Teardown:1. Let HEPA vacuum run for at least 15 minutes to clean air in enclosure.

2. Perform maintenance work and clean-up and tear-down steps on Level C checklist tocomplete work.

S - 65 # Surfacing ACM # Asbestos O&M Work Practices # © NIBS 1996 # Page - 141

S9 . SummaryReplace bulbs in light fixture attached to or insurface finished with ACM

SummaryThis work practice covers procedures forreplacing light bulbs in a fixture attachedto a surface finished with ACM. Lightfixtures attached to or in surfaces finishedwith ACM can cause damage to ACM ifthe fixtures are moved during maintenancework. In instances where the ACM willbe neither contacted or disturbed a workpractice level is not assigned, butsufficient control must be exercised toinsure that the material is not inadvertentlydisturbed. This can be accomplished bydesignating the ACM surfacing material asa "Controlled System" which may becontacted only by authorized personnel. Awareness training is required for workerswho could contact the material. OSHA(29 CFR 1926.11-1(k)(8)(vii)) (Clarifiedby the Compliance Directive CPL 2-2.63page C-36) requires that the ACM orPACM be labeled. A practical way ofdoing this that will insure that workers seethe warning is to put a label at each latchpoint for the light fixture.

When selecting work practices for asurfacing material it may be necessary todistinguish between situations where thematerial is in its original condition andthose where it has been encapsulated orcoated with layers of paint. Differentwork practices may be necessary for eachsituation. This should be clearly describedin each work practice.

Level A: The work is Level A, if thematerial is going to be contacted duringthe work, but not disturbed. The OSHAregulation (29 CFR 1926.1101) requiresthat this determination be made by acompetent person. Refer to Appendix I formore information on the OSHAregulation.

Level B: Some acoustic materials arevery fragile so that a small amount ofdebris may be released due to contact, orthere may be ACM debris inside or on topof a light fixture. Replacing bulbs intheses situations is Level B work.

Examples

Level A: A. Replace bulbs in recessed or pendant mount light fixtures attached to an asbestos-containing decorative texture finish or acoustical plaster ceiling where the materialmay be contacted, but it is unlikely that any debris will be released.

B. Replace bulbs in fixtures mounted on fireproofed surface where the material may becontacted, but it is unlikely that any material will be released.

Level B: This work practice is appropriate for situations where the surfacing treatments may bedisturbed during re-lamping knocking off a small amount of debris, or will be contactedand is so fragile that the contact may knock off a small amount of debris. If the release ofdebris is unlikely, then Level A procedure could be used. The ceiling should bedesignated as a "controlled system" that is to be contacted only by those with at aminimum awareness training.



A. Replace bulbs in light fixtures recessed in an asbestos-containing decorative texturefinish or acoustical plaster ceiling where the material is likely to be contacted andrelease of a small amount of debris is likely.

B. Replace bulbs in recessed fixtures where ACM surfacing material debris is visibleinside fixture.

C. Replace bulbs in pendant mount fixture where ACM debris is present inside or on topof fixture.

Related Work PracticesS5 Attach item to ceiling finished with ACM.S11 Repair damaged surfacing ACM.

Worker RecommendationsOne worker is usually sufficient. Two or more workers may be needed to increaseefficiency or for additional health and/or safety considerations. A person with airmonitoring training might be required. This person can be a worker.


S9 . Level AReplace bulbs in light fixture attached to or insurface finished with ACM


A. Replace bulbs in recessed or pendant mount light fixtures attached to an asbestos-containing decorative texture finish or acoustical plaster ceiling where the materialmay be contacted, but it is unlikely that any debris will be released.

B. Replace bulbs in fixtures mounted on fireproofed surface where the material may becontacted, but it is unlikely that any material will be released.






b. Replacement bulbs



5. Carefully replace light bulbs without jarring fixture or releasing debris. Clean-up anydust or debris generated using HEPA vacuum. Use Work Practice M22 if HEPAvacuum needs maintenance, or if bag or filter needs to be replaced.



S9 . Level BReplace bulbs in light fixture attached to or insurface finished with ACM


A. Replace bulbs in light fixtures recessed in an asbestos-containing decorative texturefinish or acoustical plaster ceiling where the material is likely to be contacted andrelease of a small amount of debris is likely.

B. Replace bulbs in fixtures mounted on fireproofed surface where the material is likelyto be contacted and release of a small amount of debris is likely.






b. Replacement bulbs




6. Put on respirator and perform fit check.

7. Carefully replace light bulbs without jarring fixture. Clean-up any dust or debrisgenerated using HEPA vacuum. Use Work Practice M22 if HEPA vacuum needsmaintenance, or if bag or filter needs to be replaced



S10 . SummaryClean room with exposed surfaces finishedwith ACM

SummaryThis work practice covers the proceduresfor cleaning a room with exposed surfacesfinished with ACM. This room has beenpredetermined to not be contaminated orhas previously been cleaned. However,debris could be released from the materialby contact with occupants during normaloccupation of the space. This workpractice is intended to collect any debristhat may have been released before it canaccumulate. This is not the procedure touse if a fiber release has occurred. Seerelated work practices below.


Examples

Level A A. Routine cleaning in room with spray-applied acoustical plaster on walls or ceilingswhere there is no visible dust or debris.

B. Routine cleaning in mechanical room with exposed fireproofing in good conditionwhere there is no visible dust or debris.

Related Work PracticesS11 - Repair damaged surfacing ACM.T6 - Repair damaged thermal system insulation on a pipe.R7 - Clean resilient asbestos flooring.M20 - Clean up debris from minor fiber release.

Worker RecommendationsOne worker.


S10 . Level AClean room with exposed surfaces finishedwith ACM


A. Routine cleaning in room with spray applied acoustical plaster on walls or ceilingswhere there is no visible debris.

B. Routine cleaning in mechanical room with exposed fireproofing in good conditionwhere there is no visible debris.

NotesIf any debris from ACM is found in an area to be cleaned, notify the APM or yoursupervisor. The APM will need to determine whether this work practice is appropriate orif more stringent practices are needed.

Work Practice1. Tools, equipment and materials:

a. Standard cleaning equipment and materials

2. Clean area using standard cleaning methods. Avoid contact with any ACM materialsthat could be damaged during cleaning.

3. Do not clean up asbestos debris. If asbestos debris is found in a space , stop cleaningwork in that space and notify your supervisor.

4. The following precautions should be observed when working around the ACM:

a. Do not bump ACM with vacuum cleaners, broom handles, mop handles orsimilar objects. Do not exhaust vacuum cleaners toward ACM.

b. Do not brush ACM surfaces with a broom or similar objects to remove cobwebsor other items attached to ACM.


S11 . SummaryRepair damaged surfacing ACM

SummaryThis work practice covers the proceduresfor repairing small amounts of damagedsurfacing ACM, such as acoustical plasteror fireproofing. The procedure assumesthat the damage is in isolated areas notgreater in size than the OSHA limit onClass III work (operation will generate no

more waste than can be contained in one60" by 60" glovebag or disposal bag). It isstandard industry practice not to fill thesebags more than one-third full, to allow forproper sealing and to guard againstbreakage.

Examples

Level A: A. Repair small hole in acoustical plaster ceiling or wall without disturbing surroundingplaster.

B. Repair small gouged area in asbestos-containing decorative texture finish withoutdisturbing surrounding finish.

Level B: A. Repair gouge marks in acoustical plaster ceiling where a small amount of damagedACM is present.

B. Repair small area of delaminated acoustical plaster in good condition.

Level C: A. Install fire rated enclosure over small area of damaged fireproofing.B. Trowel-on fireproofing to repair small water damaged area.C. Repair a small area of delaminated plaster in fair condition.

Related Work PracticesS2 - Attach component to an ACM finished surface that is above a ceiling.S6 - Attach item to ceiling finished with ACM.

Worker RecommendationsOne worker is usually sufficient for Level A and Level B. Two workers for Level C. More workers may be needed to increase efficiency or for additional health and/or safetyconsiderations. A person with air monitoring training might be required. This personcan be a worker.


S11 . Level ARepair damaged surfacing ACM


A. Repair small hole in acoustical plaster ceiling or wall without disturbing surroundingplaster.

B. Repair small gouged area in asbestos-containing decorative texture finish withoutdisturbing surrounding finish.






b. Non-ACM caulking materials & tools



5. Repair damaged area using non-ACM caulking without disturbing ACM. Do notscrape or sand existing ceiling.



S11 . Level BRepair damaged surfacing ACM


A. Repair gouge marks in acoustical plaster ceiling where a small amount of damagedACM is present.

B. Repair small area of delaminated acoustical plaster in good condition.






b. Small stiff-bladed scraper

c. Non-ACM repair materials & tools




6. Mist any damaged surfacing using garden sprayer containing amended water andallow water to soak in for several minutes.

7. With HEPA vacuum within several inches of damaged area, remove any loosematerial by hand or with scraper. Collect material in disposal bags as it is removed. Remove material around edges of damaged area until well-adhered material is found,but do not remove beyond area protected by drop cloth. Mist removal area duringremoval of damaged material.

8. Repair damaged area using non-ACM and perform clean-up and tear-down steps onLevel B checklist to complete work.


S11 . Level CRepair damaged surfacing ACM


A. Install fire rated enclosure over small area of damaged fireproofing.B. Trowel-on fireproofing to repair small water damaged area.C. Repair a small area of delaminated plaster in fair condition.

Notes The ceiling is a “controlled system.” Do not contact or disturb ceiling unless authorizedby facility management.







c. Non-ACM repair materials & tools




6. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuumoutside of the enclosure with hose and nozzle extending inside enclosure for useduring repair work. If access above ceiling is required, obtain access usingappropriate O&M work practice.

7. Adequately wet area of damaged surfacing using garden sprayer containing amendedwater and allow water to soak in for several minutes.



8. With HEPA vacuum within several inches of damaged area, remove any loosematerial by hand or with scraper. Collect material in disposal bags as it is removed. Remove material around edges of damaged area until well-adhered material is found,but do not remove beyond area protected inside enclosure. Mist removal area duringremoval of damaged material.

9. Repair damaged area using non-ACM materials.



S12 . SummaryAccessing through an ACM finished surface

SummaryThis work practice covers the proceduresfor opening access doors (such as thoseused in a wall or ceiling to access valvesor dampers) in ACM finished surfacessuch as acoustical plaster or fireproofing.


Level A work practices should only beused in situations where the ACM surfacematerial is in good condition and will becontacted but not disturbed by the work. During design of the O&M procedure, aCompetent Person (as defined by OSHA)must make a determination that theexposed surfacing ACM is in goodcondition and that contact with thematerial without disturbance will notcause an exposure to a worker that isabove the PEL.

Level B should be used for work that canbe accomplished without generatingairborne fiber levels in the breathing zoneof workers that are above the PEL, andwithout spreading visible dust and debrisfrom the ACM.

Level C work practices should be usedwhere airborne fiber levels may exceedthe PEL, or ACM dust and debris may bespread. In general, developing asbestoscontrol procedures used during the workto the extent that Level B controls canreliably control airborne fiber levels andthe spread of ACM dust and debris willresult in a safer and more economicalO&M program. The procedure assumesthat the damage is in isolated areas notgreater in size than the OSHA limit onClass III work (operation will generate nomore waste than will fit into one 60" by60" glovebag or disposal bag. Limit theuse of Level C work practices to outsideabatement contractors unless theseprocedures will be used on a routine basis.

ExamplesLevel A: Level A work practices should be used only in situations where the access door can be

opened without disturbing the ACM. During design of the O&M procedure, a CompetentPerson (as defined by OSHA) must make a determination that the ACM will not bedisturbed and that there will be no exposure to a worker that is above the PEL.

A. Open access door in acoustical plaster ceiling that has been opened before. Ceilingor wall is in good condition and debris is not likely on door.

Level B: These procedure use amended water to wet the surface. Some surfaces can be stained byeven a small amount of water. An inconspicuous part of the surfacing material should betested for staining and the work practice adjusted as required to avoid defacingarchitectural finishes.



A. Open access door in acoustical plaster ceiling where ACM is in fair condition andmay be disturbed.

B. Open access door that has surfacing material on flanges that will be disturbed whendoor is opened.

Level C: A. Open access door in acoustical plaster or fireproofed surface where ACM is in poorcondition or a significant amount of ACM debris may be present on back side ofdoor.

Related Work PracticesS6 Attach item to ceiling finished with ACM.S7 Repair or replace item in surface finished with ACM.S8 Cut or drill hole in Surfacing ACM.

Worker Recommendations One worker for Level A work. One or two workers for Level B depending upon safetyand efficiency considerations. Two workers for Level C. A person with air monitoringtraining might be required. This person can be a worker.


S12 . Level AAccessing through an ACM finished surface


A. Open access door in acoustical plaster ceiling or wall that has been opened before. Ceiling or wall is in good condition and access door can be opened withoutdisturbing ACM.









6. Unlatch door and open carefully. Avoid contact with ACM, be careful not to disturbACM during process of opening access door.

7. Perform maintenance work required above or behind access door and slowly closedoor until it is secured in place.

8. Complete applicable steps on Level A checklist to complete work.


S12 . Level BAccessing through an ACM finished surface


A. Open access door in acoustical plaster ceiling where ACM is in fair condition andmay be disturbed.






b. Sponge





7. Unlatch door and open door 1/4" to ½" [6mm to 13mm]. HEPA vacuum aroundedges of door. Slowly open door and HEPA vacuum any debris on door or any ACMdisturbed while opening door.

8. Perform maintenance work required above or behind access door and then slowlyclose door until it is secured in place.



S12 . Level CAccessing through an ACM finished surface


A. Open access door that has surfacing material on flanges that will be disturbed whendoor is opened.

B. Open access door in acoustical plaster or fireproofed surface where ACM is in poorcondition or ACM debris may be present on back side of door.











6. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuumoutside of enclosure with hose and nozzle extending inside enclosure for vacuumingareas above ceiling.

7. Enter enclosure and remove any ACM surfacing material that may be disturbed whenthe access door is opened. Remove enough material so that future use of the accessdoor will not involve a disturbance of ACM.

8. Wet any ACM on access door flanges that may be disturbed when door is opened. Wet sufficiently so that ACM is wetted completely. Allow amended water to soak



into material so that ACM is wetted through to substrate in spot where ACM it to beremoved.

9. If the surface is coated with paint, mist surface and scarify paint sufficiently for ACMto be wetted. Remove paint by peeling or scraping off as necessary. Wet surface ofexposed ACM. Allow amended water to soak into material so that ACM is wettedthrough to substrate in spot where ACM it to be removed.

10. Remove ACM surfacing material using one of the following procedures.

a. Scrape away surfacing material that will disturbed when access door is opened. Hold a pan immediately under area to catch debris while scraping. If any dryACM is encountered stop scraping and wet ACM. Maintain scraping area andany dust or debris generated wet at all times.

b. Scrape away surfacing material that will be disturbed with access door is opened. Scrape material directly into the nozzle of an operating HEPA vacuum or usenozzle of HEPA vacuum directly as tool to remove ACM. Continuouslymaintain HEPA vacuum nozzle within 6" [150mm] of where work is occurring. If any dry ACM is encountered stop scraping and wet ACM. Maintain scrapingarea and any dust or debris generated wet at all times.

11. After ACM surfacing is removed wet surface of substrate and remove all residue witha stiff nylon brush. Remove water and residue from surface with paper towels. Immediately dispose of towels in an asbestos waste bag. Repeat brushing and papertowel process three (3) times. If substrate is a scratch coat, wet substrate and scrapeoff 1/16" of scratch coat to remove any residual ACM that may be trapped in thetexture of the scratch coat.

12. Spray substrate and edges of acoustical plaster with clear penetrating encapsulant.

13. Perform maintenance work required above or behind access door.



S13 . SummaryPainting surfacing ACM.

SummaryThis work practice describes the workrequired to paint small amounts ofsurfacing ACM, such as acoustical plasteror a decorative texture finish. Paint coatsshould be as thin as possible to preventdelamination of surfacing that may becaused by painting. This work may needto be treated as abatement work dependingupon the type and condition of thesurfacing. When selecting work practicesfor a surfacing material it may benecessary to distinguish betweensituations where the material is in itsoriginal condition and those where it hasbeen encapsulated or coated with layers ofpaint. Different work practices may benecessary for each situation. This shouldbe clearly described in each work practice.

Painting a previously painted surface isLevel A work because the surfacingmaterial is contacted but not disturbed. The individuals performing this workshould at a minimum have O&M training. Painting an unpainted surface where theOSHA PEL will not be exceeded or wherethe surface is strong enough that dust ordebris will not be released is Level Bwork. If the work will result in airbornefiber levels above the PEL or if dustand/or debris will be released the work isLevel C. Depending upon the type, condition andfriability of the ACM, this work may needto be treated as an abatement activityinstead of O & M work.

ExamplesLevel A: A. Repaint previously painted asbestos-containing acoustical plaster in good condition.

No preparation of the surface is required.

Level B: A. Paint asbestos-containing decorative texture finish that has not been previouslypainted.

Level C: A. Paint asbestos-containing acoustical plaster that has not been previously painted.B. Paint asbestos-containing fireproofing.

Related Work PracticesS11 Repair damaged surfacing ACM.

Worker RecommendationsOne worker for Level A and Level B. Two workers for Level C. A person with airmonitoring training might be required. This person can be the worker.


S13 . Level APainting surfacing ACM.


A. Repaint previously painted asbestos-containing acoustical plaster in good condition. No preparation of the surface is required.


Use Work Practice M22 if HEPA vacuum needs maintenance, or if bag or filter needs tobe replaced.




b. Paint, rollers or low pressure airless sprayer, and other painting equipment.



5. Place tools, equipment and materials needed on drop cloth.

6. Paint ceiling using sprayer or rollers. If rollers are used, try to contact each area ofthe ceiling only once to avoid damage to ACM.

7. When painting is completed, clean up any loose debris using wet wiping and/orHEPA vacuuming, and roll up drop cloth. Dispose of paint rollers as ACM.



S13 . Level BPainting surfacing ACM.

ExampleThe following is an example of work that can be performed using the procedures of thisLevel B work practice. If job conditions vary from the examples stop work and notifyyour supervisor.

A. Paint asbestos-containing decorative texture finish that has not been previouslypainted.






b. Paint, rollers or low pressure airless sprayer, and other painting equipment




6. Paint ceiling using sprayer or rollers. If rollers are used, try to contact each area ofthe ceiling only once to avoid damage to ACM.

7. When painting is completed, clean up any loose debris using wet-wiping and/orHEPA vacuuming and roll up drop cloth. Dispose of paint rollers as ACM.



S13 . Level CPainting surfacing ACM.

Example The following are examples of work that can be performed using the procedures of thisLevel C work practice. If job conditions vary from the examples stop work and notifyyour supervisor.

A. Paint asbestos-containing acoustical plaster that has not been previously painted.B. Paint asbestos-containing fireproofing.






b. Paint, and rollers or low pressure airless sprayer, and other painting equipment.



5. Erect mini-enclosure (or enclose entire room) and set up negative pressure systemand/or HEPA filtered local exhaust ventilation according to General Procedure W20“Mini-Enclosure”

6. Place tools, equipment and materials needed into enclosure.

7. Enter enclosure and paint ceiling as follows:

a. For acoustical plaster, use rollers or sprayer. If rollers are used, try to contacteach area of the ceiling only once to avoid damage to ACM.

b. For fireproofing, use airless sprayer only.

8. When painting is completed, wet drop cloth with amended water, roll up and disposeof as ACM. Use HEPA vacuum and/or wet-wiping to clean up any dust or debrisunder drop cloth. Dispose of rollers as ACM.


V. Thermal System Insulation (TSI)Work Practices

T-3 # Thermal System Insulation (TSI) # Asbestos O&M Work Practices # © NIBS 1996 #Page-165

Section V. Thermal Systems Insulation (TSI)Work Practices

Work Practices Location Illustration . . . . . . . . . . . . . . . . . . . . . . . . . . . . 164Code Levels DescriptionT1 B C Remove asbestos-containing insulation on exposed

pipe for maintenance work . . . . . . . . . . . . . . . . . . . . . . . . . . . 170T2 B C Remove asbestos-containing insulation on

pipe above ceiling for maintenance work . . . . . . . . . . . . . . . . 177T3 B C Remove asbestos-containing insulation on exposed

pipe in elevated location for maintenance work . . . . . . . . . . . 185T4 B C Remove asbestos-containing insulation on pipe in

occupied area for maintenance work . . . . . . . . . . . . . . . . . . . 193T5 A B C Repair damaged asbestos-containing insulation

on a pipe . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199T6 B C Repair damaged asbestos-containing insulation on a

boiler, duct or flue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 205T7 B C Install device in or access surface of asbestos-containing

insulation on a pipe, boiler, duct or flue . . . . . . . . . . . . . . . . . 210T8 B C Remove asbestos-containing duct insulation

above ceiling for maintenance work . . . . . . . . . . . . . . . . . . . . 215T9 B C Remove asbestos-containing insulation inside HVAC

unit for maintenance work . . . . . . . . . . . . . . . . . . . . . . . . . . . 221T10 B C Clean up asbestos-containing debris in crawlspace

or tunnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 227

The accompanying diagram illustrates typical applications of these work practices.

GENERAL NOTESThe basic method of controlling thedisturbance of TSI which contains ACM isto set up controlled systems and spaces. This can be accomplished by designatingthe systems which contain asbestos as“Controlled Systems.” This designationshould be as specific as possible and basedon the function of the insulated system (e.g. pipe and fitting insulation on steam

piping, fitting insulation on domestic hotwater piping). Spaces where TSI islocated and to which access can becontrolled such as boiler rooms and aboveceiling plenums can be designated as“Controlled Areas.” Access to these areascan be limited to trained personnel whoknow what ACM is present in the space,and know how to avoid disturbing it.


DESIGNING AND IMPLEMENTING WORK PRACTICES

An O&M program will be easier, morepractical to implement and more costefficient if it is designed so that themajority of work can be performed with-out enclosures. For this to happen, eachwork practice needs to be developed tothe point that there is no airborne ex-posure to asbestos (as defined by OSHA). In terms of the OSHA constructionstandard this means that a NegativeExposure Assessment (NEA) must bemade.

The work practices given in this manualare examples of procedures that aretypically useable for the situationsdescribed. The level of training, ex-perience and skill of the staff performingthe work, and the exact type of materialand material conditions will vary fromfacility to facility. The O&M designerneeds to adjust the work practices in theexample to work for the specific materialsand workers in a facility.

Work that occurs in the vicinity of anACM TSI, but does not contact it and isnot likely to disturb it is not given a leveldesignation, but requires control to insurethat a disturbance does not occur. Thisrequires awareness training to notify per-sonnel about the ACM and instructions toavoid disturbing it. Exposure monitoringis not required for these activities as ACMis not being contacted. Awarenesstraining is needed to inform workers aboutthe location of the ACM, and to advisethem to avoid contacting it. A special caseof work in this category are activitieswhere a non-asbestos-containing paper orcloth lagging on a thermal insulation sys-tem is contacted but the insulation itself isnot contacted. The insulation is protectedfrom contact by the lagging. An exampleof this is routine housekeeping such asdusting of piping in occupied areas of abuilding. The awareness training in thisinstance needs to stress the importance of

avoiding damaging the lagging.

Work practice levels are defined in termsof OSHA work classes:

Level A work is an OSHA Class IVactivity, where an ACM thermal systeminsulation is contacted but not disturbed,and a negative exposure assessment(NEA) has been made. Respiratory andarea protection is not required by OSHAfor this level of work, but is an option thatthe designer should consider. Carefulhandling, wet methods, HEPA vacuums,prompt clean up and disposal, andawareness training for workers is required.

! Design: During design of the O&Mprocedure, the designer (who must bea Competent Person as defined byOSHA) must make an initial exposureassessment and determine that theACM is in good condition and that itwill not be disturbed by the work. This requires that a negative exposureassessment NEA be made. Refer tothe introduction for more informationon making an NEA. The only LevelA work procedure on TSI in thismanual is the use of wetted lagging towrap pipe insulation. A similarprocedure could be used to coat andstabilize insulation in the vicinity ofplumbing work.

! Implementation: The AsbestosProgram Manager (APM) orsomebody designated by the APMshould be qualified as a competentperson so that someone is availablewhen new situations come up. Ideallythe person that is currently in chargeof assigning work to the maintenancestaff should be this competent person.


Level B work is an OSHA Class IIIactivity, where ACM thermal systeminsulation is disturbed but a negativeexposure assessment has been made (thePEL will not be exceeded). The“disturbance” of the ACM in this instanceis usually the removal of a small quantityof material, penetration by a fastener, orthe removal of an intact section ofinsulation. Work practices such as carefulhandling, wetting, and local exhaustventilation using a HEPA vacuum areused to prevent fiber release. Frequently,the wand of an operating HEPA vacuum isused as a tool to remove the ACM. TheHEPA vacuum not only collects theremoved material and contains it insidethe vacuum, but also collects any releasedairborne fibers. The HEPA vacuumaccomplishes localized cleaning of the airin the vicinity of the work when used inthis manner, or if held near the location ofwork that disturbs ACM. OSHA requiresrespiratory protection for work thatdisturbs TSI even if the PEL is notexceeded. Drop cloths are not required byOSHA, but are a practical necessity forthis type of work.

Warning: The Level B work practicesin this manual cannot be used until anegative exposure assessment hasbeen made. Level B work practicesare performed without an enclosure. OSHA does not allow work thatdisturbs asbestos-containing thermalsystem insulation to be performedoutside of an enclosure unless therehas been an NEA.

! Design: The designer selects the workpractice in this section that mostclosely matches the work to be ac-complished. The work practice ismodified as necessary toaccommodate conditions in thefacility. The work practice must thenbe tested. This should be done byhaving the workers that will beperforming the work follow theprocedure. Normally, unless there is

exposure data is available, this testingwill have to be performed inside anenclosure. During the test, the workpractices are adjusted as necessaryuntil exposures are reliably kept belowthe OSHA PELs. The designer, whomust be a competent person, can thenmake a negative exposure assessment. If the facility has requirements forarea samples, these are also monitoredduring the test.

! Implementation: Each time that workis assigned the asbestos programmanager (APM) (who must also be acompetent person) must make adetermination that the work practice isapplicable to the conditions at thespecific job site.

Level C work is an OSHA Class IIIactivity on an ACM thermal systeminsulation where the work includesdrilling, cutting, abrading, sanding,chipping, breaking, or sawing; or there isno negative exposure assessment (the PELmay be exceeded). In this instance carefulhandling, wetting, and use of HEPAvacuums is not sufficient to prevent theescape of airborne fibers, dust and debris,and some sort of enclosure is needed toprotect the environment. Usually thisenclosure will be a glove bag (particularlyin the case of pipe or fitting insulation). The glove bag protects both the workerand the environment. The porous natureof thermal system insulation and the spacethat usually exists between the insulationand its substrate (e.g.. the annular spacebetween pipe insulation and the pipe toallow the pipe to expand and contract)make it physically impossible to get anairtight seal on a glovebag. Exposures toworkers and the environment aresubstantially reduced, but are noteliminated. Workers using glovebagsneed to be protected with respirators,protective clothing and decontaminationprocedures. It is dangerous to use powertools inside a glovebag. Work with powertools should be performed with tools


equipped with HEPA filtered localexhaust ventilation or be performed insidea mini-enclosure.

! Design: Glovebag procedures shouldbe developed to the point that anegative exposure assessment can bemade. Worker and area protectionshould then be equivalent to Level Brequirements.

A mini-enclosure protects theenvironment, but may actuallyincrease the exposure to workers.Initial monitoring needs to beconducted inside mini-enclosures todetermine what respiratory protectionand other worker protectionrequirements are required. Workpractices used inside a mini-enclosureshould be similar to those used forLevel B work. Workers need to beprotected with respirators, protective

clothing and decontaminationprocedures.

Training as abatement workers ismore adequate for those performingLevel C work in a mini-enclosurewhere exposure to elevated asbestoslevels and the need for a wetdecontamination is possible. Frequently, O&M programs will avoidthe use of level C work practices. Iflevel C work is infrequentlyencountered, it is best to limit thistype of work to outside abatementcontractors who have workersaccustomed to working inenvironments with elevated asbestoslevels.

! Implementation: Periodicmonitoring must be performed insidemini-enclosures to validate theselection of respiratory protection.

WORK PRACTICES

Careful work practices should be theprimary means used to prevent releases ofasbestos fibers during O&M work. Suchpractices include control measures such ascareful handling, wetting and localexhaust using HEPA vacuums that controlor collect fibers at the source. The goal ofall asbestos O&M work should be toprevent any exposure of the worker andunnecessary contamination of the workarea, drop cloths, mini-enclosures andother secondary control devices. Mini-enclosures should never be used to excusesloppy work or creation of "bigger"messes.

Users should review General ProcedureW17 (glovebag removal procedures) andbe properly trained in the use ofglovebags. Glovebags are used in most ofthe TSI work practices. Glovebags usedshould be the appropriate type for the sizeof the task, orientation of piping (or othermaterials), temperature of surface and

other relevant factors. Other types ofprefabricated contaminant devices thatmay be used in place of glovebags arebriefly discussed in W18.

Materials that have had TSI removedshould be sprayed with a lockdownencapsulant in accordance with GeneralProcedure W12. Care should be used inselecting a lockdown for pipes that gethot, to select materials that do not breakdown or char at the service temperature ofthe pipe. In general, lockdownencapsulant should not be used at all onbreechings or high pressure steam lines.

Many of the TSI work practicesrecommend the use of two workers. Safety considerations for many activities,as well as efficiency considerations willoften necessitate the use of two workers. Two workers are recommended for workpractices using mini-enclosures. The O &M program may also require that two


workers be used for glovebag removalwork.

General Procedure APM10 discussesemergency work and/or dry removal thatmight be necessary under certainconditions, such as removing insulationadjacent to an activated power panel tomake emergency repairs on a critical pieceof equipment. Review and comply withall applicable regulatory requirements.

Some of the TSI Work Practices specify

attaching a glovebag over duct tapeapplied around a pipe. If the pipeinsulation surface is smooth, a flexiblemetal sleeve might be wrapped around thepipe in lieu of duct tape if an adequate sealcan be obtained. This allows removal ofthe metal sleeve at the end of the workrather than leaving duct tape in placearound the pipe (duct tape isrecommended to be left in place becauseremoval of duct tape can damage ACMinsulation).


T1 . SummaryRemove asbestos-containing insulation onexposed pipe for maintenance work.

SummaryThis work practice covers the proceduresfor removing small amounts of asbestos-containing insulation on an exposed pipein an unoccupied area such as a boiler ormechanical room. The procedure assumesthat the pipe insulation is accessible froma ladder or scaffold less than 10 feet (3 m)in height.

Two Level C work practices are given. One is a glove-bag procedure, the other isa mini-enclosure procedure where the useof glove-bags is impractical for some

reason. Standard glove-bags do notprovide an airtight enclosure. Theyreduce, but do not eliminate exposure. Negative pressure glove-bags and glove-boxes are not as proven, but should reduceexposures below that experienced with astandard glove-bag. These devices aremore cumbersome to use, and in actualuse, difficulties with sealing and thebellows pumping action of a glove-bag inuse may overcome any negative pressurethat could be developed with a HEPAvacuum.

Examples

Level B: This example relies on the use of careful handling and wetting as the primary asbestoscontrols, augmented by the use of a HEPA vacuum for local area exhaust. This will bemost effective on aircell insulation. This control strategy may not work in allcircumstances. Work on amosite based insulations will be more successful if local areaexhaust using the HEPA vacuum is the primary means of asbestos control. Plaster typeinsulations might be removed by thoroughly wetting and then removed using the nozzleof the HEPA vacuum as the tool. Other methods can also be affective. Refer to otherwork practices in this manual for examples that can be applied to this situation. Someexperimentation is necessary to see what works in a given facility

OSHA allows work on TSI to be conducted as Class III as long as a small amount ofmaterial is involved. Class III work on TSI requires the use of careful handling, wetmethods, local exhaust ventilation (using a HEPA vacuum), and respirators. A dropclothis not required by OSHA but is a practical necessity for this type of work.

The O&M designer must make a negative exposure assessment (NEA) before these un-enclosed Level B work practices are used in the facility. See the introduction for moreinformation on making an NEA.

A. Remove no more than one 4 foot length of laminated corrugated paper pipe insulationin good condition, where the insulation can be removed intact.

T1 . Summary ... continued


Level C: Glove-bagA. Removal of 1 standard glovebag of insulation in good condition to make a new

connection to an existing pipe.B. Removal of insulation in good condition from a fitting to replace a valve.

Level C: Mini-enclosureA. Removal of a section of pipe insulation in poor condition, or metal or waterproofed

jacketed insulation. B. Removal of a section of pipe insulation that will not fit in a glovebag, or removal

work on hot piping (>150o).

Related Work PracticesT 2 Remove asbestos-containing insulation on pipe above panel ceiling for

maintenance workT 3 Remove asbestos-containing insulation on exposed pipe in elevated location for

maintenance workT 4 Remove asbestos-containing insulation on pipe in occupied area for maintenance

workT 5 Repair damaged system insulation on a pipeT 7 Install device in asbestos-containing insulation on a or excess surface of, pipe,

boiler, duct or flue

Worker RecommendationsTwo workers are required for this work by the OSHA regulation. A person with airmonitoring training might be required. This person can be a worker.


T1 . Level BRemove asbestos-containing insulation onexposed pipe for maintenance work


A. Remove no more than one 4 foot length of laminated corrugated paper pipe insulationin good condition, where the insulation can be removed intact.


Asbestos-containing pipe insulation is a “Controlled System” Do not contact or disturbpipe insulation unless you have been authorized by facility management.




b. Razor Knife

c. Non-ACM replacement insulation




6. Adequately wet insulation to be removed.

7. Wait until water has soaked into insulation. Add water until insulation is completelysaturated

8. Cut bands holding insulation in place

9. Slice lagging with a razor knife at joints between sections of insulation and lengthwise at joints between clamshell halves.

10. Open insulation clamshell and place intact into an asbestos disposal bag. Do notdrop.

11. Keep hose of an operating HEPA vacuum adjacent to the removal area during entireremoval operations to capture any debris or fibers generated.

12. Wet wipe surface of pipe to remove any ACM residue.

T1 . Level B ... continued


13. HEPA vacuum and then wet wipe surface of HVAC unit and floor in vicinity of thework.

14. Perform maintenance work and clean-up and tear-down steps on Level B checklist tocomplete work.


T1 . Level C (glove-bag)Remove asbestos-containing insulation onexposed pipe for maintenance work.


A. Removal of 1 standard glovebag of insulation in good condition to make a newconnection to an existing pipe.

B. Removal of insulation in good condition from a fitting to replace a valve.

Notes Asbestos-containing pipe insulation is a “controlled system.” Do not contact or disturbpipe insulation unless authorized by facility management






b. Glovebags

c. Replacement non-ACM insulation if required

d. Pipe repair materials and tools




6. Place all needed tools inside of glovebag and attach glovebag to area of pipeinsulation to be removed. See general procedure W18.

7. Remove ACM using glovebag procedures. Adequately wet removal area frequentlyduring removal of the bulk material. Seal exposed ends of insulation beforeremoving glovebags.



T1 . Level C (Mini-enclosure)Remove asbestos-containing insulation onexposed pipe for maintenance work.


A. Removal of a section of pipe insulation in poor condition, or metal or waterproofedjacketed insulation.

B. Removal of a section of pipe insulation that will not fit in a glovebag, or removalwork on hot piping (>150o).







b. Glovebags (if applicable)

c. Replacement non-ACM insulation, if required

d. Pipe repair materials and tools



5. Erect mini-enclosure and set up negative pressure system and/or HEPA filtered localexhaust ventilation according to General Procedure W20 “Mini-Enclosure.” If workis on hot piping use a HEPA filtered fan unit instead of a HEPA vacuum toaccomplish negative pressure in mini-enclosure. Size fan unit so that mini-enclosureis sufficiently ventilated that heat build up does not occur.

T1 . Level C (Mini-enclosure) ... continued



7. If working on hot pipes, wear cloth coverall and use insulated gloves for handling hotpiping.

8. Enter enclosure and place all needed tools inside of glovebag, (if pipe is not too hotfor a glove-bag and will fit in a glovebag) and attach glovebag to area of pipeinsulation to be removed. Remove ACM using glovebag procedures. See generalprocedure W18. If pipe is hot or will not fit in a glovebag, set up HEPA filtered localexhaust ventilation and follow glovebag removal sequence inside of mini-enclosure.

9. For hot piping only: Wear cloth coverall without paper suit. Wear insulated gloves. Do not work in area unless ventilation is sufficient to prevent heat build-up insidemini-enclosure. Do not touch pipes. Perform all work on hot pipes with tools. Donot wet pipe insulation. Do not try to use a glove-bag. Cut bands holding insulationin place. While holding the nozzle of a HEPA vacuum in the vicinity of, and wherepossible, below the work: slit lagging with a razor knife, open clamshell of insulationand remove from pipe. Set removed insulation aside and allow to cool and thencarefully place in an asbestos disposal bag. Remove any ACM residue on pipe withnozzle of HEPA vacuum and a brass wire brush. Perform required maintenance workand re-insulate pipe as soon as possible.

10. If a glove-bag is not used, remove the pipe insulation using this procedure. Wet pipelagging with amended water. Slit lagging at both ends of length of insulation to beremoved with a razor knife. If pipe insulation is painted or otherwise impervious towater penetration, slit lagging with a razor knife as necessary and inject amendedwater into insulation with tip of sprayer nozzle. Allow water to soak in, add wateruntil insulation is soggy. Cut bands holding insulation. Slit lagging with a razorknife, and carefully open clamshell of insulation and remove from pipe. Placeremove insulation in a disposal bag. Wet wipe pipe to remove any ACM residue.



T2 . SummaryRemove asbestos-containing insulation onpipe above ceiling for maintenance work.

SummaryThis work practice covers the proceduresfor removing small amounts of asbestos-containing insulation on a pipe locatedabove a lay-in panel ceiling.

Two Level C work practices are given. One is a glove-bag procedure, and theother is a mini-enclosure procedure wherethe use of glove-bags is impractical forsome reason. Standard glove-bags do notprovide an airtight enclosure. They

reduce, but do not eliminate exposure. Negative pressure glove-bags and glove-boxes are not as proven, but should reduceexposures below that experienced with astandard glove-bag. These devices aremore cumbersome to use, and in actualuse, difficulties with sealing and thebellows pumping action of a glove-bag inuse may overcome any negative pressurethat could be developed with a HEPAvacuum.

Examples


OSHA allows work on TSI to be conducted as Class III as long as a small amount ofmaterial is involved. Class III work on TSI requires the use of careful handling, wetmethods, local exhaust ventilation (using a HEPA vacuum), and respirators. A dropclothis not required by OSHA but is a practical necessity for this type of work.


A. Remove no more than one 4 foot length of laminated corrugated paper pipeinsulation in good condition, where the insulation can be removed intact.

Level C: (Glove-Bag)A. Remove a section of pipe insulation above lay-in panel ceiling where insulation is in

good condition, e.g., pipe leak.B. Repair pipe leak above a non-ACM plaster or drywall ceiling.C. Attach branch line to existing steam line above non-ACM plaster ceiling.



Level C: (Mini-enclosure)A. Remove a section of pipe insulation in poor condition for fitting replacement.B. Remove a section of pipe insulation in poor condition, or with metal jacket, or

waterproofed to replace a section of pipe.C. Remove ACM insulation which is damaged and in poor condition from steam line

above non-ACM plaster ceiling.D. Remove insulation in poor condition on a pipe to repair leak above a non-ACM

drywall ceiling.

Related Work PracticesS 2 Observation or work in ceiling plenum space where exposed surfacing ACM is

presentT 3 Remove asbestos-containing insulation on exposed pipe in elevated location for

maintenance workM 11 Replace asbestos-containing ceiling panels in lay-in ceiling system.M 12 Replace asbestos containing ceiling tiles attached with adhesiveM 13 Replace asbestos containing ceiling tiles in spline ceiling systemM 29 Clean up debris from minor fiber release

Worker Recommendations: Two workers. A person with air monitoring training might be required. This person canbe a worker.


T2 . Level BRemove asbestos-containing insulation onpipe above ceiling for maintenance work








b. Razor Knife














T2 . Level C (Glove-Bag)Remove asbestos-containing insulation onpipe above ceiling for maintenance work


A. Remove a section of pipe insulation above lay-in panel ceiling where insulation is ingood condition, e.g., pipe leak.







b. Scraper (2-3" [50-75 mm] wide stiff blade)


d. Replacement non-ACM insulation if required

e. Pipe repair materials and tools

f. Glovebags





7. Pick up any bulk debris within reach on top of ceiling and place into disposal bag. HEPA vacuum top side of ceiling within reach from access hole.

8. Place all tools needed inside glovebag and attach glovebag to area where pipeinsulation will be removed. See general procedure W18.

9. Remove ACM using glovebag procedures. Adequately wet removal area frequentlyduring removal of the bulk material.

T2 . Level C (Glove-Bag)




T2 . Level C (mini- enclosures)Remove asbestos-containing insulation onpipe above ceiling for maintenance


A. Remove a section of pipe insulation in poor condition for fitting replacement.B. Remove a section of pipe insulation in poor condition, or with metal jacket, or

waterproofed to replace a section of pipe.











f. Glovebags





T2 . Level C (mini- enclosures) ... continued


7. Enter enclosure and obtain access above ceiling using appropriate O & M workpractice.

8. Pick up any bulk debris within reach on top of ceiling and place into disposal bag.


10. If present, remove any metal jacket material over insulation to be removed.

11. Enter enclosure, place all tools needed inside glovebag and attach glovebag to areawhere pipe insulation will be removed. general procedure W18. Remove ACMusing glovebag procedures. Adequately wet removal area frequently during removalof the bulk material.


13. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist tocomplete work.


T3 . SummaryRemove asbestos-containing insulation onexposed pipe in elevated location formaintenance work

SummaryThis work practice covers the proceduresfor removing small amounts of asbestos-containing insulation on exposed piping inelevated locations (approximately 10 feet[3 m] or more above floor level). Thisprocedure uses a scaffold as a workplatform to reduce the safety hazards fromworking from a tall ladder.

Two Level C work practices are given. One is a glove-bag procedure, and theother is a mini-enclosure procedure wherethe use of glove-bags is impractical for

some reason. Standard glove-bags do notprovide an airtight enclosure. Theyreduce, but do not eliminate exposure. Negative pressure glove-bags and glove-boxes are not as proven, but should reduceexposures below that experienced with astandard glove-bag. These devices aremore cumbersome to use, and in actualuse, difficulties with sealing and thebellows pumping action of a glove-bag inuse may overcome any negative pressurethat could be developed with a HEPAvacuum.

Examples


OSHA allows work on TSI to be conducted as Class III as long as a small amount ofmaterial is involved. Class III work on TSI requires the use of careful handling, wetmethods, local exhaust ventilation (using a HEPA vacuum), and respirators. A dropclothis not required by OSHA but is a practice necessity for this type of work.





Level C: (Glove-bag)A. Repair small pipe leak in boiler roomB. Install new ceiling mounted hot water heating unit in warehouse space fed from

existing piping.

Level C: (Mini-enclosure)A. Remove insulation on 12" (305 mm) fitting in poor condition, 15 feet (4.5 m) above

floor level to repair leak in steam line.B. Remove insulation on pipe adjacent to steel grate catwalk 30 feet (9 m) above floor in

boiler room.

Related Work PracticesT 2 Remove asbestos-containing insulation on pipe above panel ceiling for

maintenance work.T 4 Remove asbestos-containing insulation on pipe in occupied area for maintenance

work.

Worker RecommendationsTwo workers. A person with air monitoring training might be required. This person canbe a worker.


T3 . Level BRemove asbestos-containing insulation onexposed pipe in elevated location formaintenance work








b. Razor Knife













T3 . Level C (Glove-bags)Remove asbestos-containing insulation onexposed pipe in elevated location formaintenance work


A. Repair small pipe leak in boiler roomB. Install new ceiling mounted hot water heating unit in warehouse space fed from

existing piping.











f. Glovebags

g. Non-slip drop cloth



5. Erect scaffold system using proper OSHA procedures. Care should be taken not todisturb the ACM.

6. Place tools, equipment and materials needed onto non-slip drop cloth on scaffoldsystem.

7. Place all tools needed inside glovebag and attach glovebag to area where pipeinsulation will be removed. See general procedure W18.

T3 . Level C (Glove-bags) ... continued



9. Perform maintenance work and clean-up and tear-down steps on Level C checklistto complete work.


T3 . Level C (mini-enclosure)Remove asbestos-containing insulation onexposed pipe in elevated location formaintenance work


A. Remove insulation on 12" (305 mm) fitting in poor condition, 15 feet (4.5 m) abovefloor level to repair leak in steam line.

B. Remove insulation on pipe adjacent to steel grate catwalk 30 feet (9 m) above floor inboiler room.











f. Glovebags

g. Non-slip drop cloth



T3 . Level C (mini-enclosure) ... continued



6. Erect scaffold system using proper OSHA procedures. Care should be taken not todisturb the ACM. Erect mini-enclosure on top of scaffold system and set up negativepressure system. See general procedure W20. The top floor layer in enclosureshould be a non-slip drop cloth material. If work is on hot piping use a HEPAfiltered fan unit instead of a HEPA vacuum to accomplish negative pressure in mini-enclosure. Make-up air inlet so that it brings in air from outside boiler room. Sizefan unit so that mini-enclosure is sufficiently ventilated that heat build up does notoccur.


8. If working on hot pipes, wear cloth coverall and use insulated gloves for handling hotpiping.

9. Enter enclosure, place all tools needed inside glovebag and attach glovebag to areawhere pipe insulation will be removed. general procedure W18. Remove ACMusing glovebag procedures. Adequately wet removal area frequently during removalof the bulk material.




T4 . SummaryRemove asbestos-containing insulation onpipe in occupied area for maintenance work

SummaryThis work practice covers the proceduresfor removing small amounts of asbestos-containing pipe insulation inside a mini-enclosure located in an occupied area. This procedure assumes that maintenancework must occur immediately in anoccupied area or work area is occupied 24hours a day.

Two Level C work practices are given. One is a glove-bag procedure, and theother is a mini-enclosure procedure wherethe use of glove-bags is impractical for

some reason. Standard glove-bags do notprovide an airtight enclosure. Theyreduce, but do not eliminate exposure. Negative pressure glove-bags and glove-boxes are not as proven, but should reduceexposures below that experienced with astandard glove-bag. These devices aremore cumbersome to use, and in actualuse, difficulties with sealing and thebellows pumping action of a glove-bag inuse may overcome any negative pressurethat could be developed with a HEPAvacuum.

Examples





Level C: A. Repair leak in pipe riser of occupied computer room.B. Replace a small amount of damaged insulation on piping in manufacturing plant

during working hours.



Related Work PracticesT 2 Remove asbestos-containing insulation on pipe above ceiling for maintenance

workT 3 Remove asbestos-containing insulation on exposed pipe in elevated location for

maintenance work



T4 . Level BRemove asbestos-containing insulation onpipe in occupied area for maintenance work








b. Razor Knife














T4 . Level CRemove asbestos-containing insulation onpipe in occupied area for maintenance work


A. Repair leak in pipe riser of occupied computer room.B. Replace a small amount of damaged insulation on piping in manufacturing plant

during working hours.












f. Glovebags




T4 . Level C ... continued


6. Place tools, equipment and materials needed into enclosure. If work must occurabove ceiling, include a HEPA vacuum inside enclosure for vacuuming areas aboveceiling.

7. Enter enclosure and place all tools needed inside glovebag. If access above ceiling isrequired, obtain access above ceiling using O & M work practice selected (see noteabove step 1). Attach glovebag to area where pipe insulation will be removed. Seegeneral procedure W18.




T5 . SummaryRepair damaged asbestos-containinginsulation on a pipe

SummaryThis work practice covers the proceduresfor repairing small areas of damagedasbestos-containing insulation.

The insulation system on piping usuallyconsists of insulations which is soft andeasily damaged, covered by a lagging thatprotects the insulation. Laggings onpiping are typically made from paper,cloth, cement or cloth impregnated withcement. The lagging may or may notcontain asbestos. It may be continuous sothat there are no visible joints, or all jointsbetween sections of insulation may beexposed. Some insulation systems havean integral lagging made from the samematerial as the insulation (e.g. some aircellinsulation systems) that may be fragile andrequire great care.

Repair work on TSI that has a small dentor hole by wrapping with a wetted laggingcloth contacts, but does not disturb theACM. This is Class IV work and henceLevel A. If a facility has a great deal ofintact TSI with intact lagging that hasperiodic dings, then a Level A procedureshould be considered. However, in manyinstances this work involves the removalof a small amount of damaged insulating

or lagging material, or the repositioning oradjusting of insulation or lagging. Thisconstitutes a disturbance of the ACMmaking this Class III work and hence levelB. If the insulation is badly damagedrepair work may result in the release ofairborne asbestos or visible debris. In thisinstance the work is Level C.

Installation of pipe lagging is a plumbingskill not an abatement skill. Installation orrepair of pipe insulation materials requirespecial skills, especially on sub-ambient(cold) surfaces. Particular care is neededto restore vapor barriers and protectagainst condensation and moisture/frostmigration. Workers installing laggingmaterial as an asbestos control activityshould be trained by an experiencedplumber or insulator in proper lagginginstallation. Many lagging repairs madeby asbestos O&M trained workers havefailed after a short period of time when therepair cracked or fell off due to expansionand contraction of the pipe insulation. The design of the O&M program shouldinclude the selection of the correct laggingmaterial for the service conditions of thepipe insulation.

ExamplesLevel A: A. Repair small area of impact damage on pipe insulation in good condition with

lagging in good condition.

Level B: A. Repair small area of impact damage on pipe insulation in good condition.B. Repair minor damage to insulation on a pipe fitting.

Level C: A. Repair a small amount of damaged pipe insulation adjacent to operating HVAC.B. Repair a small amount of delaminated pipe insulation in an occupied area.



Related Work PracticesT 3 - Remove asbestos-containing insulation on exposed pipe in elevated location for

maintenance workM 29 - Clean up debris from minor fiber release

Worker Recommendations:One worker - Level A and B. Two workers - Level C. A person with air monitoringtraining might be required. This person can be a worker.


T5 . Level ARepair damaged asbestos-containinginsulation on a pipe


A. Repair small area of impact damage on pipe insulation in good condition wherelagging is intact.

NotesAsbestos-containing pipe insulation is a “controlled system.” Do not contact or disturbpipe insulation unless authorized by facility management





b. Sponge

c. Lag cloth



5. If access above ceiling is required, obtain access above ceiling using appropriate O &M work practice.

6. Adequately wet area of insulation to be repaired where appropriate. HEPA vacuumdamaged area to be repaired.

7. Dip lag cloth into water and squeeze out excess water. Apply lag cloth to area ofinsulation being repaired and smooth out using a wet sponge. Restore vapor barrieron cold insulation and seal off to adjacent vapor barrier surfaces.



T5 . Level BRepair damaged asbestos-containinginsulation on a pipe


A. Repair small area of impact damage on pipe insulation in good condition.B. Repair minor damage to insulation on a pipe fitting.






b. Sponge

c. Non-ACM insulation patching material

d. Putty Knife

e. Lag cloth



5. Place tools, equipment and materials needed onto drop cloth. If access above ceilingis required, obtain access above ceiling using appropriate O & M work practice.

6. Adequately wet area of insulation to be repaired where appropriate. HEPA vacuumdamaged area to be repaired. Remove any loose debris with HEPA vacuum.

7. Fill in repair area with non-ACM patching material. Dip lag cloth into water andsqueeze out excess water. Apply lag cloth to area of insulation being repaired andsmooth out using a wet sponge. Restore vapor barrier on cold insulation and seal offto adjacent vapor barrier surfaces.



T5 . Level CRepair damaged asbestos-containinginsulation on a pipe


A. Repair a small amount of damaged pipe insulation adjacent to operating HVAC.B. Repair a small amount of delaminated pipe insulation in an occupied area.










d. Sponge

e. Non-ACM insulation patching material

f. Putty Knife

g. Lag cloth




6. Place tools, equipment and materials needed into enclosure. If work must occurabove ceiling, include a HEPA vacuum inside enclosure for vacuuming areas aboveceiling.



7. Enter enclosure. If access above ceiling is required, obtain access above ceilingusing appropriate O & M work practice.

8. If work can be done with a glovebag method, follow procedures below:

a. Install duct tape around area to be repaired.

b. Place tools, equipment and other materials into glove bag. Attach glovebag toduct tape using more duct tape.

c. Remove all loose or damaged insulation that is not going to be repaired usingglovebag procedures. See general procedure W18.

d. Remove glovebag leaving duct tape from step “a” above.

9. If a glovebag method cannot be effectively utilized, follow procedures below:

a. Adequately wet material at area to be repaired.

b. Cut out damaged TSI, trimming edges so straight square clean edges remain. This procedure must only be performed on adequately wet material, and with aHEPA vacuum nozzle adjacent to the cutting tool so that any debris or fibers arecaptured by the HEPA vacuum.

10. Fill in repair area with non-ACM patching material. Dip lag cloth into water andsqueeze out excess water. Apply lag cloth to area of insulation being repaired andsmooth out using a wet sponge. Restore vapor barrier on cold insulation and seal offto adjacent vapor barrier surfaces.



T6 . SummaryRepair damaged asbestos-containinginsulation on a boiler, duct or flue

SummaryThis work practice covers the proceduresfor repairing small amounts of damagedasbestos-containing thermal systemsinsulation.

The insulation system on boilers ducts andflues can be complicated. It frequentlyconsists of several layers. The inner layeris typically blocks of insulation(frequently with an amosite or sometimeswith a chrysotile or crocidolite content)wired or fastened in place. This may becovered with an insulating cementreinforced with chicken wire (this materialfrequently contains chrysotile asbestos). The insulation cement may be troweledsmooth as a lagging or a separate laggingmay have been installed. This laggingmay be a dense hard cement, clothimpregnated with cement or some otherinstallation. This lagging may or may notcontain asbestos. The final lagging isusually continuous so that there are novisible joints, except for expansion joints.

Repair of insulation and lagging onboilers, ducts and flues requires skill andunderstanding of insulating techniques. Itis preferable to train skilled insulators inAsbestos O&M procedures rather than to

expect asbestos workers to performinsulating and lagging work. The quickfix of a plug of insulating material with apatch of wettable lagging cloth over a holein boiler or flue insulation is highly likelyto fail. Many lagging repairs made byasbestos O&M trained workers have failedafter a short period of time when the repaircracked loose or fell out due to expansionand contraction of the insulation. Inmany instances the surface temperature ofthe insulation is high enough that clothmaterials cannot be used at all.

Repair work on these types of systemfrequently involve the reinstallation oflagging over a fairly large part of thesurface of the insulation. In manyinstances this work involves the removalof a small amount of damaged insulatingor lagging material, or the repositioning oradjusting of insulation or lagging. Thisconstitutes a disturbance of the ACMmaking this Class III work and hence levelB. If the insulation is badly damagedrepair work may result in the release ofairborne asbestos or visible debris. In thisinstance the work is Level C. The designof the O&M program should include theselection of the correct lagging materialand method of installation.

ExamplesLevel B: A. Repair small area of impact damaged insulation on duct or flue in good condition.

B. Repair minor damage to boiler insulation around access hatch.

Level C: A. Repair a small area of badly damaged flue or duct insulation.B. Repair a small area of water damaged insulation on hot water tank or boiler.




maintenance workM 29 - Clean up debris from minor fiber release

Worker RecommendationsOne worker - Level B. Two workers - Level C. A person with air monitoring trainingmight be required. This person can be a worker.


T6 . Level BRepair damaged asbestos-containinginsulation on a boiler, duct or flue


A. Repair small area of impact damaged insulation on duct or flue in good condition.B. Repair minor damage to boiler insulation around access hatch.


Asbestos-containing pipe, boiler, flue and equipment insulation is a “Controlled System”Do not contact or disturb these materials unless you have been 6authorized by facilitymanagement.




b. Sponge

c. Non-ACM insulation patching material

d. Putty Knife

e. Lag cloth



5. Place tools, equipment and materials needed onto drop cloth. If access above ceilingis required, obtain access above ceiling using appropriate O & M work practice.

6. Adequately wet area of insulation to be repaired where appropriate. HEPA vacuumdamaged area to be repaired and remove any loose debris.

7. Fill in repair area with non-ACM patching material.

8. Properly relag repaired area. Apply all lagging materials wet and insure the existingACM material is not disturbed by lagging installation.



T6 . Level CRepair damaged asbestos-containinginsulation on a boiler, duct or flue


A. Repair a small area of badly damaged flue or duct insulation.B. Repair a small area of water damaged insulation on hot water tank or boiler.

NotesAsbestos-containing pipe insulation is a “controlled system.” Do not contact or disturbpipe insulation unless authorized by facility management









d. Sponge

e. HEPA vacuum, hose and attachments

f. Putty Knife

g. Glovebags

h. Lag cloth






6. Place tools, equipment and materials needed into enclosure. If work must occurabove ceiling, include a HEPA vacuum outside of the enclosure with hose and nozzleextending inside enclosure for vacuuming areas above ceiling.



a. Install duct tape around area to be repaired.


c. Remove all loose or damaged insulation using glovebag procedures. See generalprocedure W18.

d. Remove glovebag leaving duct tape from step above.


a. Adequately wet material at area to be repaired.

b. Cut out damaged TSI, trimming edges so straight square clean edges remain. This procedure must only be performed on adequately wet material, and with aHEPA vacuum nozzle adjacent to the cutting tool so that any debris or fibers arecaptured by the HEPA vacuum.

10. Place ACM debris into disposal bags.

11. Remove glovebag (if used) and fill in small repair areas with non-ACM patchingmaterial.

12. Properly re-insulate and relag repaired area. Apply all lagging materials wet andinsure the existing ACM material is not disturbed by lagging installation.

13. Perform clean-up and tear-down steps on Level C checklist to complete work. Leaveduct tape installed in glovebag procedure in place.


T7 . SummaryInstall device in, or access surface of,asbestos-containing insulation on a pipe,boiler, duct or flue

SummaryThis summary covers the removal of smallamounts of ACM as required to install adevice (such as a temperature sensor ordamper control) in, or simply to access,the surface of an ACM insulated pipe,boiler, duct or flue.

This example relies on the use wetting andlayer by layer removal of a small patch ofinsulation to keep airborne fiber levelsbelow the OSHA PEL and avoidspreading dust and debris. Someexperimentation is necessary to see whatworks on equipment in a given facility.

Different types of equipment may havedifferent insulation systems. Some typesof equipment may have insulationcontaining high concentrations of amosite. Procedures that rely on wetting would beless effective in this situation than whereonly chrysotile is involved. A workpractice developed on a chrysotile systemwhich wets well may not be effective onan amosite system. Work practices thatuse local area exhaust with a HEPAvacuum as the primary means of controlhave a better chance of being universallyapplicable.

ExamplesLevel B: A. Remove a small amount of ACM in good condition in order to install energy

management system sensors and controls.

Level C: A. Drill through insulation using power tools to attach heat sensor directly on metal flue.B. Remove a small amount of damaged insulation in order to attach heat sensor directly

on metal flue.

Related Work PracticesT 1 - Remove Asbestos-containing insulation on exposed pipe for maintenance workT 4 - Remove Asbestos-containing insulation on pipe in occupied area for maintenance

workT 5 - Repair damaged asbestos-containing insulation on a pipe

Worker RecommendationsOne worker. A person with air monitoring training might be required. This person canbe the worker.


T7 . Level BInstall device in, or access surface of,asbestos-containing insulation on a pipe,insulated boiler, duct or flue


A. Remove a small quantity of ACM in good condition in order to install energymanagement system sensors and controls.


Asbestos-containing thermal system insulation is a “Controlled System” Do not contactor disturb thermal system insulation unless you have been authorized by facilitymanagement.




b. Non-ACM replacement insulation or patching material (if required)

c. Device to be installed and related tools



5. Place tools, equipment and materials needed onto drop cloth. If access above ceilingis required, obtain access using appropriate O & M work practice.

6. Wet insulation that is to be removed with amended water. Allow water to soakthrough insulation to substrate. Apply more water as required to saturate insulationthat is to be removed.

7. Scrape wetted insulation from equipment. Hold a pan immediately under area beingscraped to catch debris. If dry insulation is encountered, stop scraping, re-wet andallow water to soak in. Remove all wetted material. Promptly place removedinsulation in a disposal bag. Spray pan with amended water and wet wipe to removeall insulation debris and residue.



8. After insulation is removed, wet surface of equipment with amended water and wetwipe surface with paper towels. Wet wipe until all residue is removed. After allresidue is removed wet wipe surface with clean water without surfactant. Dispose ofpaper towels as asbestos waste.

9. HEPA vacuum surface of equipment and edge of remaining insulation.

10. Perform work as necessary to install device.

11. Replace removed insulation with new insulation patching material. Install patchmaterial in accordance with facility’s repair work practices, and manufacturer’sinstructions.

12. Restore vapor barrier on cold insulation and seal off to adjacent vapor barriersurfaces.

13. Perform clean-up and tear-down steps on Level 2 checklist to complete work. Leaveduct tape installed in step 5 in-place.


T7 . Level CInstall device in, or access surface of,asbestos-containing insulation on a pipe,boiler, duct or flue


A. Drill through insulation using power tools to attach heat sensor directly on metal flue.B. Remove a small area of damaged insulation in order to attach heat sensor directly on

metal flue.








b. Scraper (1" [25 mm] wide blade)


d. Wire cutters

e. Power drill with dust collection collar attached to a HEPA vacuum.

f. Hole saw or drill bits

g. Glovebags

h. Non-ACM replacement insulation or patching material (if required)

i. Device to be installed and related tools






6. Place tools, equipment and materials needed into enclosure. If work must occurabove ceiling, include a HEPA vacuum outside of enclosure with hose and nozzleextending inside enclosure for use during the work.



a. Install duct tape around area to be penetrated or removed.


c. Remove all loose or damaged insulation using glovebag procedures. See generalprocedure W18.

d. Remove glovebag leaving duct tape from step “a” above.


a. Adequately wet material at area to be penetrated or removed.

b. Carefully remove or penetrate ACM using drill with dust collection collarattached to HEPA vacuum. This procedure must only be performed onadequately wet material, and with a HEPA vacuum nozzle adjacent to theremoval or penetrating tool so that any debris or fibers are captured by the HEPAvacuum.

10. Install device and repair/restore insulation around device. Restore vapor barrier oncold insulation and seal off to adjacent vapor barrier surfaces.

11. perform clean-up and tear-down steps on Level C checklist to complete work. Leaveduct tape installed in step 6 in place.


T8 . SummaryRemove asbestos-containing duct insulationabove ceiling for maintenance work

SummaryThis work practice describes theprocedures for removing small amounts ofasbestos-containing duct insulation abovea ceiling. Ceiling might be ACM or non-ACM. Ceiling might be plaster, drywallor lay-in.

Air conditioning supply ducts commonlycarry cooled air. After repairs, the vaporbarrier on the insulation must also berepaired to avoid condensation problems.

ExamplesLevel B: This example relies on the use of wetting as the primary asbestos control, augmented by

the use of a HEPA vacuum for local area exhaust. This may not work in allcircumstances. Work on amosite based insulations will be more successful if local areaexhaust using the HEPA vacuum is the primary means of asbestos control. In thisinstance the area might be dampened and the ACM removed using the nozzle of theHEPA vacuum as the tool. Other methods can also be affective. Some experimentationis necessary to see what works on insulations in a given facility.

OSHA allows work on TSI to be conducted as Class III rather than Class II work as longas a small amount of material is involved. Class III work requires the use of wetmethods, local exhaust ventilation (using a HEPA vacuum), and respirators. The O&Mdesigner must make a negative exposure assessment before these un-enclosed Level Bwork practices are used in the facility.

A. Remove small amount of damaged insulation around damper control to permitinsulation repair.

B. Replace a Variable Air Volume (VAV) box on ACM insulated duct.

Level C: This example relies on the use glove bags inside a mini-enclosure. The mini-enclosureprotects the environment, but not the workers. The glove-bag, is an engineering controlthat reduces airborne fiber levels and protect workers. Other methods such as wettingand HEPA vacuum use can also be affective. Some experimentation is necessary to seewhat works on the insulation in a given facility. Ideally the engineering controls will bedeveloped sufficiently that the PEL is not exceeded, and dust and debris are not spread bythe work. In this instance the mini-enclosure becomes insurance for the buildingenvironment against the failure of an engineering control.

A. Remove a small area of damaged duct insulation so that new branch lines can be tiedto existing duct system for sub-divided office space.

B. Remove a small area of delaminating duct insulation above lay-in ceiling.C. Remove a small area of delaminating duct insulation above plaster or drywall ceiling.



Related Work PracticesT 6 - Repair damaged asbestos-containing insulation on a boiler, duct or flueM 25 - Remove section of asbestos-containing drywall or plaster.

Worker Recommendations: Two workers. A person with air monitoring training might be required. This person canbe a worker.


T8 . Level BRemove asbestos-containing duct insulationabove ceiling for maintenance work


A. Remove small amount of damaged insulation around damper control to permitinsulation repair.

B. Replace a Variable Air Volume (VAV) box on ACM insulated duct.








d. Non-ACM replacement duct insulation





7. Pick up any bulk debris within reach on top of ceiling and place into disposal bag.


9. Wet insulation to be removed with amended water. Allow water to penetrate ACM. Add water until the material in the area to be removed is saturated.

10. Carefully remove saturated ACM while holding nozzle in vicinity of work.

11. After ACM is removed wet wipe surface of duct to remove all residue.

12. After drying, spray surface dust and edges where ACM was removed with apenetrating asbestos encapsulant.



13. Perform maintenance work and repair/restore insulation. Restore vapor barrier oncold insulation and seal off to adjacent vapor barrier surfaces.

14. Perform clean-up and tear-down steps on Level B checklist and ceiling access workpractice to complete work.


T8 . Level CRemove asbestos-containing duct insulationabove ceiling for maintenance work


A. Remove a small area of damaged duct insulation so that new branch lines can be tiedto existing duct system for sub-divided office space.

B. Remove a small area of delaminating duct insulation above lay-in ceiling.C. Remove a small area of delaminating duct insulation above plaster or drywall ceiling.











e. Glovebags, size and configuration as required




6. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuuminside enclosure for use during the work.



7. Obtain access above ceiling using appropriate O & M work practices.

8. Pick up bulk debris within reach on top of ceiling and place into disposal bag.


10. Install duct tape around area to be removed.

11. Place all tools needed inside glovebag and attach glovebag to duct tape around areaof duct insulation to be removed.

12. Remove ACM using glovebag procedures. See general procedures W18. Adequately wet removal area frequently during removal of bulk material.

13. Perform maintenance work and repair/restore insulation. Restore vapor barrier oncold insulation and seal off to adjacent vapor barrier surfaces.

14. Perform clean-up and tear-down steps on Level C checklist and ceiling access workpractice to complete work. Leave duct tape installed in step 8 in place.


T9 . SummaryRemove asbestos-containing insulationinside HVAC unit for maintenance work

SummaryThis work practice describes theprocedures to be used to remove smallamounts off asbestos-containing duct orpipe insulation inside an HVAC unit. Atthe completion of work this insulationmust be replace and any vapor barriersrestored to avoid condensation problems.

Asbestos-containing equipment insulationshould be designated as a “Controlled

System” that is contacted only by thosewho have had awareness training as aminimum. The inside of the HVAC unitshould be designated as a “ControlledArea.” Workers performing this workpractice should be familiar with theoperation and maintenance of the HVACunit and should have at least O&Mtraining with specific hands-on instructionin repair of duct insulation and lagging.

Examples





Level C: This example relies on the use of glove-bags as the primary asbestos control. This maynot work in all circumstances. Other methods can also be affective. Refer to other workpractices in this manual for examples that can be applied to this situation. Someexperimentation is necessary to see what works in a given facility.

A. Remove a small amount of ACM pipe insulation in poor condition inside HVACunit.



B. Remove a small amount of duct insulation as required to replace flexible connector.


maintenance workT 4 - Remove asbestos-containing insulation on pipe in occupied area for maintenance

workT 5 - Repair damaged asbestos-containing insulation on a pipeT 6 - Repair damaged asbestos-containing insulation on a boiler, duct or flueM 17 - Remove asbestos-containing flexible duct connector



T9 . Level BRemove asbestos-containing insulationinside HVAC unit for maintenance work


A. Remove no more than one 4 foot length of laminated corrugated paper pipeinsulation in good condition, where the insulation can be removed intact to replacecooling or heating coil.








d. Non-ACM replacement insulation














14. Perform maintenance work and replace/restore insulation. Restore vapor barrier oncold insulation and seal off to adjacent vapor barrier surfaces.



T9 . Level CRemove asbestos-containing insulationinside HVAC unit for maintenance work


A. Remove a small amount of ACM pipe insulation in poor condition inside HVACunit.

B. Remove a small amount of duct insulation required to replace flexible connector.











e. Glovebags



5. Place tools, equipment and materials needed onto drop sheet.

6. Install duct tape around area to be removed.

7. Place tools, equipment and other materials into glove bag. Attach glovebag to ducttape using more duct tape.



8. Remove all loose or damaged insulation using glovebag procedures. See generalprocedure W18.

9. Remove glovebag leaving duct tape from step above.

10. Perform maintenance work and replace/restore insulation. Restore vapor barrier oncold insulation and seal off to adjacent vapor barrier surfaces.

11. Perform clean-up and tear-down steps on Level C checklist to complete work. Leaveduct tape installed above in place.


T10 . SummaryClean up asbestos-containing debris incrawlspace or tunnel

SummaryThis work practice describes the workrequired to clean up small amounts ofasbestos-containing debris found in acrawlspace area or tunnel.

Crawl spaces and tunnels where there isACM thermal system insulation and/ordebris on the floor should be designated asa controlled area. Entry into the areashould be only by those who have at aminimum awareness training. The TSIand debris should be designated as“Controlled Systems” that is contactedonly by those who have had awarenesstraining as a minimum. Workersperforming this work practice should befamiliar with the facilities confined spaceentry program and should have at leastO&M training with specific hands-oninstruction in clean up of asbestos debris.

Crawl spaces and tunnels can be confinedspaces. Spaces such as crawl spaces maybe a permit required confined space duringthe heating system when steam pipes are

active, and a non-permit confined spaceduring the summer. An employer who hasemployees working in a confined space isrequired by OSHA to have a confinedspace entry program, and procedures forconfined space entry. The followingrefers to confined space entry proceduresfound elsewhere. As an alternativeconfined space entry procedures could beincluded in the work practice and the workpractice made a part of the confined spaceprogram.

This example presumes the existence of afloor. Many crawl spaces have dirt floors. There could also be localized flooding,low head height and other factors that willaffect the work practices. Revise asnecessary as required by conditions in thespecific facility. Refer to other workpractices in this manual for examples thatcan be applied to this situation. Someexperimentation is necessary to see whatworks in a given facility

Examples

Level B: A. Clean up several pieces of pipe insulation debris that can be picked up in intact piecesin a crawlspace

B. Clean up small amount of insulation debris that can be picked up in intact pieces in atunnel

Level C: A. Clean up of a small amount of deteriorated ACM debris that will disintegrate whenpicked up in a tunnel.

B. Clean-up of a small amount of deteriorated ACM debris that is mixed into soil in acrawl space.



Related Work PracticesT 1 - Remove asbestos-containing insulation on exposed pipe for maintenance workT 5 - Repair damaged asbestos-containing insulation on a pipeT 6 - Repair damaged asbestos-containing insulation on a boiler, duct or flue

Worker Recommendations:Two workers due to confined space safety concerns. A person with air monitoringtraining might be required. This person can be a worker.


T10 . Level BClean up asbestos-containing debris incrawlspace or tunnel


A. Clean up several pieces of pipe insulation debris in crawlspaceB. Clean up small amount of insulation debris in tunnel


Asbestos-containing pipe insulation is a “Controlled System.” Do not contact or disturbpipe insulation unless you have been authorized by facility management. The Crawlspace is a “Controlled Space.” Do not enter the crawl space without authorization

The crawl space is a confined space. You must have had training in confined space entrybefore entering crawl space. If you have not had confined space entry training, do notenter crawl space, and notify your supervisor. If you have had Confined Space training,review confined space requirements with APM before start of work.




3. If the area where work is to be performed is a confined space, follow the facility’sconfined space entry procedures. These procedures are in addition to the proceduresin this work practice.


5. Place tools, equipment and materials needed into work area. One worker shouldremain outside to communicate with inside worker and handle rescue arrangements,if needed.

6. Adequately wet floor area and debris in work area.

7. Starting near entry to area and working toward rear of area, pick up pieces of debrisand place into disposal bags.

8. Adequately wet areas where debris was removed. Use HEPA vacuum to remove anyremaining debris. Place debris into disposal bags. HEPA vacuum floor after grossdebris is removed.


T10 . Level CClean up asbestos-containing debris incrawlspace or tunnel


A. Clean up a small amount of deteriorated ACM debris that will disintegrate whenpicked up in a tunnel.

B. Clean-up a small amount of deteriorated ACM debris that is mixed into soil in acrawl space.

Notes Asbestos-containing pipe insulation is a “controlled system.” Do not contact or disturbpipe insulation unless authorized by facility management. Crawl space is a “ControlledArea.” Do not enter crawl space without authorization.




The crawl space is a confined space. You must have had training in confined space entrybefore entering crawl space. If you have not had confined space entry training, do notenter crawl space, and notify your supervisor. If you have had Confined Space training,review confined space requirements with APM before start of work.


2. Tools, equipment and materials:a. Tools as needed from the lists in General Procedure W1


4. If the area where work is to be performed is a confined space, follow the facility’sconfined space entry procedures. These procedures are in addition to the proceduresin this work practice.




6. One worker should remain outside to communicate with inside worker and handlerescue arrangements if needed. Prepare work area with mini-enclosure (withoutfloor) and set up negative pressure system and/or local exhaust ventilation accordingto General Procedure W20 “Mini-Enclosure

7. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuuminside enclosure.

8. Adequately wet floor area and debris inside enclosure.

9. Starting near entry to area and working toward rear of area, pick up pieces of debrisand place into disposal bags.

10. Adequately wet areas where debris was removed. Use HEPA vacuum to removeany remaining debris. Place debris into disposal bags. HEPA vacuum floor aftergross debris is removed.


VI. Miscellaneous MaterialsWork Practices

M - 3 # Miscellaneous ACM # Asbestos O&M Work Practices # © NIBS 1996 # Page 235

Section VI. Miscellaneous Materials Work PracticesWork Practices Location Illustration . . . . . . . . . . . . . . . . . . . . . . . . . . . 235Code Levels DescriptionM 1 A B Clean potentially asbestos-contaminated carpet . . . . . . . . . . . . . . . . . . . 240M 2 A B C Remove asbestos-containing ceiling panels in lay-in ceiling system . . . 243M 3 B C Remove asbestos-containing ceiling tiles attached with adhesive . . . . . 247M 4 B C Remove asbestos-containing ceiling tiles in spline ceiling system . . . . . 250M 5 B C Cut or drill asbestos cement panels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 253M 6 A B C Remove asbestos cement panels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 257M 7 A B Remove asbestos cement cooling tower louvers . . . . . . . . . . . . . . . . . . . 261M 8 A B Remove or replace asbestos cement roof shingles . . . . . . . . . . . . . . . . . 264M 9 A B Remove and replace asbestos cement siding shingles . . . . . . . . . . . . . . 269M 10 A B C Remove high-temperature resistant (HTR) asbestos cement panels . . . . 272M 11 A B C Remove asbestos-containing chalk board . . . . . . . . . . . . . . . . . . . . . . . . 276M 12 A B C Remove asbestos-containing fire door and/or door hardware . . . . . . . . . 280M 13 A B Remove asbestos-containing built-up roofing . . . . . . . . . . . . . . . . . . . . 285M 14 A B Remove asbestos-containing asphalt shingles . . . . . . . . . . . . . . . . . . . . 289M 15 B C Cut or drill asbestos-containing drywall, plaster or drywall compound . 294M 16 B C Remove section of asbestos-containing drywall . . . . . . . . . . . . . . . . . . 300M 17 A B C Remove asbestos-containing flexible duct connector . . . . . . . . . . . . . . 305M 18 A B C Remove asbestos-containing paper or cloth from ductwork . . . . . . . . 310M 19 B Remove filters from HVAC unit . . . . . . . . . . . . . . . . . . . . . . . . . . . . 315M 20 B Clean up debris . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 317M 21 A B C Replace asbestos-containing gaskets/packing . . . . . . . . . . . . . . . . . . . . 320M 22 B C Emptying and changing filter in HEPA vacuum or changing filter in

HEPA fan unit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 328M 23 A B C Remove asbestos-wrapped wiring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 332M 24 A B C Removing asbestos-containing caulking/glazing compound . . . . . . . . 339M 25 A Clean room that has asbestos-containing dust . . . . . . . . . . . . . . . . . . . 343

Figure 10 illustrates typical applications of these work practices.

General NotesMany of the miscellaneous materials in this section are non-friable. These materials aretreated differently from friable materials (surfacing and TSI) by both OSHA andNESHAP.

OSHA

Work under this section is governed bythe OSHA construction standard (29 CFR1926.1101. The work is either Class II fornon-friable materials, and Class III forfriable and small quantities of non-friablematerials. O&M work practices must bedesigned to comply with these

requirements.

Class II: OSHA defines work on non-friable materials as Class II work. Insection (g) of the construction standard(29 CFR 1926.1101) OSHA sets forthgeneral “methods of compliance” for


Class II work as supervision by acompetent person, impermeabledropcloths, HEPA vacuums, wet methodsand prompt clean up. If there is noNegative Exposure Assessment thencritical barriers or some other barrier orisolations method must also be used. Inaddition, there are specific requirementsfor work on resilient flooring; roofing;siding, shingles, and transite (cementasbestos panels); and gaskets. In addition,OSHA gives specific requirements forintact roofing materials (roof cements,mastics, coatings, or flashings) that,“contain asbestos fibers encapsulated orcoated by bituminous compounds.” In theCompliance Directive(CPL 2-2.63) in thedefinition of Class II work, OSHA allowsClass II work that removes no morematerial than will fit in a 60" disposal bagto be classified as Class III work.

OSHA allows considerable flexibility inthe design of work practices, as long asairborne fiber levels are maintained belowthe OSHA PEL. If the work is consideredas Class II, under requirements for Class IIwork OSHA allows the use of“Alternative Work Practices and Controls”as long as worker exposures will notexceed the PELs. 29 CFR1926.1101(g)(8)(vi) requires that “thedifferent or modified controls reducedirect and indirect employee exposure tobelow the PELs under all expectedconditions of use and that the methodmeets the requirements of this [sic. theOSHA] standard.” To meet thisrequirement, the controls developed by theO&M designer must reliably keepairborne fiber levels below the PELs. Thework area where these controls are to beapplied must be evaluated by a competentperson.

Class III: Work on a small quantity ofnon-friable miscellaneous materials for

maintenance purposes can be Class III. OSHA allows Class II work that removesno more material than will fit in a 60"disposal bag to be classified as Class IIIwork. In section (g) of the constructionstandard (29 CFR 1926.1101) OSHA setsforth general “methods of compliance” forany work as HEPA vacuums, wet methodsand prompt clean up. In addition Class IIIwork must performed using wet methodsand local exhaust ventilation. If there isno Negative Exposure Assessment thenthe work area must be contained withimpermeable dropcloths and sheet plasticbarriers or their equivalent. If the workinvolves, “drilling, cutting, abrading,sanding, chipping, breaking, or sawing,”then impermeable dropcloths and mini-enclosures, glovebags or another isolationmeasure are required. Respirators arerequired if the work is on surfacing or TSIor if there is no negative exposureassessment.

Both class II and Class III requirementsallow open work practices as long asairborne fiber levels are maintained belowthe PELs. A great deal of the effort ofdesigning work practices formiscellaneous materials will center aroundmaking a negative exposure assessment. Refer to the introduction for moreinformation on making an NEA. TheO&M program designer should becomefamiliar with the OSHA requirements forClass II and Class III work as set forth inthe construction standard (29 CFR1926.1101) with amplifications andexplanations in the Compliance Directive(CPL 202.63, November 3, 1995)


DESIGNING and IMPLEMENTING WORK PRACTICES

An O&M program will be easier and morepractical to implement and more costefficient if it is designed so that themajority of work can be performedwithout enclosures. For this to happen,each work practice needs to be developedto the point that there is no airborneexposure to asbestos (as defined byOSHA). In terms of the OSHAconstruction standard this means that aNegative Exposure Assessment (NEA)must be made.

The work practices given in this manualare examples of procedures that aretypically useable for the situationsdescribed. The level of training,experience and skill of the staffperforming the work, and the exact type ofmaterial and material conditions will varyfrom facility to facility. The O&Mdesigner needs to adjust the work practicesin the example to work for the specificmaterials and workers in a facility.

Level A: Level A work proceduresinvolve work that contacts, but does notdisturb asbestos-containing materials(ACM).

! Design: Non-friable materials cansurvive fairly high impacts withoutbeing disturbed. However, thedesigner should determine if thesurface characteristics of the materialare such that asbestos could bereleased from the surface upon contacteven if the matrix of the material isnot disturbed. For example: cementasbestos board can weather under acidrain to the extent that asbestos can bereleased from the surface by contacteven though the panel ispredominantly non-friable. As LevelA procedures are open, a negativeexposure assessment is necessary.

Workers performing Level A tasksneed to have more than awarenesstraining. Workers involved withroofing, siding, ceiling tiles, andtransite need to have a minimum of 8hours of training per category ofmaterial. Work on other materialsrequires training in general asbestosissues (paragraph (k)(9)(viii) of theconstruction standard), as well asspecific work practices andengineering controls including “hand-on” training.

! Implementation: Worker should reportback to the APM any changes in thecondition of materials or otherchanges that could dictate a change incontrol strategies.

Level B: Level B work proceduresinvolve work that disturbs ACM, but thatuse work procedures that control therelease of asbestos well enough so that thework can be performed in the open. Tocomply with OSHA requirements, thisrequires certification under Class IIrequirements and a Negative Exposureassessment.

! Design: During design of the workpractice the O&M designer (who mustbe a competent person) needs to eithermake the determination that airbornefiber levels during the use of the workpractice will not exceed the OSHAPELs required for an alternative ClassII work practice, and should also makea negative exposure assessment. Underthe Class II requirements the designermust certify in writing that use of thework practice will, “reduce direct andindirect employee exposure to belowthe PELs under all expected conditionsof use,” and that the work practicemeets the requirements of the OSHA


standard. The requirements for anNEA are described in the introduction. Both the certification and NEA arebased on exposure monitoring.

Several of the Level B work practicesin this section offer examples that relyon an, “another isolation method” fordrilling ACM. This is generallyaccomplished by the use of a collararound the drill that is attached to aHEPA vacuum. Used properly this canisolate the site of the drilling to thesame extent as a mini-enclosure orglovebag, but in a much more portableand worker friendly manner. Theability of the HEPA collar to isolate thedrilling needs to be demonstratedduring design of the work practice by anegative exposure assessment. Duringtesting of the work practice it would beprudent for the designer to perform thework inside of an enclosure such as amini-enclosure. Under nocircumstances should this be attemptedinside of a glovebag. The use of powertools inside a glovebag is dangerousdue to poor visibility and a highprobability of catching the tool in theplastic of the bag. There are severalother isolation methods known tomembers of the project committeeincluding drilling through shavingcream or a wet sponge, slowly hand

drilling sodden material, and using thenozzle of HEPA vacuum for local areaexhaust. The designer may want to trythese techniques during development ofthe O&M.

! Implementation: Each time that workis assigned the asbestos programmanager (APM) (who must also be acompetent person) must evaluate thework area make a determination thatthe conditions at the specific job siteare equivalent to those that existingduring development of the workpractice, so that the work practice isapplicable.

Level C: Level C work proceduresinvolve work that disturbs ACM, andduring which the PELs could be exceededor where, “drilling, cutting, abrading,sanding, chipping, breaking, or sawing,” isoccurring.

! Design: Initial monitoring needs to beconducted to determine whatrespiratory protection and other workerprotection requirements will be.

! Implementation: Periodic monitoringmust be performed to validate theselection of respiratory protection.

NESHAP

The NESHAP regulates the disposal ofACM. Non-friable materials are treateddifferently from friable materials such assurfacing materials and thermal systeminsulation. Most miscellaneous (non-friable) materials are classified by theEPA NESHAP as Category 1 non-friableACM. If Category I ACM has becomefriable, or will become friable, or has been

or will be subjected to sanding, grinding,cutting or abrading, it is defined asRegulated ACM by NESHAP, and itswetting, labeling and disposalrequirements apply. State and localregulations may have differentrequirements, and these may be morestringent.


WORK PRACTICES:

Careful work practices should be theprimary means used to prevent releases ofasbestos fibers during O&M work. Suchpractices include control measures such aswetting and local exhaust that control orcollect fibers at the source. The goal of allasbestos O&M work should be to preventany exposure of the worker andunnecessary contamination of the workarea, drop cloths, mini-enclosures or othersecondary control devices. Mini-enclosures should never be used to excusesloppy work or creation of "bigger"messes.

Drilling: The OSHA regulation requiresthat drilling be isolated by an enclosure. However, the work practices in thissection offer several alterative isolationmethods that the O&M designer may wantto experiment with. CAUTION: beforethese procedures are used, the O&Mdesigner must demonstrate that they are aseffective at isolating the drilling as anenclosure. This is accomplished with anegative exposure assessment. ! A wet sponge can be used where small

holes must be drilled in ACM. Thesponge can be held over the locationwhere the hole is needed and the holecan be drilled through the wet sponge. The sponge should help to keep anydust or debris wet.

! The hose of an operating HEPAvacuum can be placed near the cuttingpoint of a drill bit or other tools.

! Shaving cream can be sprayed over anarea where ACM will be cut or drilledto contain dust or debris. Any shavingcream used in this manner should bedisposed of as ACM after use.

! Tools with HEPA filtered dustcollection attachments.

Glovebag removal procedures asdescribed in General Procedure W18 maybe appropriate for use in certain smallO&M tasks involving miscellaneousACM, such as the removal of a small areaof AC plaster where an enclosure isdesired, changing the bag in a HEPAvacuum or removing a small amount ofductwork taping cloth.

If the O&M activity involves work onmaterials (such as asbestos cement board)that might have chemical residue present,either the residue will need to be properlyremoved prior to the start of the O&Mwork, or the O&M work will have to beperformed dry. If dry removal isnecessary, local exhaust ventilation andcareful handling will need to be relied onto maintain airborne fiber levels withinsatisfactory limits. This approach wouldneed to be validated during design of theO&M program. Cleaning might benecessary to reduce the possibility of achemical reaction that could be caused bywater, surfactants and/or other substancesmixing with chemical residues duringO&M work.

M - 8 # Miscellaneous ACM # Asbestos O&M Work Practices # © NIBS 1996 # Page - 240

M1 . SummaryClean potentially asbestos-contaminatedcarpet

SummaryThis work practice describes the O&Mprocedures that can be used to substituteHEPA vacuuming of carpeting for normalvacuuming. This can be useful insituations where there could be a smallperiodic release from an ACM (e.g. in aroom that has a soft acoustical finish thatis within reach of the occupants and maybe contacted upon occasion). Thisprocedure can also be used for cleaningsmall areas of asbestos-contaminatedcarpet. If contamination is present due toa fiber release, see work practice M20.

Note: EPA's Green Book indicates thatroutine use of a special cleaning workpractice is not required if asbestos-containing dust or debris is not presentand deterioration or damage to ACM isunlikely. While NIBS is notrecommending its use as a routinemandatory asbestos control procedure inthis case, the Level A work practice isbeing provided for those operations andmaintenance programs which choose touse it.

ExamplesLevel A: A. Clean potentially asbestos-contaminated carpet that has no visible contamination or

analytical confirmation of asbestos contamination. ACM in room is in goodcondition.

Level B: A. Clean carpet that has some visual or analytical evidence of asbestos contamination.

Related Work PracticesR 3 Install new resilient flooring or carpet over resilient asbestos flooring.R 8 Remove carpet over resilient asbestos flooring.

Worker Recommendations One worker. A person with air monitoring training might be required. This person canbe the worker.


M1 . Level AClean potentially asbestos-contaminatedcarpet

ExampleThe following is an example of work that can be performed using the procedures of thisLevel A work practice. If job conditions vary from the example stop work and notifyyour supervisor.

A. Clean potentially asbestos-contaminated carpet that has no visible contamination oranalytical confirmation of asbestos contamination. ACM in room is in goodcondition

NotesA Negative Exposure Assessment must have been made by a Competent Person beforethis work practice is used. Verify that a negative exposure assessment (NEA) has beenmade. If an NEA cannot be verified, stop work and notify your supervisor.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Carpet attachment for HEPA vacuum

3. HEPA vacuum carpet using carpet attachment. Use Work Practice M22 ifHEPA vacuum needs maintenance, or if bag or filter needs to be replaced.

4. Perform applicable steps on Level A checklist to complete work.


M1 . Level BClean potentially asbestos-contaminatedcarpet


A. Clean carpet that has some visual or analytical evidence of asbestos contamination.





b. HEPA vacuum with beater bar or carpet steam cleaning equipment.



5. Place tools, equipment and materials needed into work area.

6. Clean carpet using one of the following procedures:

a. With HEPA vacuum, vacuum contaminated area in parallel passes with each passoverlapping the previous by one half the width of the beater bar. Vacuum thearea a second time, in the same manner, in passes at right angles to the firstpasses.

b. With steam cleaning equipment, clean carpet in accordance with manufacturer'sequipment instructions. Clean in overlapping passes in one direction, and then asecond time in overlapping passes at right angles to the first passes. Water fromcleaning operation shall be disposed of in accordance with applicable regulations. See General Procedure W19.



M2 . SummaryRemove asbestos-containing ceiling panels inlay-in ceiling system

SummaryThis work practice covers the procedure for removing a small number of asbestos-containing ceiling panels in a lay-in ceiling system, such as a 2' x 4' or 2' x 2' (600 x 1200mm or 600 x 600 mm) suspended ceiling for O&M work. The practices assume thatsurfacing ACM is not present above the ceiling. If surfacing is present, see work practiceS1.

Examples

Level A: A. Move one or several panels in good condition that do not offer resistance to beingmoved, and where edges do not abrade.

Level B: A. Remove several asbestos-containing ceiling panels to perform maintenance work onor above ceiling where the panel(s) offer resistance to being moved and/or the edgesare or will be abraded.

Level C: A. Remove several damaged, broken, or soiled asbestos-containing ceiling panels aloneor in conjunction with maintenance work above ceiling.

Related Work PracticesS 1 Move one non-asbestos-containing ceiling panel below a plenum space that has

exposed surfacing ACM.M 3 Replace asbestos-containing ceiling tiles attached with adhesive.M 4 Replace asbestos-containing ceiling tiles in spline ceiling system.

Worker Recommendation One worker for Level A work. One or two workers for Level B depending upon safetyand efficiency considerations. Two workers for Level C. A person with air monitoringtraining might be required. This person can be a worker.


M2 . Level ARemove asbestos-containing ceiling panels inlay-in ceiling system


A. Move one or several panels in good condition that do not offer resistance to beingmoved, and where edges do not abrade.


Coordinate work with O & M Work Practice S1 if surfacing ACM is present aboveceiling.

Use Work Practice M22 if HEPA vacuum needs maintenance, or if bag or filter needs tobe replaced.




b. Non-asbestos replacement ceiling panels, if needed.



5. Set up ladder or scaffold in work area.

6. If panel will be replaced, remove ceiling panel and place into disposal bag. If panelwill be reinstalled, remove carefully and store for reinstallation.

7. HEPA vacuum area where tile was installed and any suspension system componentsexposed where tile was removed.

8. Perform maintenance work and reinstall existing panels or install new panels.



M2 . Level BRemove asbestos-containing ceiling panels inlay-in ceiling system

Example The following are examples of work that can be performed using the procedures of thisLevel B work practice. If job conditions vary from the examples stop work and notifyyour supervisor.

A. Remove several asbestos-containing ceiling panels to perform maintenance work onor above ceiling where the panel(s) offer resistance to being moved and/or the edgesare or will be abraded.






b. Stiff nylon bristle brushes

c. Non-asbestos replacement ceiling panels, if needed



5. Place tools, equipment and materials needed onto drop cloth. Set up ladder orscaffold and adequately wet ceiling panel(s), if panel(s) will be replaced.

6. If panel(s) will be replaced, remove ceiling panel(s) and place into disposal bag. Ifpanel(s) will be reinstalled, remove carefully and store for reinstallation.

7. HEPA vacuum area where panel(s) were installed. Wet wipe any suspension systemcomponents exposed where panel(s) were removed. Use brushes to remove anydebris that is not removed by wet wiping. Place wet wipes and any debris intodisposal bags.



M2 . Level CRemove asbestos-containing ceiling panels inlay-in ceiling system


A. Remove several damaged, broken, or soiled asbestos-containing ceiling panels aloneor in conjunction with maintenance work above ceiling.

NotesCoordinate work with O & M Work Practice S1 if surfacing ACM is present aboveceiling.




b. Stiff nylon bristle brushes

c. Non-asbestos replacement ceiling panels, if needed





7. Enter enclosure

8. Set up ladder or scaffold inside enclosure.

9. Adequately wet ceiling panel(s) and remove.

10. HEPA vacuum area where panel(s) were installed. Wet wipe any suspension systemcomponents exposed where panel(s) were removed. Use brushes to remove anydebris that is not removed by wet wiping. Place wet wipes and any debris intodisposal bags.



M3 . SummaryRemove asbestos-containing ceiling tilesattached with adhesive

SummaryThis work practice covers the O&M procedures for removing a small number of asbestos-containing ceiling tiles attached with adhesive. These most commonly are 12" (13 mm)tiles glued to a substrate such as gypsum board or plaster. The procedures assume thatthe tile adhesive does not contain asbestos.

ExamplesLevel B: A. Remove several ceiling tiles that can be removed as whole tiles without breakage.

Small pieces of tile may remain attached to adhesive on ceiling.

Level C: A. Remove several ceiling tiles that will break during removal.B. Remove several badly damaged ceiling tiles.

Related Work PracticesM 2 Remove asbestos-containing ceiling panels in lay-in ceiling system.M 4 Remove asbestos-containing ceiling tiles in spline ceiling system.M 16 Remove section of asbestos-containing drywall.

Worker Recommendations One or two workers for Level B depending upon safety and efficiency considerations. Two workers for Level C. A person with air monitoring training might be required. Thisperson can be a worker.


M3 . Level BRemove asbestos-containing ceiling tilesattached with adhesive


A. Remove several ceiling tiles that can be removed as whole tiles without breakage. Small pieces of tile may remain attached to adhesive on ceiling.





b. Non-asbestos replacement ceiling panels and adhesive

c. Scraper or other tools as needed to remove tiles




6. Set up ladder or scaffold on drop cloth.

7. Adequately wet ceiling tiles to be removed.

8. Cut away outer ½" (13 mm) of tile on tongue and grove edges. Pry tile away fromsubstrate to break adhesive bond, remove ceiling tiles and place into disposal bags.

9. HEPA vacuum area where tiles were installed. Wet wipe any smooth finishedcomponents exposed where tiles were removed. Use scraper to remove anyremaining adhesive or debris.

10. Install new ceiling tiles and perform clean-up and tear-down steps on Level Bchecklist to complete work.


M3 . Level CRemove asbestos-containing ceiling tilesattached with adhesive


A. Remove several ceiling tiles that will break during removal.B. Remove several badly damaged ceiling tiles.




b. Non-asbestos replacement ceiling panels and adhesive

c. Scraper or other tools as needed to remove tiles





7. Enter enclosure

8. St up ladder or scaffold inside enclosure.


10. Cut away outer ½" (13 mm) of tile on tongue and grove edges. Pry tile away fromsubstrate to break adhesive bond, remove ceiling tiles and place into disposal bags.

11. HEPA vacuum area where tiles were installed. Wet wipe any smooth finishedcomponents exposed where tiles were removed. Use scraper to remove anyremaining adhesive or debris. Place wet wipes and debris into ACM disposal bags.

12. Install new ceiling tiles and perform clean-up and tear-down steps on Level Cchecklist to complete work.


M4 . SummaryRemove asbestos-containing ceiling tiles inspline ceiling system

SummaryThis work practice covers the O&M procedure for removing small numbers of asbestos-containing ceiling tiles in a spline ceiling system. Procedures assume that tile adhesivedoes not contain asbestos.

ExamplesLevel B: A. Remove several tiles that can be removed as whole tiles without breakage.

Level C: A. Remove several ceiling tiles that will break during removal.B. Remove several badly damaged ceiling tiles.

Related Work PracticesM 2 Remove asbestos-containing ceiling panels in lay-in ceiling system.M 3 Remove asbestos-containing ceiling tiles attached with adhesive.M 24 Remove section of asbestos-containing drywall.

Worker Recommendations One or two workers for Level B depending upon safety and efficiency considerations. Two workers for Level C. A person with air monitoring training might be required. Thisperson can be a worker.


M4 . Level BRemove asbestos-containing ceiling tiles inspline ceiling system


A. Remove several tiles that can be removed as whole tiles without breakage.






b. Non-asbestos replacement ceiling panels and straight pins




6. Set up ladder or scaffold and adequately wet ceiling tiles to be removed.

7. Cut away outer ½" (13 mm) of tiles on edges set on splines. Remove ceiling tiles andplace into disposal bags.

8. HEPA vacuum area where tiles were installed. Wet wipe any suspension systemcomponents exposed where tiles were removed.

9. Install new tiles using pins into adjacent tiles to secure in place.



M4 . Level CRemove asbestos-containing ceiling tiles inspline ceiling system


A. Remove several ceiling tiles that will break during removal.B. Remove several badly damaged ceiling tiles.

NotesCoordinate work with O & M Work Practice S1 if surfacing ACM is present aboveceiling.




b. Non-asbestos replacement ceiling panels and straight pins





7. Enter enclosure

8. Set up ladder or scaffold inside enclosure.


10. Cut away outer ½" (13 mm) of tiles on edges set on spline. Remove ceiling tiles andplace into disposal bags.

11. HEPA vacuum area where tiles were installed. Wet wipe any smooth finishedcomponents exposed where tiles were removed.

12. Install new tiles using pins into adjacent tiles to secure in place.



M5 . SummaryCut or drill asbestos cement panels

SummaryThis work practice covers the procedures cutting or drilling asbestos cement panels.

ExamplesLevel B: OSHA requires that during Class III (O&M) operations that involve, “drilling, cutting,

abrading, sanding, chipping, breaking, or sawing of thermal system insulation orsurfacing materials, the employer shall use impermeable dropcloths, and shall isolate theoperation using mini-enclosures or glove bag systems ...or another isolation method.” This work practice relies on the HEPA exhausted collar on the drill as, “another isolationmethod.” During design of the O&M program the designer must be a competent personand must determine that the use of the HEPA exhausted collar as described in the workpractice effectively isolates the drilling work. This evaluation should be based on an,“Initial exposure assessment,” leading to a “Negative Exposure Assessment,” (NEA) asdescribed in the OSHA construction standard 29 CFR 1926.1101(f)(2). Duringimplementation of the program, the APM must also be a competent person, and mustmake a determination that conditions at a specific job site are equivalent to those thatexisting during development of the work practice, so that the work practice is applicable. The work order issued to the person performing the work should inform them of the NEAand any conditions that are attached to the NEA. It is possible that after there has beensome experience with the OSHA regulation the manufacturers of the type of equipmentused in this work practice will make the proper evaluations and submissions to OSHAand provide a copy of this to the O&M program designer. In any case as a minimumrequirement the supervisor that assigns work to maintenance staff should be a competentperson able to evaluate the applicability of a dust collection collar with HEPA vacuum toa particular situation.

A. Drill a few holes in an asbestos cement board to install a new electrical panel.

Level C: A. Cut or drill a few holes in an asbestos cement panel to install a vent through panelusing power tools.

Related Work Practices M 6 Remove asbestos cement panels.M 15 Cut or drill asbestos-containing drywall or drywall compound.

Worker Recommendation One worker for Level B. Two workers for Level C. A person with air monitoringtraining might be required. This person can be a worker.


M5 . Level BCut or drill asbestos cement panels


A. Drill a few holes in an asbestos cement board to install a new electrical panel.

NotesA Negative Exposure Assessment must have been made by a Competent Person beforethis work practice is used. Verify that a negative exposure assessment (NEA) has beenmade. If an NEA cannot be verified, stop work and notify your supervisor




b. Hand or power drill equipped with a HEPA vacuum dust collection attachment.



5. If accessible, install a drop cloth on the back side of the panel below where hole willpenetrate through panel.


7. Adequately wet both sides of area to be drilled using garden sprayer with amendedwater. Keep water away from any electrical cords or equipment.

8. Drill hole using hand drill or power drill with operating HEPA vacuum attached. Wet drilling area using amended water.

9. As options, the following wetting methods/controls may be used:a. For small holes, a wet sponge can be placed on both sides of the surface and the

hole drilled through the sponges.b. A HEPA vacuum hose may be used near the bit of a non-HEPA equipped drill,

and on the back side if accessible.c. Shaving cream can be sprayed on both sides of the drilling area to control dust

and debris. Shaving cream must be wiped up and disposed of as ACM.

10. Wipe debris off drill using wet disposable towels and place towels into disposal bag

11. If back side was enclosed, insert wand of garden sprayer with amended water intoback side enclosure and wet dust or debris. Remove back side enclosure and placeinto disposal bag. Wet wipe surfaces that were exposed inside back side enclosure.



M5 . Level CCut or drill asbestos cement panels


A. Cut or drill a few holes in an asbestos cement panel to install a vent through panelusing power tools.




b. Hand or power drill equipped with a HEPA vacuum dust collection attachment.




6. If accessible, enclose back side of panel to catch dust and debris where hole willpenetrate through panel.


8. Enter enclosure and adequately wet both sides of area to be cut or drilled usinggarden sprayer with amended water. Keep water away from any electrical cords orequipment.

9. Cut or drill hole(s) using saw or drill. Power tools should have an operating HEPAvacuum attached. Wet cutting area during drilling or cutting using amended water.

10. As options, the following wetting methods/controls may be used:

a. For small holes, a wet sponge can be placed on both sides of the surface and thehole drilled through the sponges.

b. A HEPA vacuum hose may be used near the bit of a non-HEPA equipped drill,and on the back side if accessible.

c. Shaving cream can be sprayed on both sides of the drilling area to control dustand debris. Shaving cream must be wiped up and disposed of as ACM.

11. Remove panel piece and wet wipe debris off drill or saw using wet disposable towelsand place towels and debris into disposal bag.

12. If back side was enclosed, insert wand of garden sprayer with amended water intoback side enclosure and wet dust or debris. Remove back side enclosure and placeinto disposal bag. Wet wipe surfaces that were exposed inside back side enclosure.

M5 . Level C ...continued




M6 . SummaryRemove asbestos cement panels

SummaryThis work practice covers the procedures for removing a small number of asbestoscement panels to support O&M work. This procedure can be used for asbestos cementrange hoods.

ExamplesLevel A: A. Remove several corrugated or flat asbestos cement panels that are painted or in good

condition, and have fasteners that can be easily removed.

Level B: A. Remove several corrugated or flat asbestos cement panels in fair condition.

Level C: A. Remove several corrugated or flat asbestos cement panels in poor condition whichhave become friable and where dust or powder may be generated during removal.

Related Work PracticesM 5 Cut or drill asbestos cement panels.

M 12 Remove asbestos-containing fire door.

Worker Recommendations One worker for Level A and Level B. Two workers for Level C. Panel size maynecessitate two or more workers. A person with air monitoring training might berequired. This person can be a worker.


M6 . Level ARemove asbestos cement panels


A. Remove several corrugated or flat asbestos cement panels that are painted or in goodcondition, and have fasteners that can be easily removed.





b. Tools as needed to remove panel fasteners (slatter's ripper, nail clipper,screwdriver)



5. Adequately wet panels to be removed with amended water. Remove fastenersholding panel in place. Clean fasteners if they are to be reused. Dispose of fastenersas ACM if not being reused.

6. Remove panel and wrap in two (2) layers of polyethylene sheet for disposal as ACM.

7. Perform maintenance work and clean-up and tear-down steps on Level A checklist tocomplete work.


M6 . Level BRemove asbestos cement panels


A. Remove several corrugated or flat cement asbestos panels in fair condition.

NotesA Negative Exposure Assessment must have been made by a Competent Person beforethis work practice is used. Verify that a negative exposure assessment (NEA) has beenmade. If an NEA cannot be verified, stop work and notify your supervisor

If activated electrical equipment is in work area, do not wet, stop work, and notify yoursupervisor.




b. Tools as needed to remove panel fasteners (slatter's ripper, nail clipper,screwdriver)




6. Adequately wet panel(s) to be removed using garden sprayer with amended water.

7. Remove fasteners holding panel in place. HEPA vacuum and wet fasteners as theyare removed. Clean fasteners using water if they are to be reused. Dispose offasteners as ACM if not being reused.

8. Remove panel and wrap in two (2) layers of polyethylene sheet for disposal as ACM.

9. HEPA vacuum and wet wipe surfaces to which panel was attached. HEPA vacuumand wet wipe up any dust or debris from panel removal.



M6 . Level CRemove asbestos cement panels


A. Remove several corrugated or flat asbestos cement panels in poor condition which havebecome friable and where dust or powder may be generated during removal.

NotesIf activated electrical equipment is in work area, do not wet, stop work, and notify yoursupervisor.




b. Tools as needed to remove panel fasteners (slatter's ripper, nail clipper,screwdriver





7. Enter enclosure and adequately wet panel(s) to be removed using garden sprayer withamended water.

8. Remove fasteners holding panel in place. HEPA vacuum and wet fasteners as theyare removed. Clean fasteners using water if they are to be reused. Dispose offasteners as ACM if not being reused.

9. Remove panel and wrap in two (2) layers of polyethylene sheet for disposal as ACM. If panel breaks or chips and small debris results from removal, collect and dispose ofin disposal bags or containers.

10. HEPA vacuum and wet wipe surfaces to which panel was attached. HEPA vacuumand wet wipe up any dust or debris from panel removal.



M7 . SummaryRemove asbestos cement cooling towerlouvers

SummaryThis work practice covers the procedures for asbestos cement cooling tower louvers.

Examples

Level A: A. Remove several asbestos cement cooling tower louvers in good condition.

Level B: A. Remove several asbestos cement cooling tower louvers in poor condition, abraded orseverely weathered.

Related Work PracticesM 6 Remove asbestos cement panels.

Worker Recommendations One worker. Two or more for large panels or elevated work areas. A person with airmonitoring training might be required. This person may be a worker.


M7 . Level ARemove asbestos cement cooling towerlouvers


A. Remove several asbestos cement cooling tower louvers in good condition.


Turn off cooling tower fan, tag, and lock-out switch in accordance with facility’s Lock-Out Tag-Out program before performing this work practice.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Tools as needed to remove louversc. Non-asbestos replacement louvers



5. Verify that cooling tower is shut off and locked out.

6. Remove any fasteners holding louvers in place. HEPA vacuum and wet fastenersduring removal. Clean fasteners for reuse or dispose of as ACM.

7. Wet louvers with amended water. Remove louvers without breaking and place theminto disposal bags as they are removed. If louvers are too big for a disposal bag, laydown a double sheet of 6 mil polyethylene. Stack louvers on sheet. After 6 louversare stacked wrap in polyethylene sheet for disposal. Candy strip wrapped louverswith duct tape. Do not drop removed louvers to the ground, carry down all removedmaterials by the end of the shift.

8. Wet wipe and/or HEPA vacuum surfaces louvers were contacting and any dust ordebris from louver removal. Use Work Practice M22 if HEPA vacuum needsmaintenance, or if bag or filter needs to be replaced.



M7 . Level BRemove asbestos cement cooling towerlouvers


A. Remove several asbestos cement cooling tower louvers in poor condition.


Turn off cooling tower fan, tag, and lock-out switch in accordance with facility’s Lock-Out Tag-Out program before performing this work practice.

Work Practice1. Perform Pre-work activities on Level B checklist.2. Tools, equipment and materials:

a. Tools as needed from the lists in General Procedure W1 b. Tools as needed to remove louversc. Non-asbestos replacement louvers

3. Complete Worker General Procedure W4 “Secure Work Area”4. Put down drop sheet and complete Worker General Procedure W10 “Polyethylene

Drop Cloth” 5. Verify that cooling tower is shut off and locked out. See General Procedure W3.6. Place tools, equipment and materials needed onto drop cloth.7. Adequately wet louvers to be removed.8. Remove any fasteners holding louvers in place. HEPA vacuum and wet fasteners

during removal. Clean fasteners for reuse or dispose of as ACM.9. Remove louvers without breaking if possible and place them into disposal bags as

they are removed. Collect any large broken pieces or chips and place into disposalbags. If louvers are too big for a disposal bag, lay down a double sheet of 6 milpolyethylene. Stack louvers on sheet. After 6 louvers are stacked wrap inpolyethylene sheet for disposal. Candy strip wrapped louvers with duct tape. Do notdrop removed louvers to the ground, carry down all removed materials by the end ofthe shift.

10. Wet wipe and/or HEPA vacuum surfaces louvers were contacting and any dust ordebris from louver removal. Use Work Practice M22 if HEPA vacuum needsmaintenance, or if bag or filter needs to be replaced.



M8 . SummaryRemove or replace asbestos cement roof shingles

SummaryThis work practice covers the procedures for removing or replacing a small number ofasbestos cement shingles from the roof of a building to support O&M work.

Examples

Level A: A. Replace or remove less than 25 square feet of intact asbestos cement roof shingleswith out creating visible dust, to perform patching, repair work, or install new ventor stack.

Level B: A. Replace or remove asbestos cement roof shingles where: more than 25 square feet ofshingles are removed, or the shingles are damaged, or may become non-intact, orcreate visible dust during removal.

Related Work PracticesM 5 Cut or drill asbestos cement panels.M 6 Remove asbestos cement panels.M 9 Remove and replace asbestos cement siding.M 13 Remove asbestos-containing built-up roofing.

Worker Recommendations One worker is usually sufficient. Two or more workers may be needed to increaseefficiency or for additional health and/or safety considerations. A person with airmonitoring training might be required. This person can be a worker.


M8 . Level ARemove or replace asbestos cement roof shingles


A. Replace or remove less than 25 square feet of intact asbestos cement roof shingleswith out creating visible dust, to perform patching, repair work, or install new ventor stack.


Use of a safety harness is strongly recommended for working on sloped roofs. Completeroofing removal work before any penetrations are made in the roof deck.




b. Thin, flat sharp nail cutter

c. Pry bars, slatter's ripper and/or nail clipper

d. Non-slip boots for roofing work

e. Safety harness

f. Replacement roofing

g. Hammer


4. Put down drop sheet and complete Worker General Procedure W10“Polyethylene Drop Cloth.” Drop cloth should be below removal area tocatch any debris generated during removal.


6. If feasible, spray amended water on shingles prior to start of removal. Caution: Wetting shingles will often make then slippery and lead to slippingand falling hazards that can be particularly dangerous on sloped roofs.

7. Do not cut, abrade or break shingles

8. Starting at top of removal area, remove nails, or cut nails with a flat sharpnail cutter. Pry up edge of first shingle until edges can be gripped by hand. Remove shingle and place into disposal bags or polyethylene lined cardboard

M8 . Level A ... continued


boxes and lower to ground level. Do not drop shingles to the ground. Carrydisposal bag to the ground, do not drop.

9. Continue removing shingles using procedure above.

10. Clean up any debris or dust using HEPA vacuuming and wet wiping.

11. Perform maintenance work and clean-up and tear-down steps on Level Achecklist to complete work.


M8 . Level BRemove or replace asbestos cement roof shingles


A. Replace or remove asbestos cement roof shingles where: more than 25 square feet ofshingles are removed, or the shingles are damaged, or may become non-intact, orcreate visible dust during removal.


Use of a safety harness is strongly recommended for working on sloped roofs. Completeroofing removal work before any penetrations are made in the roof deck.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Thin, flat sharp nail cutter c. Pry bars, slatter's ripper and/or nail clipperd. Non-slip boots for roofing worke. Safety harnessf. Replacement roofingg. Hammer

3. Prepare work area with barrier tape according to General Procedure W4 “SecureWork Area”

4. Put down drop sheet and complete Worker General Procedure W10 “PolyethyleneDrop Cloth.” Drop cloth should be below removal area to catch any debris generatedduring removal. Seal any roof penetrations, air intakes or windows in work area withpolyethylene. Do not seal over plumbing vent stacks.


6. If feasible, spray shingles with amended water prior to removal. Do not wet shinglesif this will create a slipping and falling hazard. Caution: Wetting shingles will oftenmake then slippery and lead to slipping and falling hazards that can be particularlydangerous on sloped roofs.


M8 . Level B ... continued


8. Starting at top of removal area, remove nails, or cut nails with a flat sharp nail cutter. Pry up edge of first shingle until edges can be gripped by hand. Remove shingle andplace into disposal bags or polyethylene lined cardboard boxes and lower to groundlevel. Do not drop shingles to the ground. Carry disposal bag to the ground, do notdrop.





M9 . SummaryRemove and replace asbestos cement siding shingles

SummaryThis work practice covers the procedures for removing small amounts of asbestos cementsiding shingles from the exterior of a building to support O&M work.

Examples

Level A: A. Replace or remove a small number of asbestos cement siding shingles in goodcondition that are loose or can be removed with minimal breakage to performpatching, repair work, or to install a new window or door.

Level B: A. Replace or remove several asbestos cement siding shingles that are sufficientlydamaged and may become friable during removal.

Related Work PracticesM 5 Cut or drill asbestos cement panels.M 6 Remove cement asbestos panels.M 8 Remove and replace asbestos cement shingles.M 13 Remove asbestos-containing built-up roofing.



M9 . Level ARemove and replace asbestos cement siding shingles


A. Replace or remove a small number of asbestos cement siding shingles in goodcondition that are loose or can be removed with minimal breakage to performpatching, repair work, or to install a new window or door.



2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Thin, flat sharp nail cutter c. Pry bars, slatter's ripper and/or nail clipperd. Replacement siding, if required


4. Put down drop sheet and complete Worker General Procedure W10 “PolyethyleneDrop Cloth.” Drop cloth should be below removal area to catch any debris generatedduring removal.


6. Set up ladder or scaffold if needed.

7. Spray shingles with amended water prior to start of removal. Maintain shingles in awet condition throughout removal..


9. Starting at top of removal area, remove nails, or cut nails with a flat sharp nail cutter. Pry up edge of first shingle until edges can be gripped by hand. Remove shingle andplace into disposal bags or polyethylene lined cardboard boxes and lower to groundlevel. Do not drop shingles or disposal bag to the ground.


11. Clean up any debris or dust using wet wiping or HEPA vacuum. Use Work PracticeM22 if HEPA vacuum needs maintenance, or if bag or filter needs to be replaced.



M9 . Level BRemove and replace asbestos cement siding shingles


A. Replace or remove several asbestos cement siding shingles that are sufficientlydamaged and may become friable during removal.



2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Thin, flat sharp nail cutter c. Pry bars, slatter's ripper and/or nail clipperd. Replacement siding, if required


4. Put down drop sheet and complete Worker General Procedure W10 “PolyethyleneDrop Cloth.”

5. Drop cloth should be below removal area to catch any debris generated duringremoval. Set up ladder or scaffold if needed. Seal over any penetrations, air intakesor windows in work area with polyethylene. Do not cover over exhaust vents.


7. Spray shingles with amended water prior to start of removal. Maintain shingles in awet condition throughout removal..


9. Starting at top of removal area, remove nails, or cut nails with a flat sharp nail cutter. Pry up edge of first shingle until edges can be gripped by hand. Remove shingle andplace into disposal bags or polyethylene lined cardboard boxes and lower to groundlevel. Do not drop shingles or disposal bag to the ground.





M10 . SummaryRemove high-temperature resistant (HTR)asbestos cement panels.

SummaryThis work practice covers the procedures for removing small amounts of hightemperature resistant asbestos panels for maintenance work. These panels typically havea high asbestos content.

Examples

Level A: A. Remove several HTR asbestos cement panels in good condition that can be removedwith no breakage.

Level B: A. Remove several HTR asbestos cement panels that are damaged and may becomefriable during removal.

Level C: A. Remove several HTR asbestos cement panels in poor and friable condition inside amini-enclosure.

Related Work PracticesM 5 Cut or drill asbestos cement panels.M 6 Remove asbestos cement panels.M 8 Remove and replace asbestos cement shingles.M 13 Remove asbestos-containing built-up roofing.

Worker RecommendationsOne worker for Level A work. One or two workers for Level B depending upon safetyand efficiency considerations. Two workers for Level C. A person with air monitoringtraining might be required. This person can be a worker.


M10 . Level ARemove high temperature resistant (HTR)asbestos cement panels.


A. Remove several HTR asbestos cement panels in good condition that can be removedwith no breakage.





b. Tools needed to remove panels and fasteners

c. Spray encapsulant (if used)


4. Put down drop sheet and complete Worker General Procedure W10 “PolyethyleneDrop Cloth.” Drop cloth should be below removal area to catch any debris generatedduring removal.


6. Set up ladder or scaffold if needed. Spray amended water on panels before startingremoval. Maintain panels in a wet condition throughout removal..

7. Do not cut, abrade or break panels.

8. Remove fasteners securing panels in place. Wet fasteners during removal.

9. Remove panels without breaking and place them into disposal bags as they areremoved. If panels are too big for a disposal bag, lay downs a double sheet of 6 milpolyethylene. Stack panels on sheet. After 6 panels are stacked wrap in polyethylenesheet for disposal. Candy strip wrapped panels with duct tape. Do not drop removedpanels to the ground, carry down all removed materials by the end of the shift.

10. Clean up any debris or dust using wet wiping or HEPA vacuum. Use Work PracticeM22 if HEPA vacuum needs maintenance, or if bag or filter needs to be replaced.



M10 . Level BRemove high temperature resistant (HTR)asbestos cement panels.


A. Remove several HTR asbestos cement panels that are damaged and may becomefriable during removal.





b. Tools needed to remove panels and fasteners

c. Spray encapsulant (if used)


4. Put down drop sheet and complete Worker General Procedure W10 “PolyethyleneDrop Cloth.” Drop cloth should be below removal area to catch any debris generatedduring removal. Set up ladder or scaffold if needed


6. Spray amended water on panels before starting removal. Maintain panels in a wetcondition throughout removal..


8. Remove fasteners securing panels in place. Wet fasteners during removal.

9. Remove panels without breaking and place them into disposal bags as they areremoved. If panels are too big for a disposal bag, lay downs a double sheet of 6 milpolyethylene. Stack panels on sheet. After 6 panels are stacked wrap in polyethylenesheet for disposal. Candy strip wrapped panels with duct tape. Do not drop removedpanels to the ground, carry down all removed materials by the end of the shift.




M10 . Level CRemove high temperature resistant (HTR)asbestos cement panels


A. Remove several HTR asbestos cement panels in poor and friable condition inside amini-enclosure.

NotesThis work practice must be used in conjunction with General Procedures W1, W10 and aLevel C Worker Checklist. The worker checklist includes tasks that must be performedbefore these work practices are begun.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1b. Tools needed to remove panels and fastenersc. Spray encapsulant (if used)




6. Place tools, equipment and materials needed into enclosure. Set up ladder or scaffoldif needed.

7. Enter enclosure and spray panels to be removed with amended water. Maintainpanel wet throughout removal


9. Remove fasteners holding panels in place. Wet or HEPA vacuum fasteners duringremoval. Pull panel away slightly, spray amended water on back of panel, removepanel without breaking and place into disposal bags or polyethylene lined cardboardboxes. as they are removed. If panels are too big for a disposal bag, lay downs adouble sheet of 6 mil polyethylene. Stack panels on sheet. After 6 panels are stackedwrap in polyethylene sheet for disposal. Candy strip wrapped panels with duct tape. Do not drop removed panels to the ground, carry down all removed materials by theend of the shift. Spray any loose or broken panel pieces with amended water andplace into disposal bags.




M11 . SummaryRemove asbestos-containing chalk board

SummaryThis work practice describes the work required to remove a chalkboard that is made ofasbestos-containing material.

Examples

Level A: A. Remove an asbestos-containing chalkboard that is non-adhered and easily removed.

Level B: A. Remove an asbestos-containing chalkboard that is adhered or may generate minordebris from removal.

Level C: A. Remove an asbestos-containing chalkboard that is in poor condition or stronglyadhered to wall.

Related Work PracticesNone

Worker Recommendations One worker for small boards or mechanically attached units. Two workers for largerboards or adhered units. A person with air monitoring training might be required. Thisperson can be a worker.


M11 . Level ARemove asbestos-containing chalk board


A. Remove an asbestos-containing chalkboard that is non-adhered and easily removed.









5. Adequately wet chalkboard unit using garden sprayer with amended water. Spraywater around sides of board and at joint between wall and top of board to wet anydebris behind board.

6. Remove any fasteners or moldings attaching board to wall and remove board. Someboards lift up out of a supporting tray or off of supporting clips to remove. Wrapboard in two layers of polyethylene sheet for disposal. If board is adhered to wall, aLevel B or C procedure should be performed.

7. HEPA vacuum surface that board was attached to wall. Use Work Practice M22 ifHEPA vacuum needs maintenance, or if bag or filter needs to be replaced.



M11 . Level BRemove asbestos-containing chalk board


A. Remove an asbestos-containing chalkboard that is adhered or may generate minordebris from removal.







d. Crow bar and screwdrivers




6. Adequately wet chalkboard unit using garden sprayer with amended water. Spraywater around sides of board and at joint between wall and top of board to wet anydebris behind board.

7. Remove any fasteners or moldings attaching board to wall and remove board. Someboards lift up out of a supporting tray or off of supporting clips to remove. If boardis adhered to wall, use screwdrivers or crow bar to remove board. Wet adhesive(using amended water) while prying board off wall. Wrap board in two layers ofpolyethylene sheet for disposal.

8. If board was attached with adhesive, wet and scrape remaining adhesive off wall.

9. Wet wipe and HEPA vacuum surface that board was attached to.



M11 . Level CRemove asbestos-containing chalk board


A. Remove an asbestos-containing chalkboard that is in poor condition or stronglyadhered to wall.






d. Crow bar and screwdrivers



5. Erect mini-enclosure and set up negative pressure system and/or HEPA filtered localexhaust ventilation according to General Procedure W20 “Mini-Enclosure.” Enclosure must be large enough to lay board on floor and wrap for disposal.


7. Enter enclosure and adequately wet chalkboard unit using garden sprayer withamended water. Spray water around sides of board and at joint between wall and topof board to wet any debris behind board.

8. Remove any fasteners or moldings attaching board to wall and remove board. Someboards lift up out of a supporting tray or off of supporting clips to remove. If boardis adhered to wall use screwdrivers or crow bar to remove board. Wet adhesive usingamended water while prying board off wall. Wrap board in two layers ofpolyethylene sheet for disposal.

9. If board was attached with adhesive, wet and scrape remaining adhesive off wall.

10. Wet wipe and HEPA vacuum surface that board was attached to.



M12 . SummaryRemove asbestos-containing fire door and/ordoor hardware

SummaryThis procedure sets forth the O&M work procedures to remove an asbestos-containingfire door or door hardware in an asbestos-containing fire door. Cutting or drilling intoasbestos containing doors are included as Level C work.

Examples

Level A: A. Remove an asbestos-containing fire door that is in good condition for replacement.

B. Replace a lockset or closer on asbestos-containing fire door in good condition. Lockset does not penetrate asbestos core of door.

Level B: A. Remove an asbestos-containing fire door that is damaged.

B. Replace a lockset or closer on asbestos-containing fire door in poor condition. Lockset may penetrate asbestos core of door.

Level C: A. Cut a door to install new window.

B. Drill a hole for new lockset through asbestos core of a door.

Related Work PracticesNone.

Worker Recommendations One worker for Level A and Level B. Two workers may facilitate handling of heavydoors being removed. Two workers for Level C. A person with air monitoring trainingmight be required. This person can be a worker.


M12 . Level ARemove asbestos-containing fire door and/ordoor hardware


A. Remove an asbestos-containing fire door that is in good condition for replacement.

B. Replace a lockset or closer on asbestos-containing fire door in good condition. Lockset does not penetrate asbestos core of door.





b. Screwdriver and tools needed for hardware or door removal



5. If door is equipped with a closer, detach closer arm from door frame. Removescrews attaching closer to door. HEPA vacuum or wet clean screws, closer, and areawhere closer was attached to door. Thoroughly clean closer and parts if they will bere-used. If closer will not be re-used, dispose of as ACM waste.

6. Remove lockset from door using procedures used for closer. HEPA or wet wipevacuum lockset if it will be re-used or disposed of as ACM waste. Use WorkPractice M22 if HEPA vacuum needs maintenance, or if bag or filter needs to bereplaced.

7. Lay two layers of polyethylene sheet on floor for wrapping door.

8. Remove hinge pins or screws attaching hinges to door frame. Lay door onpolyethylene.

9. If hinges are to be re-used, remove from door following procedures used for closer. If hinges are to be disposed of, leave hinges attached to door.

10. Wrap door for disposal.



M12 . Level BRemove asbestos-containing fire door and/ordoor hardware


A. Remove an asbestos-containing fire door that is damaged.

B. Replace a lockset or closer on asbestos-containing fire door in poor condition. Lockset may penetrate asbestos core of door.





b. Screwdrivers and tools needed for hardware and door removal



5. Place tools, equipment and materials needed on drop cloth.

6. Wet any damaged areas with amended water.

7. If door is equipped with a closer, detach closer arm from door frame. Wet closer andarea where closer is attached to door using amended water. Remove screws attachingcloser to door. Wet screws during removal and area behind closer once all screws areremoved. HEPA vacuum and wet wipe closer and screws if it is to be re-used. Ifcloser and screws will not be re-used, dispose of as ACM waste.

8. Remove lockset from door using procedures used for closer. HEPA vacuum locksetif it will be re-used or dispose of as ACM waste.

9. Lay two layers of polyethylene sheet on floor for wrapping door.

10. Remove hinge pins or screws attaching hinges to door frame. Lay door onpolyethylene.

11. If hinges are to be re-used, remove from door following procedures used for closer. If hinges are to be disposed of, leave hinges attached to door.

M12 . Level B...continued


12. Wrap door for disposal.



M12 . Level CRemove asbestos-containing fire door and/ordoor hardware


A. Cut a door to install new window.

B. Drill a hole for new lockset through asbestos core of a door.

NotesPerform work in a mini-enclosure located at door, or remove door and take to remotemini-enclosure




b. Tools needed to cut or drill door, with HEPA filtered dust collection attachmentif possible.

c. New lockset or window



5. Erect mini-enclosure and set up negative pressure system and/or HEPA filtered localexhaust ventilation according to General Procedure W20 “Mini-Enclosure.” Enclosures can be installed at door location, or door can be removed and taken intoan enclosure.


7. Wet area where hole will be cut or drilled.

8. Cut or drill door as required. Wet cutting or drilling location during work.

9. Place cut piece of door or debris from drilling into ACM disposal bags. HEPAvacuum or wet wipe new hole area and clean up any debris.

10. Install window or lockset and perform clean-up and tear-down steps on Level Cchecklist to complete work.


M13 . SummaryRemove asbestos-containing built-up roofing

SummaryThis work practice describes the work required to remove a small amount of asbestos-containing built-up roofing or flashing for maintenance or repair work.

Examples

Level A: A. Replace or remove intact less than 25 square feet of asbestos containing built-uproofing without creating visible dust, to perform patching, repair work, or install newvent or stack.

Level B: A. Replace or remove a small area of asbestos containing built-up roofing that isdamaged, may become non-intact or create visible dust during removal, or wheremore than 25 square feet is removed

Related Work PracticesM 8 Remove and replace asbestos cement roof shingles.

M 14 Remove asbestos-containing asphalt shingles.



M13 . Level ARemove asbestos-containing built-up roofing


A. Replace or remove intact less than 25 square feet of asbestos containing built-uproofing without creating visible dust, to perform patching, repair work, or install newvent or stack..


Use fall prevention measures (including safety harnesses, a warning line system withsafety monitor, and/or a motion stopping system) as required by OSHA for roofing work. Roofing removal work shall be completed before any penetrations through the roof deckare made. Coordinate work with O & M Work Practice S7 if surfacing is present onunderside of deck.




b. Safety harness/warning line system and/or motion stopping system

c. Hook knife

d. Scraper 2-3" (50-75 mm) wide stiff blade

e. Replacement roofing materials and tools

f. Rope for lowering bags



5. Cut around area to be removed using hand tools. Note that several layers may bepresent.

6. Scrape up roofing and place into disposal bags. Remove any remaining roofingdebris in removal area using scraper and place into disposed bags. Lower bags toground.

7. Perform maintenance/repair work and clean-up and tear-down steps on Level Achecklist to complete work.


M13 . Level BRemove asbestos-containing built-up roofing


A. Replace or remove a small area of asbestos containing built-up roofing that isdamaged, may become non-intact or create visible dust during removal, or wheremore than 25 square feet is removed


Use fall prevention measures (including safety harnesses, a warning line system withsafety monitor, and/or a motion stopping system) as required by OSHA for roofing work. Roofing removal work shall be completed before any penetrations through the roof deckare made. Coordinate work with O & M Work Practice S7 if surfacing ACM is presenton underside of deck.




b. Safety harness/warning line system and/or motion stopping system

c. Hook knife

d. Scraper 2-3" (50-75 mm) wide stiff blade

e. Replacement roofing materials and tools

f. Rope for lowering bags


4. Put down drop sheet and complete Worker General Procedure W10 “PolyethyleneDrop Cloth.” Seal any windows, HVAC units, air intakes or other openings thatcould allow fibers from work area into building. Do not seal any plumbing vents inwork area.


6. If feasible and safe, adequately wet roofing to be removed using garden sprayer withamended water. The use of wetting and amended water for roofing work shouldlimited for the following reasons:



a. Wet roofing can create slip hazards.

b. Roofing mastic/coal tar/bitumen will not adhere to wet surfaces.

c. Water can damage materials below the roof membrane.

7. Cut around area to be removed using hand tools. Wet cutting area using amendedwater. Note that several layers may be present.

8. Scrape up roofing section and place into disposal bags. Wet and remove any roofingdebris in removal area using scraper. Lower bags to ground.

9. HEPA vacuum or wet wipe removal area. Use HEPA vacuum where needed to cleanup ACM. It may not be appropriate or necessary to use HEPA vacuum on non-ACM.

10. Perform maintenance/repair work and clean-up and tear-down steps on Level Bchecklist to complete work.


M14 . SummaryRemove asbestos-containing asphalt shingles

SummaryThis work practice describes the work required to remove a small number of asbestos-containing shingles for maintenance or repair work.

Examples

Level A: A. Remove intact less than 25 square feet of asbestos containing asphalt shingleswithout creating visible dust, to perform patching, repair work, or install new vent orstack.

Level B: A. Replace or remove asbestos containing asphalt shingles that are damaged to theextent that they have become friable, may become non-intact or create visible dustduring removal, or where more than 25 square feet is removed

Related Work PracticesM 8 Remove and replace asbestos cement roof shingles.

M 13 Remove asbestos-containing built-up roofing.



M14 . Level ARemove asbestos-containing asphalt shingles


A. Remove intact less than 25 square feet of asbestos containing asphalt shingleswithout creating visible dust, to perform patching, repair work, or install new vent orstack.


Use fall prevention measures (including safety harnesses, a warning line system withsafety monitor, and/or a motion stopping system) as required by OSHA for roofing work. Roofing removal work shall be completed before any penetrations are made in the roofdeck.




b. Garden sprayer with amended water

c. Scraper 2-3" (50-75 mm) wide stiff blade

d. Roofing repair materials (shingles, roofing cement, nails)

e. Hammer

f. Pry bar

g. Safety harness/warning line system and/or motion stopping system

h. Non-slip boots

i. Spray encapsulant (if used)

3. Complete Worker General Procedure W4 “Secure Work Area.”


5. Slide scraper under bottom shingle and twist scraper to break shingle seal. Removeentire shingle or sections of 3-Tab type shingles. Perimeter of removal area musthave clean, straight vertical cuts to allow installation of new shingles. Note thatseveral layers may be present.



6. Continue removing shingles one at a time following the steps used for the firstshingle until area needed is removed. Place all shingles into disposal bags.

7. Do not drop shingles or disposal bags to the ground.

8. Pry up tabs on shingles immediately above removal area to facilitate installing newshingles.

9. Perform maintenance work and clean-up and tear-down steps on Level A checklist tocomplete work. Use roofing cement on tabs of existing shingles to seal them to newshingles.


M14 . Level BRemove asbestos-containing asphalt shingles


A. Replace or remove asbestos containing asphalt shingles that are damaged to theextent that they have become friable, may become non-intact or create visible dustduring removal, or where more than 25 square feet is removed Remove asbestos-containing asphalt shingles in poor condition to repair roof leak. Shingles aredamaged to the extent that they have become friable.


Use fall prevention measures (including safety harnesses, a warning line system withsafety monitor, and/or a motion stopping system) as required by OSHA for roofing work. Roofing removal work shall be completed before any penetrations are made in the roofleak.





c. Roofing repair materials (shingles, roofing cement, nails)

d. Hammer

e. Pry bar

f. Safety harness/warning line system and/or motion stopping system

g. Non-slip boots

h. Spray encapsulant (if used)


4. Put down drop sheet and complete Worker General Procedure W10 “PolyethyleneDrop Cloth.” Seal over any windows, HVAC units, air intakes or other openings thatcould allow fibers from work area into building. Do not seal over any plumbingvents in work area.




6. If feasible and safe, adequately wet area of shingles to be removed with amendedwater or encapsulant. The use of wetting and amended water for roofing work shouldbe limited for the following reasons:

a. Wet roofing can create slip hazards.

b. Roofing mastic/coal tar/bitumen will not adhere to wet surfaces.

c. Water can damage materials below the roof membrane.

7. Slide scraper under bottom shingle and twist scraper to break shingle seal. Removeentire shingle or sections of 3-Tab type shingles. Wet underside of shingles as theyare removed. Perimeter of removal area must have clean, straight vertical cuts toallow installation of new shingles. Note that several layers may be present.

8. Continue removing shingles one at a time following the steps used for the firstshingle until area needed is removed. Place all shingles into disposal bags.

9. Do not drop shingles of disposal bag.

10. Pry up tabs on shingles immediately above removal area to facilitate installing newshingles.

11. HEPA vacuum or wet wipe removal area. Use HEPA vacuum where needed to cleanup ACM. It may not be appropriate or necessary to use HEPA vacuum on non-ACM.

12. Perform maintenance work and clean-up and tear-down steps on Level B checklist tocomplete work. Use roofing cement on tabs of existing shingles to seal them to newshingles.


M15 . SummaryCut or drill asbestos-containing drywall,plaster or drywall compound

SummaryThis work practice covers the procedures for cutting or drilling of asbestos-containingdrywall or plaster. Joint compounds and tape are also covered by this procedure.

ExamplesLevel B: OSHA requires that during Class III (O&M) operations that involve, “drilling, cutting,

abrading, sanding, chipping, breaking, or sawing of thermal system insulation orsurfacing materials, the employer shall use impermeable drop cloths, and shall isolate theoperation using mini-enclosures or glove bag systems ...or another isolation method.” This work practice relies on a HEPA exhausted collar on the drill, shaving cream, or awet sponge as, “another isolation method.” During design of the O&M program thedesigner must be a competent person and must determine that the use of these techniquesas described in the work practice effectively isolates the drilling or cutting work. Thisevaluation should be based on an, “Initial exposure assessment,” leading to a “NegativeExposure Assessment,” (NEA) as described in the OSHA construction standard 29 CFR1926.1101(f)(2). During implementation of the program, the APM must also be acompetent person, and must make a determination that conditions at a specific job site areequivalent to those that existing during development of the work practice, so that thework practice is applicable. The work order issued to the person performing the workshould inform them of the NEA and any conditions that are attached to the NEA. It ispossible that after there has been some experience with the OSHA regulation themanufacturers of the type of equipment used in this work practice will make the properevaluations and submissions to OSHA and be able to provide this to the designers ofO&M programs. In any case, as a minimum requirement the supervisor that assignswork to the maintenance staff should be a competent person able to evaluate theapplicability of the work procedures to a particular situation.

A. Install new electrical receptacle or ceiling junction box in asbestos-containingdrywall using hand tools.

B. Drill holes to attach conduit to asbestos-containing drywall using a drill with a HEPAexhausted collar attachment.

C. Drill holes in asbestos-containing joint compound where drywall is non-asbestos.

Level C: The OSHA construction standard requires that activities involving drilling, cutting,abrading, etc. take place inside of mini-enclosures or glovebags. This will help protectthe building environment, but in the case of mini-enclosures may increase exposures forworkers and complicate clean up of the mini-enclosure. The work practice should alwaysrequire that the careful work procedures of Level B be used inside of mini-enclosures. This will help protect workers and will simplify cleanup of the mini-enclosure interior. Use of power tools inside of a glovebag could be dangerous and should never be allowed.

M15 . Summary ... continued


A. Install conduit or ductwork through asbestos-containing drywall using power tools.

Related Work PracticesM 5 Cut or drill asbestos cement panels.M 6 Remove asbestos cement panels.

Worker Recommendations One worker is usually sufficient for Level B. Two workers for Level C. Two workersmay be needed to increase efficiency or for additional health and/or safetyconsiderations. Workers should be trained in working with drywall and asbestos. Aperson with air monitoring training might be required. This person can be a worker.


M15 . Level BCut or drill asbestos-containing drywall,plaster or drywall compound


A. Install new electrical receptacle or ceiling junction box in asbestos-containingdrywall using hand tools.

B. Drill holes to attach conduit to asbestos-containing drywall using a drill with a HEPAexhausted collar attachment.

C. Drill holes in asbestos-containing joint compound where drywall is non-asbestos



2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1b. Drill or hole saw (as needed) equipped with HEPA filtered dust collectionc. Maintenance work materials



5. If accessible, also install a drop cloth on back side of drywall if hole(s) will penetratethrough wall.


7. Mark area to be cut or drilled.

8. Adequately wet area to be cut using garden sprayer with amended water. Asalternate methods, holes can be drilled/cut through a wet sponge or shaving cream onboth sides.

9. Cut new hole using utility knife, hand tools or power tools with HEPA filtered dustcollection. Wet the cutting area using amended water during cutting or drilling.



10. Remove piece of cut drywall and place into disposal bag. If wet sponges were used,place sponges into disposal bag.

11. HEPA vacuum removal area and areas accessible from hole.

12. HEPA vacuum and wet wipe up any accessible dust or debris generated on back side. Wet wipe drop cloth and surfaces adjacent to area where hole was cut or drilled. Remove drop cloth and place into disposal bags.



M15 . Level CCut or drill asbestos-containing drywall,plaster or drywall compound


A. Install conduit or ductwork through asbestos-containing drywall using power tools.

NotesInside of enclosure, use Level B work practices to minimize fiber release for proceduresthat involve drilling, cutting, abrading, sanding, chipping, breaking or sawing.




2. Tools, equipment and materials:a. Tools as needed from the lists in General Procedure W1 b. Drill or saw (as needed) with HEPA filtered dust collection attachmentc. Maintenance work materials.




6. If back side of drywall is accessible, enclose area if hole(s) will penetrate throughwall. Provide negative air in backside enclosure if possible. A glovebag may beused as an enclosure for small work areas.

7. Place tools, equipment and materials needed into enclosure. Include a second HEPAvacuum outside of the enclosure with hose and nozzle extending inside enclosure forany power tools to be used for cutting or drilling.

8. Enter enclosure and mark area to be cut or drilled.

9. Adequately wet area to be cut using garden sprayer with amended water.

10. Cut new hole using utility knife, hole saw or drill. Power tools must have anoperating HEPA vacuum attached during cutting. Wet the cutting area usingamended water during cutting or drilling.

M15 . Level C ... continued


11. Remove piece of cut drywall and place into disposal bag.

12. HEPA vacuum removal area and areas accessible from hole.

13. If dust or debris is generated on back side, insert wand of garden sprayer into backside of enclosure and adequately wet any dust or debris present. Remove back-sideenclosure, place into disposal bags, and wet wipe surfaces that were exposed insideenclosure.



M16 . SummaryRemove section of asbestos-containingdrywall

SummaryThis work practice describes the work required to remove a small area of asbestos-containing drywall, or non-ACM drywall with ACM joint compound in support of O&Mwork.

Examples

Level B: A. Remove small area of asbestos-containing drywall in good condition using non-powered hand tools. Low dust Level expected.

Level C: A. Replace damaged section of asbestos-containing drywall or drywall adhered to studsusing hand tools or power tools with HEPA vacuum dust collection attachments.

Related Work PracticesM 15 Cut or drill asbestos-containing drywall or drywall compound.

Worker Recommendations One worker is usually sufficient for Level B. Two workers for Level C. Two or moreworkers may be needed to increase efficiency or for additional health and/or safetyconsiderations. A person with air monitoring training might be required. This personcan be a worker.


M16 . Level BRemove section of asbestos-containingdrywall


A. Remove small area of asbestos-containing drywall in good condition using non-powered hand tools. Low dust Level expected.


This work practice must be used in conjunction with General Procedures W1, W10 and aLevel B Worker Checklist. The worker checklist includes tasks that must beperformed before these work practices are begun.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Hand tools as needed c. Pry bars




6. Adequately wet entire area of drywall to be removed using garden sprayer withamended water.

7. Cut around perimeter of area to be removed using hand tools. Wet cutting area withamended water during cutting.

8. If drywall remains attached to studs or substrate, use pry bar to pull sheet out enoughso edge can be gripped with hands. Mist cavity behind drywall and back side ofdrywall to be removed with amended water.

9. Pull sheet out so sheet folds at fastener line or sheet is pulled away from fasteners. Adequately wet fold or holes from fasteners.

10. Repeat step above at other attachment points, remove drywall piece, and package fordisposal.



11. Remove fasteners from studs or substrate and place into disposal bags. Clean anydebris left on studs or substrate using amended water and nylon brush.

12. Pick up any debris and place into disposal bags. HEPA vacuum and wet wipe up anydust generated.



M16 . Level CRemove section of asbestos-containingdrywall


A. Replace damaged section of asbestos-containing drywall or drywall adhered to studsusing hand tools or power tools with HEPA vacuum dust collection attachments.




2. Tools, equipment and materials:a. Tools as needed from the lists in General Procedure W1b. Tools as neededc. Pry bar




6. If back side of drywall is accessible, enclose and provide negative pressure forenclosure.


8. Enter enclosure and adequately wet area of drywall to be removed using gardensprayer with amended water.

9. Cut around perimeter of area to be removed using utility knife. Wet cutting areaduring cutting.

10. If drywall remains attached to studs or substrate, use pry bar to pull sheet out enoughso edge can be gripped with hands. Mist cavity behind drywall, and back side ofdrywall to be removed with amended water.

11. Pull sheet out so sheet folds at fastener line or sheet is pulled away from fasteners. Adequately wet fold or holes from fasteners.



12. Repeat steps above at other attachment points, remove drywall piece, and package fordisposal.

13. Remove fasteners from studs or substrate and place into disposal bags. Clean anydebris left on studs or substrate using amended water and nylon brush.

14. Pick up any debris and place into disposal bags. HEPA vacuum and wet wipe up anydust generated.



M17 . SummaryRemove asbestos-containing flexible ductconnector

SummaryThis work describes the work required to remove an asbestos-containing fabric flexibleduct connector.

Examples

Level A: A. Remove flexible duct connector in good condition with duct work.B. Remove flexible duct connector in good condition where connector will not be

damaged.

Level B: A. Remove flexible duct connector where it may be damaged during removal.

Level C: A. Remove flexible duct connector in poor condition.

Related Work PracticesT 10 Remove duct insulation above lay-in ceiling for maintenance work.T 11 Remove duct insulation above plaster or drywall ceiling for maintenance work.M 19 Remove contaminated filters in HVAC unit serving plenum space with exposed

ACM.

Worker Recommendations One worker for Level A and Level B. Two workers for Level C. A second worker maybe needed for large connectors. A person with air monitoring training might be required. This person can be a worker.


M17 . Level ARemove asbestos-containing flexible ductconnector


A. Remove flexible duct connector in good condition with duct work.B. Remove flexible duct connector in good condition where connector will not be

damaged.


Coordinate work with proper O & M work practice for removing duct insulation ifneeded to access fasteners attaching flexible connector in place.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Scraper 2-3" (50-75 mm) wide stiff bladec. Stiff nylon bristle brushesd. Manual or power screwdriver with screwdriver bits and hex head sockets


4. Turn off, lock out and tag out HVAC unit. Install critical barriers in ductwork orHVAC unit adjacent to both sides of flexible connector (if possible) according toGeneral Procedure W5 “Critical Barriers.”


6. If possible remove flexible connector and its mounting frame in one unit. Disassemble ductwork as necessary to remove frame. Wrap frame and connector insheet plastic. Package for disposal as ACM waste.

7. If ductwork must be cut to remove flexible connector: cover flexible connector withpolyethylene on outside, and on inside, if accessible. Cut away ductwork on bothsides of connector and remove ductwork section with connector in place. Packageconnector with ductwork for disposal as ACM.

8. HEPA vacuum interior of ducts accessible at both sides where connector wasinstalled. Use Work Practice M22 if HEPA vacuum needs maintenance, or if bag orfilter needs to be replaced.

9. Remove critical barriers if installed inside ductwork or HVAC unit.


M17 . Level BRemove asbestos-containing flexible ductconnector


A. Remove flexible duct connector where it may be damaged during removal.


Coordinate work with proper O & M work practice for removing duct insulation ifneeded to access fasteners attaching flexible connector in place.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1b. Scraper 2-3" (50-75 mm) wide stiff bladec. Stiff nylon bristle brushesd. Manual or power screwdriver with screwdriver bits and hex head sockets


4. Put down drop sheet and complete Worker General Procedure W10 “PolyethyleneDrop Cloth.” Also, install critical barriers in ductwork or HVAC unit adjacent toboth sides of flexible connector (if possible) according to General Practice W5“Critical Barriers.”.


6. Adequately wet flexible connector with amended water or removal encapsulant.

7. Unscrew all screws holding flexible connector in place. Place screws into disposalbag if they will not be reused. If screws are to be reused, clean with water and nylonbrushes.

8. Rewet connector and metal flanges of flexible connector and slide off of ductwork. Pull connector out of space and package for disposal as ACM.

9. HEPA vacuum surfaces where flanges were attached and interior of ducts accessibleat both sides where connector was installed.




M17 . Level CRemove asbestos-containing flexible ductconnector


A. Remove flexible duct connector in poor condition.

NotesCoordinate work with proper O & M work practice for removing duct insulation ifneeded to access fasteners attaching flexible connector in place.






d. Manual or power screwdriver with screwdriver bits and hex head sockets



5. Erect mini-enclosure and set up negative pressure system and/or HEPA filtered localexhaust ventilation according to General Procedure W20 “Mini-Enclosure”Enclosure must allow access to all screws attaching connector in place. Also installcritical barriers in ductwork or HVAC unit adjacent to both sides flexible connectorto be removed (if possible) according to General Procedure W5 “Critical barriers.”


7. Adequately wet flexible connector with amended water or removal encapsulant.

8. Unscrew all screws holding flexible connector in place. Place screws into disposalbag if they will not be reused. If screws are to be reused, clean with water and nylonbrushes.

9. Rewet connector and metal flanges of flexible connector and slide off of ductwork. Pull connector out of space and package for disposal as ACM.

10. HEPA vacuum and wet wipe surfaces where flanges were attached and interior ofducts accessible at both sides where connector was installed.




M18 . SummaryRemove asbestos-containing paper or clothfrom ductwork

SummaryThis work practice covers the steps required to remove small amounts of asbestos-containing paper or cloth tape sealing the seams, or covering sheet metal ductwork.

This procedure can also be used to remove the tape sealing the vapor barrier/lagging overduct insulation. If vapor barrier sealing tape is removed the work practice should berevised to include replacement of the seal to avoid future condensation problems.

Examples

Level A: A. Repair asbestos-containing ductwork taping cloth.

Level B: A. Remove a small amount of ductwork sealing tape that is in good condition to installnew duct attached to existing ducts.

Level C: A. Replace damaged section of ductwork.B. Remove asbestos-containing paper-type duct wrap in poor condition.

Related Work PracticesM 17 Remove asbestos-containing flexible duct connector.

Worker Recommendations One worker is usually sufficient for Level A and Level B. Two workers for Level C. Two or more workers may be needed to increase efficiency or for additional health and/orsafety considerations. A person with air monitoring training might be required. Thisperson can be a worker.


M18 . Level ARemove asbestos-containing paper or clothfrom ductwork


A. Repair asbestos cloth or paper sealing tape on ductwork.



2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1b. Tin snips c. Non-woven fiberglass cloth (thin felt)d. Bridging type asbestos encapsulant.e. Disposable rubber gloves.



5. HEPA vacuum surface of sealing tape and duct to remove any debris or dust.

6. Cut cloth to size that will extend 1" past edge of sealing tape.

7. Put on rubber gloves. Dip cloth into encapsulant.

8. Wrap cloth over sealing tape and smooth down with hands.

9. Remove gloves and dispose of as ACM waste.

10. HEPA vacuum floor and all surfaces under work site and/or wet wipe. Use WorkPractice M22 if HEPA vacuum needs maintenance, or if bag or filter needs to bereplaced.



M18 . Level BRemove asbestos-containing paper or clothfrom ductwork


A. Remove a small amount of ductwork sealing tape or paper covering that is in goodcondition, and can be easily removed.



2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Tools and materials needed for duct workc. Scraper 2-3" (50-75 mm) wide stiff bladed. Stiff nylon bristle brushes




6. Wet sealing tape or paper covering with amended water. Allow enough time for thewater to penetrate paper. Add sufficient water to completely saturate paper.

7. Cut tape or paper with a razor knife as necessary to separate it.

8. Carefully lift tape or paper off of duct and place in a disposal bag.

9. Wet wipe surface of duct to remove all debris and residue.

10. HEPA vacuum and wet wipe area where tape or paper was removed perform finalwet wiping using procedure in General Procedure W9 “Wet Wiping, HEPAVacuuming and Steam Cleaning.”



M18 . Level CRemove asbestos-containing paper or clothfrom ductwork


A. Remove sealing tape that requires scraping, wire brushing, and cleaning with a drillmounted wire brush.

B. Remove asbestos-containing paper-type duct wrap in poor condition.




2. Tools, equipment and materials:a. Tools as needed from the lists in General Procedure W1 b. Tools and materials needed for duct workc. Scraper 2-3" (50-75 mm) wide stiff bladed. Stiff nylon or wire brushese. Glovebags (if required)





7. Enter enclosure. Wet ACM that is to be removed. Allow enough time for amendedwater to soak into material.

8. Using scraper, remove wet sealing tape or paper.

9. Clean remaining visible debris off ductwork nylon/wire brushes.

10. Local Exhaust Ventilation: If power tools (wire brush on a drill) are needed toremove residue of old gasket/packing use the following procedure. DO NOTATTEMPT TO USE THIS PROCEDURE INSIDE A GLOVEBAG.



i. Attach a manufactured or job-built collection attachment to nozzle of HEPAvacuum that is large enough to capture material coming from operating wirebrush.

ii. Install plastic drop cloth behind HEPA vacuum collection attachment.

iii. Wet residue with amended water.

iv. Remove residue with wire brush. Direct stream of removed material intoHEPA vacuum attachment .

v. Wet wipe and HEPA inside of attachment and surfaces from which residuewas removed.

11. If entire extent of the material to be removed will fit in a single glove bag and can beremoved without the use of power tools, the work may be performed in a glovebagrather than using a mini-enclosure. Follow work practices in General Procedure W18“Glovebag Removal.”

12. HEPA vacuum and wet wipe area where tape was removed.



M19 . SummaryRemove filters from HVAC unit

SummaryThis work practice covers the procedures for removing filters in HVAC unit that may becontaminated with asbestos.

Examples

Level B: A. Remove prefabricated slip-in type filters from HVAC unit in mechanical room.

B. Replace filters in HVAC unit in mechanical room with roll-type filters.

Related Work PracticesBuilding Lock-Out Tag-Out program.

Worker Recommendations One worker. A second worker may be needed for large, roll-type filters. A person withair monitoring training might be required. This person can be a worker.


M19 . Level BRemove filters from HVAC unit


A. Remove prefabricated slip-in type filters with a heavy dust loading from HVAC unitin mechanical room.

B. Replace filters in HVAC unit in mechanical room with roll-type filters.


Turn off HVAC unit fan, tag, and lock-out switch in accordance with facility’s Lock-OutTag-Out program before performing this work practice.

Work Practice1. Perform Pre-work activities on Level B checklist.2. Tools, equipment and materials:

a. Tools as needed from the lists in General Procedure W1b. Replacement filters.

3. Complete Worker General Procedure W4 “Secure Work Area.” Verify that HVACunit is shut off and locked out.


5. Place tools, equipment and materials needed in work area.6. Wet filters with amended water. Wet sufficiently that filter is saturated, but water is

not running from filter.7. Put on disposable gloves. Remove filters from filter frame and place directly into

disposal bag. Cut away exposed portions of roll type filters, and place directly intodisposal bag.

8. After all filters are removed, take off gloves and dispose of with filters. Double bagwaste, dispose of as ACM waste.

9. HEPA vacuum and wet wipe area where filters were installed and accessible surfacesin filter chamber.

10. Install new filters. For roll type filters, roll new filter material into place and coverfilter material remaining on role with sheet plastic or filter cover.



M20 . SummaryClean up debris

SummaryThis work practice describes theprocedures to be used to clean debris anddust that has resulted from disturbance ofan asbestos-containing material (ACM). The O&M program designer needs todefine a “minor” release. This willdepend on the material in a facility and theskill and training of the maintenance staffdoing the clean-up work. Theconsequences of a material release willdepend on the nature of the material andthe event that caused the release. If arelatively non-friable material such as aceiling tile were to fall out of a ceilinggrid this would be a simple clean up thatcould probably be handled with Level Acontrols. If the material were a very softand loosely consolidated acousticalmaterial that was knocked loose by abasketball, the clean up will be more

extensive and would probably requireLevel B procedures. The O&M designerneeds to define limits appropriate for thematerial and level of expertise of themaintenance staff doing the work. TheO&M program also needs to deal withmajor fiber releases. In most cases it isbest to have these clean-ups performed byan asbestos abatement contractor, unlessthe building staff has experience inasbestos abatement work practices andcontrols. Some regulations, such asAHERA, define maximum quantities forthis activity. Regulations may also requirethat a fiber release report be prepared andmade available to affected personnel. Iffiber release needs Level C workpractices, it should be treated as anabatement project, not as O&M work.

Examples

Level B: Level B procedures are appropriate where a small quantity of debris needs to be pickedup, but dust in the space also needs to be removed as a potentially asbestos contaminatedmaterial. This could be required after the fallout of a small amount of material from aceiling, pipe insulation or other source. If a large quantity of material is involved, thenthis section should be combined with cleaning of all surfaces in the room. It is usuallyeasier and less expensive to simply remove the dust using asbestos control procedures,than it is to attempt to find out if it contains asbestos.

.A. Clean up debris and dust on surfaces after a small area of surfacing ACM has fallen

from a ceiling, pipe insulation or other source.

Related Work PracticesS 10 Repair damaged surfacing ACM.T 7 Repair damaged thermal system insulation on a boiler, duct or flue.M 25 Clean room that has asbestos-containing dust.

Worker Recommendations: One worker. A person with air monitoring training might be required. This person canbe the worker.


M20 . Level BClean up debris


A. Clean up debris and dust on surfaces after a small area of surfacing ACM has fallenfrom a ceiling, pipe insulation or other source.


This work practice is limited to the cleanup of a small quantity of relatively intact debriswhich has fallen from an architectural finish, fire-proofing, or thermal insulation onpipes, boilers or other equipment.

Coordinate work with proper O & M work practice to repair cause of fiber release.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1


4. Remove asbestos-containing debris using the following sequence:

a. Shut down all ventilation into room.

b. Start HEPA vacuum before entering the area.

c. Use the HEPA vacuum to clean a path at least 6 feet (1.83 m) wide from theentry point of the work area to the site of the fallen material.

d. Remove all small debris with the HEPA vacuum.

e. Remove any dust or loose debris from the surface of larger pieces of ACM with aHEPA vacuum. Mist surface of pieces with amended water.

f. Pick up such pieces and place in the bottom of a 6 mil (0.15 mm) polyethylenedisposal bag conforming to the requirements of General Procedure W11“Packaging and Labeling Waste.” Place pieces in the bag without dropping andavoiding unnecessary disturbance and release of material. Thoroughly wet debrisin bag with amended water as it is collected.

g. Remove all remaining visible debris with HEPA vacuum.<



h. HEPA vacuum an area 3 feet (0.91 m) beyond the location in which any visibledebris was found. HEPA in two directions each at right angles to the other usingwork procedures of work practice M1 “Cleaning Potentially Asbestos-Contaminated Carpet.”

i. Wet wipe any hard surfaces or objects in the area using procedures of GeneralProcedure W9 “Wet Wiping, HEPA Vacuuming and Steam Cleaning.”

j. Place a 6 mil (0.15 mm) polyethylene drop cloth in accordance with GeneralProcedure W10 “Polyethylene Drop Cloth,” immediately on top of the HEPAvacuumed area before performing any repair work on site from which fall-outoccurred.

k. HEPA vacuum the site from which material fell removing all loose materialwhich can be removed by the vacuums suction.

l. Repair or remove remaining material using the appropriate O&M work practice.

m. HEPA vacuum ladder and/or any tools used and pass out of the work area.

5. Clean and decontaminate objects in the vicinity of debris using the followingprocedure:

a. Perform all work of decontaminating objects wherever possible on a plastic dropsheet installed in conformance General Procedure W10 “Polyethylene DropCloth.”

b. HEPA vacuum all surfaces of object and immediate area before moving theobject.

c. Pick-up object, if possible, and HEPA vacuum all surfaces.

d. Hand to off-sheet worker who will wet-clean object, if possible, and place instorage location.

e. Decontaminate area where object was located by HEPA vacuuming twice, in twoperpendicular directions. Wet clean if necessary to remove any debris.

f. Return object to its original location.



M21 . SummaryReplace asbestos-containing gaskets/packing

SummaryThis work practice describes the workrequired to replace ACM gaskets or ACMvalve packing for O&M work. Thesecould be applied to work on small simplegaskets in a school or office building, orhighly developed and specialized gasketsin industrial applications..

The asbestos in gaskets and packing canrange from simple asbestos felt or rope to composites of cement, rubber, graphite,metal or other materials.

The temperature, pressure andcorrosiveness of the pipe fill, clampingpressure, composition of the gasket andpacking all affect the ease of maintenancetasks. The size and composition of thegasket or packing, its condition and theextent to which it is adhered are the majordeterminants of potential airborne fiberlevels. The more damaged the gasket orpacking (e.g. by a corrosive pipe fill), themore it is adhered to the flange or valve,the greater the potential for release ofdebris and airborne asbestos. The O&Mdesigner should make separate exposureassessments for different anticipated levelsof difficulty of maintenance work ongaskets or packing. This means, forexample, all of the low temperature, lowpressure piping with a particular type ofgasket could be considered as a group. During design of the O&M, an assignmentof an O&M level and specific workpractices could reasonably be made foreach piping system for removal of gasketsand packings. This activity can beintegrated with other regulatorycompliance activities such as thoserequired by OSHA for process safetymanagement. The asbestos controlrequirements could be indicated on theP&ID for various systems.

OSHA sets forth specific Class II workrequirements for gasket removal in 29CFR 1926.1101(g)(8)(iv) C If a gasket is visibly deteriorated and

unlikely to be removed intact, removalshall be undertaken within aglovebag...

C The gasket shall be thoroughly wettedwith amended water prior to itsremoval.

C The wet gasket shall be immediatelyplaced in a disposal container.

C Any scraping to remove residue mustbe performed wet

These C requirements should work wellon a small piping system for water orsteam that can be worked on cold such asmight be found in a school or officebuilding. In an industrial setting theseprocedures may be infeasible for somecircumstances. Glovebag use is notfeasible on hot or large pipes, and isdangerous when power tools (such as awire brush on a drill) are used. Wetting isnot feasible on hot or freezing piping, orwhere water is incompatible with the pipefill. Usually, airborne fiber levels duringgasket or packing removals can be keptbelow the OSHA PEL by use of wetting(where feasible), careful handling and theuse of HEPA vacuums for materialcollection and local exhaust ventilation. Fortunately, OSHA allows someflexibility in complying with theregulation. There are two possiblealternative courses the O&M designer cantake to comply with OSHA.

Class II: OSHA allows the use of“Alternative Work Practices and Controls”as long as worker exposures will notexceed the PELs. The OSHA regulation29 CFR 1926.1101(g)(8)(vi) requires that“the different or modified controls reduce



direct and indirect employee exposure tobelow the PELs under all expectedconditions of use and that the methodmeets the requirements of this [sic. theOSHA] standard.” for details. The controlsdeveloped by the O&M designer mustreliably keep airborne fiber levels belowthe PELs. The work area where thesecontrols are to be applied must beevaluated by a competent person.

Class III: OSHA allows Class II work thatremoves no more material than will fit ina 60" disposal bag to be classified as ClassIII work. Class III work can be performedwithout enclosure as long as a NegativeExposure Assessment (NEA) is made. Refer to the introduction for moreinformation on making an NEA.

In either instance the O&M designer is

allowed to develop work practices for theremoval of gaskets and packings that arepractical for a specific application and thatcomply with OSHA requirements. However, unless Class II (glovebag)procedures are followed, the O&Mdesigner has the burden of demonstratingthat the procedures are effective incontrolling worker exposures to below thePELs.

NOTE: Removal of a gasket or packingfrequently involves the removal of thermalsystem insulation. O&M procedures forTSI removal are described in Section V ofthis manual. The O&M designer shouldcoordinate the work practices of thissection with the TSI removal workpractices.

Examples

Work practices for the following situations are provided as examples. They should beedited as required for the particular conditions in a facility.

WARNING: These work practices include “Alternative Work Practices and Controls.” The O&M program designer must be a competent person as defined by OSHA, and mustmake an evaluation that PELs will not be exceeded during use of the work practices, ormust make a Negative Exposure Assessment (NEA) for work conducted using these workpractices.

Level A: The example work practice is for a situation where the gasket/packing comes out in onepiece, and no residue needs to be removed. This could cover a great proportion of non-industrial cases. The O&M designer will need to determine if this work practice appliedto a packing which unwinds from around a valve stem, but comes out in one piece.A. Remove and replace non-adhered gasket/packing that can be removed intact.

Level B: This work practice is an example of a site specific work practice that can be developedfor removal of gaskets/packing that is damaged or adhered to its seat. During design ofthe work practice the O&M designer (who must be a competent person) needs to eithermake the determination that airborne fiber levels during the use of the work practice willnot exceed the OSHA PELs required for an alternative Class II work practice, or needs tomake an NEA . To meet Class II requirements the designer must certify in writing thatuse of the work practice will, “reduce direct and indirect employee exposure to below thePELs under all expected conditions of use,” and that the work practice meets the



requirements of the OSHA standard. Each time that work is assigned the asbestosprogram manager (APM) must evaluate the work area and make a determination thatconditions at the specific job site are equivalent to those that existing during developmentof the work practice, so that the work practice is applicable. The need for Level B workpractices that are site specific will usually greater on industrial sites, locations whereworkers will frequently be working on gaskets, and where pipes are hot, cold or filledwith a material incompatible with water. The example work procedure is based on wetmethods. If water cannot be used, then the work practice will rely more on careful workpractices, and local exhaust ventilation. If work on gaskets/packing is an infrequentevent, it may be simpler to follow the OSHA glovebag procedure than to develop a sitespecific procedure.

A. Remove and replace gasket/packing that is damaged or adhered to the gasket seat. .

Level C: OSHA requires that a glovebag procedure be used unless a site specific alternativeprocedure is developed. Glovebags are a Level C procedure. This example containsthree alternatives: the OSHA glovebag, a mini-enclosure, and a site specific localventilation procedure. A. Remove and Replace a pipe flange gasket where power tools are required to remove

residue of old gasket/packing. B. Remove and replace a large friable door hatch gasket that is in poor condition, or

other large gaskets in poor condition.

Related Work PracticesT 1 Remove insulation on exposed pipe for maintenance work.T 3 Remove insulation on exposed pipe in elevated location for maintenance work.T 6 Repair damaged thermal system insulation on a boiler, duct or flue.

Worker Recommendations One worker for Level A and Level B. Two workers for Level C. A person with airmonitoring training might be required. This person can be the worker.


M21 . Level AReplace asbestos-containing gaskets/packing


A. Remove and replace non-adhered gasket/packing that can be removed intact.


If asbestos-containing thermal system insulation must be removed to permit access forgasket/packing replacement, use the appropriate work practice from Section V “ThermalSystems Insulation (TSI) Work Practices,”of this manual. Complete the Section V workpractice before starting the work of this section.




b. Tools required to access gasket

c. Replacement materials



5. Disassemble equipment as needed to expose entire gasket.

6. Remove gasket and place into disposal bag. Wet-wipe flange where gasket wasinstalled.

7. Install new gasket and reassemble equipment



M21 . Level BReplace asbestos-containing gaskets/packing


A. Remove and replace gasket/packing that is damaged or adhered to the gasket seat. .


If asbestos-containing thermal system insulation must be removed to permit access forgasket/packing replacement, use the appropriate work practice from Section V “ThermalSystems Insulation (TSI) Work Practices,”of this manual. Complete the Section V workpractice before starting the work of this section.

If active electrical equipment is in work area, do not wet equipment, stop work, notifyyour supervisor.




b. Tools required to access and work remove gasket or packing



4. Prepare work area with drop cloth and complete Worker General Procedure W10“Polyethylene Drop Cloth.”


6. If pipe is hot or cold put on protective equipment as required.

7. Remove thermal system insulation (TSI) as necessary using procedures from SectionV “Thermal Systems Insulation (TSI) Work Practices,”of this manual.

8. Disassemble equipment as needed to expose entire gasket/packing.

9. Remove gasket/packing using the following procedures:

a. Use this procedure if a negative exposure assessment (NEA) has been made. Ifyou do not know if an NEA has been made, stop work, and notify yoursupervisor.

b. Wet gasket with amended water. If wetting is not practical due to temperature ofpipe or nature of pipe fill, stop work, and notify your supervisor



c. Use careful handling and local exhaust ventilation with a HEPA vacuum toremove the gasket/packing. .

d. Carefully scrape gasket from seat while holding nozzle of HEPA vacuum inproximity to the flange or packing box. Immediately place pieces of gasket indisposal bag. Try to remove gasket in as few pieces as possible.

e. Promptly pick up any debris with a HEPA vacuum

f. Clean residue from surface of seat using wet methods. Keep work sitecontinuously wet.

g. If power tools are needed to remove residue of old gasket/packing, stop work,and notify your supervisor. Level C work practices are to be used for this type ofwork.

h. HEPA vacuum and wet wipe surfaces to which gasket was attached.

10. Install new gasket/packing and reassemble equipment.



M21 . Level CReplace asbestos-containing gaskets/packing


A. Remove and Replace a pipe flange gasket where power tools are required to removeresidue of old gasket/packing.

B. Remove and replace a large friable door hatch gasket that is in poor condition, orother large gaskets in poor condition.

NotesIf asbestos-containing thermal system insulation must be removed to permit access forgasket/packing replacement, use the appropriate work practice from Section V “ThermalSystems Insulation (TSI) Work Practices,”of this manual. Complete the Section V workpractice before starting the work of this section.




b. Tools required to access and work on remove gasket or packing


d. Glovebag (if required)



5. Use one of the following procedures to remove gasket/packing:

a. Perform work inside a glovebag. If use of a glovebag is not feasible ordangerous, the pipe is over 150°F., or if entire gasket/packing will not fit in aglovebag, stop work and notify your supervisor. Adequately wet gasket andremove gasket and debris using glovebag procedures. See General ProcedureW18 “Glovebag Removal.” DO NOT USE POWER TOOLS INSIDE OF AGLOVEBAG. If scrubbing pads and nylon/wire brushes will not completelyremove residue of old gasket/packing, stop work, and notify your supervisor.

b. Perform work inside a mini-enclosure:

i. Erect mini-enclosure and set up negative pressure system and/or HEPAfiltered local exhaust ventilation according to General Procedure W20“Mini-Enclosure”

ii. Place tools, equipment and materials needed into enclosure.

iii. Enter enclosure and disassemble equipment as needed to expose entiregasket/packing.



iv. Wet gasket with amended water. If wetting is not practical due totemperature of pipe or nature of pipe fill, stop work, and notify yoursupervisor

v. Use careful handling and local exhaust ventilation with a HEPA vacuum toremove the gasket/packing. .

vi. Carefully scrape gasket from seat while holding nozzle of HEPA vacuum inproximity to the flange or packing box. Immediately place pieces of gasketin disposal bag. Try to remove gasket in as few pieces as possible.

vii. Promptly pick up any debris with a HEPA vacuum

viii. Clean residue from surface of seat using wet methods. Keep work sitecontinuously wet.

ix. If power tools are needed to remove residue of old gasket/packing, use localexhaust ventilation as described below.

x. HEPA vacuum and wet wipe surfaces to which gasket was attached.

c. Local Exhaust Ventilation: If power tools (wire brush on a drill) are needed toremove residue of old gasket/packing use the following procedure. DO NOTATTEMPT TO USE THIS PROCEDURE INSIDE OF A GLOVEBAG.

i. Attach a manufactured or job-built collection attachment to nozzle of HEPAvacuum that is large enough to capture material coming from operating wirebrush.

ii. Install plastic drop cloth behind HEPA vacuum collection attachment.

iii. Wet residue with amended water.

iv. Remove residue with wire brush. Direct stream of removed material intoHEPA vacuum attachment .

v. Wet wipe and HEPA inside of attachment and surfaces from which residuewas removed.

6. HEPA vacuum and/or wet wipe surfaces to which gasket was attached.

7. Install new gasket, reassemble equipment and perform maintenance work required.

8. Clean-up and tear-down steps on Level C checklist to complete work.


M22 . SummaryEmptying and changing filter in HEPAvacuum or changing filter in HEPA fan unit

SummaryThis work practice covers the procedures for changing the bag, filter and/or cleaning aHEPA vacuum, or changing the filter in a HEPA filtered fan unit. The manufacturers ofHEPA vacuums publish work procedures for emptying and maintenance. Themanufacturer’s recommendations for the particular equipment in use at the facility shouldbe reviewed by the O&M designer and used as the basis for revision of these workpractices.

Examples

Level B: A. Empty HEPA vacuum bag using localized engineering controls.B. Change filter in HEPA fan unit.C. Change filter or bag in HEPA vacuum using a glovebag.

Level C: A. Empty bag, change filter and clean HEPA vacuum.B. Change filter in a HEPA fan unit in a mini-enclosure.


Worker Recommendations One worker for Level B. Two workers for Level C. A person with air monitoringtraining might be required. This person can be the worker.


M22 . Level BEmptying and changing filter in HEPAvacuum or changing filter in HEPA fan unit


A. Empty HEPA vacuum bag using localized engineering controls.B. Change filter in HEPA fan unit.C. Change filter or bag in HEPA vacuum using a glovebag.





b. Manufacturer's instructions for unit having filter or bag replaced

c. Tools as needed to remove filter or bag

d. Replacement filters or bags

e. Glovebag and hand operated spray bottle



5. Place tools, equipment and materials needed onto drop cloth, including HEPAvacuum or fan unit with filter or bag to be changed. If available, include an operableHEPA vacuum for cleaning up any dust or debris from the filter change operation.

6. Use one of the following procedures for changing filter bag

a. Use Glovebag to change filter or bag:

i. Insert new bag or filter, wet wiping cloths, and a hand-operated spray bottleinto glovebag.

ii. Seal glovebag to unit to permit access to filter or bag inside glovebag.

iii. Open unit and adequately wet filter or bag. Remove filter or bag and place incorner of glovebag. Wet wipe inside of unit.

iv. Install new filter or bag. Close unit and wet wipe inside of glovebag. Putwet wipes in corner of glovebag.



v. Twist, and tape glovebag to seal bag/filter/rags from spray bottle.

vi. Cut and remove glovebag from unit. Place glovebag into a disposal bag.

b. Change filter or bag using the manufacturer’s recommended work practice andthe following:

i. Carefully disassemble unit as needed to access filter and/or bag.

ii. Adequately wet filter and/or bag, remove from unit and place into disposalbag.

iii. Using operable HEPA vacuum or wet wiping, clean area where filter or bagwas installed.

7. Install new filter and/or bag in unit, reassemble unit and



M22 . Level CEmptying and changing filter in HEPAvacuum or changing filter in HEPA fan unit


A. Empty bag, change filter and clean HEPA vacuum.B. Change filter in HEPA fan unit in a mini-enclosure.

NotesThis procedure may be performed in an existing mini-enclosure, if available.




b. Manufacturer's instructions for unit having filter or bag replaced

c. Tools as needed to remove filter or bag

d. Replacement filters or bags




6. Place tools, equipment and materials needed into enclosure, including HEPA vacuumor fan unit with filter or bag to be changed.

7. Enter enclosure and carefully disassemble unit as needed to access filter or bag. Adequately wet filter and/or bag, remove from unit and place into disposal bag.

8. Adequately wet any remaining debris. Pick up debris or empty debris into a disposalbag.

9. Using operable HEPA vacuum or wet wiping, clean area where filter or bag wasinstalled.

10. Install new filter and/or bag in unit, reassemble unit and



M23 . SummaryRemove asbestos-wrapped wiring

SummaryThis work practice covers the workrequired to remove small amounts ofasbestos-wrapped electrical wiring forO&M work.

Work on asbestos insulated wiring isOSHA Class II work. If less than one 60"disposal bag of material is involved, thenthe work may be treated as Class III work. In either class, wetting is a required workpractice. Wetting of electrical wiring andequipment involves an obvious shockhazard. For that reason these are dry workpractices. In both Class II and III workOSHA allows some flexibility incomplying with the regulation. There aretwo possible alternative courses the O&Mdesigner can take to comply with OSHA.

Class II: OSHA allows the use of“Alternative Work Practices and Controls”as long as worker exposures will notexceed the PELs. The OSHA regulation29 CFR 1926.1101(g)(8)(vi) requires that“the different or modified controls reducedirect and indirect employee exposure tobelow the PELs under all expectedconditions of use and that the methodmeets the requirements of this [sic. theOSHA] standard.” The controlsdeveloped by the O&M designer mustreliably keep airborne fiber levels belowthe PELs. The work area where thesecontrols are to be applied must beevaluated by a competent person.

Class III: OSHA allows Class II work thatremoves no more material than will fit in a

60" disposal bag to be classified as ClassIII work. Class III work can be performeddry if a Negative Exposure Assessment(NEA) is made. Refer to the introductionfor more information on making an NEA.

In either instance the O&M designer isallowed to develop dry work practices forwork on electrical components. However,the O&M designer has the burden ofdemonstrating that the procedures areeffective in controlling worker exposuresto below the PELs.

Dry work must be approved by the EPANESHAP coordinator. This should bedone on an annual basis by the APM.

Note: Electrical work frequently occurs invaults and other confined spaces. OSHArequires training for workers in confinedspaces. Confined space entry is beyondthe scope of this document, but is anecessary component of an O&Mprogram. Refer to 29 CFR 1926.20(b)“General safety and health provisions,Accident prevention responsibilities,” and29 CFR 1926.21(b)(6) “Safety trainingand education, confined or enclosedspaces,” in the construction standard; and29 CFR 1910.146 in the general industrystandard for applicable statues. Thegeneral industry standard is much morespecific than and inclusive of theconstruction standard requirements. It isrecommended that the O&M programcomply with all three of these standardsfor all types of work.



Examples

Level A: A. Remove wiring in good condition on single stage spotlight where the insulation is notdisturbed.

Level B: A. Remove wiring in good condition on several stage spotlights.B. Remove asbestos wrapped wiring located in underground electrical vaults where

wrapping is in good condition. See APM8 “Confined Spaces,” for informationregarding confined space precautions.

Level C: A. Remove damaged wiring in poor condition.B. Remove asbestos wrapped wiring located in underground electrical vaults where

wrapping is in poor condition. See APM8 regarding confined space precautions.

Related Work PracticesConfined space entry procedure if required by conditions of the job.

Worker Recommendations One worker for Level A and Level B. Two workers are recommended for Level C and/orif work occurs in a confined space. Workers should be trained electricians with asbestostraining to perform this work. If the project involves confined space entry, all workersare required to have confined space entry training. A person with air monitoring trainingmight be required. This person can be the worker.


M23 . Level ARemove asbestos-wrapped wiring


A. Remove wiring in good condition on single stage spotlight where insulation is notdisturbed.

NotesDO NOT WET WIRING. This is a dry work procedure.

A Negative Exposure Assessment must have been made by a Competent Person beforethis work practice is used. Verify that a negative exposure assessment (NEA) has beenmade. If an NEA cannot be verified, stop work and notify your supervisor.

If work site is a confined space, use confined space entry procedures, another worker isrequired for these procedures. If you have not had confined space training, stop work,and notify your supervisor.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Electrician's insulated glovesc. Screwdriversd. Voltmeter or circuit tester.e. Soldering iron for soldered connections



5. Verify that electrical power to wiring is shut off and locked out. Test circuits usingvoltmeter or Circuit tester.

6. DO NOT WET WIRING.

7. Open any junction boxes or equipment as needed to remove wiring back to screwterminals or soldered connections. Disconnect wire at both ends without cutting wireor otherwise disturbing insulation. Remove intact wire without disturbing insulation. Do not drag wire through conduit, or through other wires.

8. Roll up wiring and place into disposal bags.

9. HEPA vacuum any surfaces that were in contact with wiring.

10. Install new wiring as necessary and perform maintenance work.

11. Clean-up and tear-down steps on Level A checklist to complete work.


M23 . Level BRemove asbestos-wrapped wiring


A. Remove wiring in good condition on several stage spotlights, where wiring must becut.

B. Remove asbestos wrapped wiring located in underground electrical vaults wherewrapping is in good condition. Perform work in accordance with facility confinedspace program.



If work site is a confined space, use confined space entry procedures, another worker isrequired for these procedures.




b. Electricians insulated gloves

c. Screwdrivers

d. Wire cutters

e. Voltmeter or circuit tester

f. Soldering iron for soldered connections



5. Verify that electrical power to wiring is shut off and locked out. Test circuits usingvoltmeter or circuit tester


7. DO NOT WET WIRE.

8. Cut out exposed wiring to be removed. Roll up wiring and place into disposal bags.



9. Open any junction boxes or equipment as needed to remove wiring back to screwterminals or soldered connections.

10. Disconnect remaining wiring from terminals or connections. Place wiring intodisposal bags.

11. HEPA vacuum any surfaces that were in contact with wiring.



M23 . Level CRemove asbestos-wrapped wiring


A. Remove damaged wiring in poor condition.

B. Remove asbestos wrapped wiring located in underground electrical vaults wherewrapping is in poor condition. Perform work in accordance with facility confinedspace program.


If work site is a confined space, use confined space entry procedures, another worker isrequired for these procedures.




b. Electricians insulated gloves

c. Screwdrivers

d. Wire cutters

e. Voltmeter or circuit tester.




6. Verify that electrical power to wiring is shut off and locked out. Test circuits usingvoltmeter or circuit tester.


8. DO NOT WET WIRE.

9. Enter enclosure, and cut out exposed wiring to be removed. Roll up wiring and placeinto disposal bags.

10. Open any junction boxes or equipment as needed to remove wiring back to screwterminals or soldered connections.

11. Cut or disconnect wiring from terminals or connections. Place wiring into disposalbags.



12. HEPA vacuum any surfaces that were in contact with wiring and any suspect visibledebris.

13. Perform maintenance work



M24 . SummaryRemove asbestos-containing caulking/glazingcompound

SummaryThis work practice describes the procedures for removing small amounts of asbestos-containing caulking compound as required for maintenance or repair work.

Examples

Level A: A. Remove a small amount of pliable caulking compound. No sanding will beperformed.

Level B: A. Reglaze several small window panes. No sanding will be performed.

B. Remove small amount of dry caulking compound.

Level C: A. Reglaze an entire window or several windows.


Worker Recommendations

One worker for Level A and Level B. Two workers for Level C. A person with airmonitoring training might be required. This person can be the worker.


M24 . Level ARemove asbestos-containing caulking/glazingcompound


A. Remove a small amount of pliable caulking compound. No sanding will beperformed.

NotesThis work practice must be used in conjunction with General Procedure W1 and a LevelA Worker Checklist. The worker checklist includes tasks that must be performed beforethese work practices are begun.

A Negative Exposure Assessment must have been made by a Competent Person beforethis work practice is used. Verify that a negative exposure assessment (NEA) has beenmade. If an NEA cannot be verified, stop work and notify your supervisor.







5. Using utility knife or edge of scraper, cut away caulking and place into disposal bags.

6. Remove any residual caulking using scraper and knife and place caulking intodisposal bags.

7. HEPA vacuum and/or wet wipe areas where caulking was removed. Use WorkPractice M22 if HEPA vacuum needs maintenance, or if bag or filter needs to bereplaced.

8. Perform maintenance work and



M24 . Level BRemove asbestos-containing caulking/glazingcompound


A. Reglaze several small window panes. No sanding will be performed.

B. Remove small amount of dry caulking compound.










6. Enter work area and adequately wet caulking to be removed using garden sprayerwith amended water.


8. Remove any residual caulking using scraper, knife and nylon brushes and placecaulking into disposal bags.

9. HEPA vacuum and wet wipe areas where caulking was removed.



M24 . Level CRemove asbestos-containing caulking/glazingcompound


A. Reglaze an entire window or several windows

Notes This work practice must be used in conjunction with General Procedures W1, W10and a Level C Worker Checklist. The worker checklist includes tasks that must beperformed before these work practices are begun.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1b. Scraper (2-3" wide stiff blade)c. Stiff nylon bristle brushes



5. Erect mini-enclosure and set up negative pressure system and/or HEPA filtered localexhaust ventilation on side of window with exposed caulking compound according toGeneral Procedure W20 “Mini-Enclosure”


7. Enter enclosure and adequately wet caulking to be removed using garden sprayerwith amended water.


9. Remove any residual caulking using scraper, knife and nylon brushes and placecaulking into disposal bags.

10. HEPA vacuum and wet wipe areas where caulking was removed.



M25 . SummaryClean room that has asbestos-containing dust

SummaryThis work practice should be used forroutine or special cleaning in rooms whereasbestos-containing dust is present, or isassumed to be present. This is useful insituations where an ACM may beperiodically disturbed (e.g. a softacoustical finish in reach of occupants). This work practice augments normalcleaning practice by adding HEPAvacuums and wet methods. It is intended

to substitute for normal cleaning practicesin locations where there could be aperiodic minor disturbance of an ACM. Cleaning with HEPA vacuums, wetmethods and dust removal methodsprevents the accumulation of asbestos inthe dust. The practices include thecleaning of furniture, fixtures, and othersurfaces.

ExamplesLevel A: A. Clean an office area where asbestos-containing dust may settle on furniture due to

periodic disturbance of an exposed ACM.

B. Clean a mechanical room where dust is assumed to contain ACM from thermalsystems insulation present in room.

Related Work PracticesS 9 Clean room with exposed surfaces finished with ACMR 5 Wet strip floor wax from resilient asbestos flooringR 6 Dry or spray buffing resilient asbestos flooringR 7 Cleaning resilient asbestos flooringM 20 Clean up debris from minor release

Worker Recommendations One worker trained in special cleaning procedures. A person with air monitoring trainingmight be required. This person can be the worker.


M25 . Level AClean room that has asbestos-containing dust


A. Clean an office area where asbestos-containing dust may settle on the floor, furnitureand horizontal surfaces due to periodic disturbance of an exposed ACM.

B. Clean a mechanical room where dust is assumed to contain ACM from thermalsystems insulation present in room.


This work procedure is intended for routine or periodic cleaning of a space. If youdiscover visible dust or debris, or a fallout of ACM, stop work, and notify yoursupervisor.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Dusting materials (cloths, dusters, mops) that are damp or are treated with

catatonic or anti-static dust attractant preparations.c. Furniture polish

3. Routine dusting: Using damp or treated dusting materials, clean surfaces beginningfrom the top of the room and working towards the floor. Do not dry dust. HEPAvacuum surfaces that are not easily cleaned with dusting materials.

4. Routine vacuuming: Perform routine vacuuming with HEPA vacuums. HEPAvacuum surfaces such as drapes and fabric covered surfaces by starting at the top andworking towards floor. HEPA vacuum carpet as last step after all dusting. Use WorkPractice M22 “Emptying and changing Filter in HEPA Vacuum” if HEPA vacuumneeds maintenance, or if bag or filter needs to be replaced.

5. Routine floor cleaning: Dust mop using damp mops or treated dusting mops. Washfloors using normal mopping procedures. HEPA vacuum carpeting. Maintainresilient flooring using work practices R5, R6 and R7. Do not dry dust. Do not usevacuum a vacuum cleaner without a HEPA filter.

6. Periodic cleaning: Surfaces that are not routinely cleaned are to be cleaned duringperiodic cleaning using wet methods or HEPA vacuums. Wet wipe smooth hard



surfaces (such as blinds) or wash with paper towels or disposable cloths using workpractices of General Procedure W9 “Wet Wiping, HEPA Vacuuming and SteamCleaning.” HEPA vacuum cloth or textured surfaces. Dispose of all dirty cloths andsoiled dusting materials while still damp in ACM disposal bags.

7. Apply new polish where needed using standard procedures.


VII. Resilient FlooringWork Practices

R - 3 # Resilient Flooring # Asbestos O&M Work Practices # © NIBS 1996 # Page - 349

Section VII. Resilient Flooring Work PracticesResilient Flooring Location Illustration . . . . . . . . . . . . . . . . . . . . . . . 348Code Levels DescriptionR1 A B+ Removal of resilient asbestos floor tiles . . . . . . . . . . . . . . . . . . 360R2 A B+ Replacement of vinyl sheet flooring with ACM backing . . . . . 370R3 A Install new resilient flooring or carpet over resilient asbestos

flooring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 377R4 A B+ Install partition over resilient asbestos flooring . . . . . . . . . . . . . 379R5 A Wet strip floor wax from resilient asbestos flooring . . . . . . . . . 382R6 A Dry or spray buffing resilient asbestos flooring . . . . . . . . . . . . 385R7 A Cleaning resilient asbestos flooring . . . . . . . . . . . . . . . . . . . . . . 388R8 A B+ Remove carpet over resilient asbestos flooring . . . . . . . . . . . . . 391

The accompanying diagram illustrates typical applications of the above workpractices.

GENERAL NOTESWork Practice Levels Thelevels for each work practice includedin this section are defined principallyin relation to the OSHA asbestosstandards. There are two standardsthat may apply. The OSHAconstruction standard, 29 CFR1926.1101, applies to most O&Mactivities that involve removal ofresilient flooring. Normal cleaning,and buffing of resilient flooring that isnot associated with construction orother O&M work is covered by theOSHA general industry standard, 29CFR 1910.1001. When maintenanceand custodial activities are incidentalto construction this work is Class IVunder the construction standard,1026.1101.

In general, an O&M program is easierto implement and is more costeffective if maintenance work can beperformed without the need forenclosures. Maintenance work thatcontacts or disturbs asbestos-

containing materials (ACM) isgoverned by OSHA. To be able toperform maintenance work governedby the Construction Standard(1926.1101) without an enclosure andstill comply with OSHA, it isnecessary to make a negative exposureassessment. This effectively makesthe OSHA PEL a limit on the level ofairborne asbestos that can be generatedby a work practice before enclosure isrequired. In general, Level A and B+maintenance work practices are un-enclosed and as such require anegative exposure assessment.

The two work practice levels in thissection are defined as follows:

Level A: is Class II work with anegative exposure assessment thatinvolves removal or repair of resilientfloor covering materials. It alsoencompasses certain housekeepingoperations, such as cleaning, buffingor polishing of resilient flooring,


governed by the general industrystandard, 29 CFR 1910.1001, whereinitial monitoring is required for suchwork unless: (1) a determination hasbeen made that these activities usingthe work practices in this manual(which are based on those contained inthe OSHA regulations ) are notreasonably expected to result inexposures exceeding the PEL; (2) theemployer has monitored after March31, 1992 for the TWA permissibleexposure limit and/or excursion limitand the monitoring satisfies therequirements of 1910.1001(d); or (3)the employer has relied on objectivedata (see pg. 4-8 for explanation ofobjective data). In addition,housekeeping operations performedincidental to construction work aregoverned by the construction standard,29 CFR 1926.1101(l), and are alsowithin Level A when an NEA has beenmade in accordance with paragraph1926.1101(f)(2).

Level B+: Level B+ is removal ofresilient flooring materials that are notintact, or will become non-intactduring removal, or where a negativeexposure assessment cannot be made. Augmented Level B+ work practicescan be used for work on resilientflooring where flooring materialsbecome friable, if the OSHA PEL isnot exceeded and release of ACM,dust and debris is confined to theimmediate location of the disturbance. To comply with OSHA, Level B+work practices used for this purposerequire the addition of critical barriersto the respiratory protection, airmonitoring and other work practicesnormally associated with Level Bwork. If more that a small quantity ofmaterial is disturbed during the work,then the activity exceeds the limitationof the work practices in this manual. Refer to the NIBS manual ModelGuide Specifications, AsbestosAbatement and Management inBuildings for more information.

USING THE RESILIENT FLOOR COVERINGMANUFACTURER’S RECOMMENDED WORK PRACTICESFOR THE REMOVAL OF RESILIENT FLOORINGThe Resilient Floor Covering Institute(RFCI) and Armstrong WorldIndustries (hereinafter referred to asthe Resilient Floor CoveringManufacturers) have developed workpractices that apply to the removal ofasbestos and non-asbestos-containingresilient floor covering materials. Some of the Level A work proceduresin this section are based on those work

practices. Work procedures thatincorporate the RFCM procedures arenoted as (RFCM Procedures).

OSHA revised its asbestos standard, inAugust of 1994. Resilient flooringmanufacturers filed petitions forjudicial review of parts of the standard. A settlement agreement resolvingthese petitions was reached withOSHA on June 15, 1995 before a court


decision was rendered. This“Settlement Agreement” is included inAppendix D to the OSHA ComplianceDirective that relates to the new OSHAstandard (CPL 2-2.63, November 3,1995, Inspection Procedures forOccupational Exposure to AsbestosFinal Rule 29 CFR Parts 1910.1001,1926.1101, and 1915.1001). TheO&M designer and asbestos programmanager should acquire a copy of theOSHA Compliance Directive from thelocal OSHA office and review itduring the development of facilityspecific work procedures for resilientflooring.

The EPA NESHAP regulation (40CFR Part 61, Subpart M) addresses thehandling and disposal of ACM duringrenovation and demolition ofbuildings. The position of the EPA onresilient flooring was clarified in theNovember 1990 revision of theNESHAP regulation. Asbestos-containing resilient floor products aredefined by this regulation as aCategory I nonfriable material, whichis not regulated by the NESHAPunless it becomes friable or issubjected to sanding, grinding, cuttingor abrading. Cutting in this instanceincludes sawing, but not shearing,slicing or punching. The EPA hasdetermined that resilient flooringmaterials that have not been madefriable before or during the work donot need to be disposed of as asbestoswaste.

Any work procedures used must, at aminimum, meet the requirements ofthe OSHA and NESHAP regulations.

This introduction describes the stepsnecessary to insure that O&Mactivities using the Manufacturers’Recommended Work Practices will bein compliance with these regulations. The O&M designer and APM shouldrealize that state or local regulationsmay have requirements that differ fromfederal regulations and some may bemore stringent. The work proceduresin this section may have to bemodified to comply with state or localregulations.

OSHA: During development of theOSHA regulation exposure data forworkers involved in removal ofresilient flooring was submitted. Inthe Settlement Agreement with theflooring manufacturers, OSHA agreedthat data submitted during therulemaking shows that removal ofasbestos-containing resilient flooringmaterial consistently results in workerexposures below the PEL (both theTWA and excursion limit), as long ascertain work practices are followed. These work practices are referred to as“compliant work practices.” OSHAhas determined that a data set calledthe “Environ Data” is an example ofthis sort of exposure data, and thatwork practices recommended by theresilient floor covering manufacturersis an example of compliant workpractices. This means that the EnvironData can be used as the basis for a“Negative Exposure Assessment” aslong as the “Recommended WorkPractices” are used, and the materialremains “intact” throughout theremoval process. If a negative


exposure assessment is made OSHAdoes not require that the work area beenclosed or that workers wearrespirators or other asbestos specificprotective clothing. Some of the LevelA work procedures in this section arebased on the manufacturers’“Recommended Work Practices.”

During design of the O&M program,the O&M designer needs to make adetermination that a negative exposureassessment (NEA) is feasible forO&M work involving removal ofresilient flooring using theRecommended Work Practices. Thisshould be done before this work ispermitted under the O&M program asa Level A activity. An administrativeframework should be established toensure that a negative exposureassessment is made and documentedfor each resilient flooring project. Thiscan be accomplished by making theAPM responsible for the NEA. This isappropriate if the workers are directlysupervised by the APM, and the APMis acting on behalf of the buildingowner or property manager whoemployees the workers. In thisinstance the APM must be acompetent person as required byOSHA for work on intact resilientflooring. The APM should evaluateeach O&M project to insure OSHAcompliance before issuing a workorder. This can be documented byhaving the APM complete the job formfrom “Using Compliant WorkPractices to Remove Resilient FloorCovering” (see Appendix E) publishedby the Resilient Floor Covering

Institute (RFCI) and Armstrong WorldIndustries, Inc. This form should besigned by the APM as the CompetentPerson making the negative exposureassessment. The designer needs todecide if any additional proceduresneed to be added to comply with theowner’s goals for the O&M program. If O&M work on resilient flooring isgoing to contracted out refer to theNIBS Model Guide Specification,Asbestos Abatement and Managementin Buildings for more information.

There are several steps necessary toinsure OSHA compliance when usingthe recommended work practices forO&M work. These must beaccomplished by the APM to insureOSHA compliance.

! A negative exposure assessmentmust be made by the competentperson. The OSHA asbestosrulemaking record contains manymeasurements, collected under avariety of worksite conditions,showing worker exposures duringremovals of asbestos-containing“flooring material” (floor tile,sheet vinyl floor covering andflooring adhesive). As part of theSettlement Agreement, OSHA hasagreed that these data show thatuse of Compliant Work Practicesduring removal of intact flooringmaterial consistently result inworker exposures below the TWAand Excursion Limit established bythe revised OSHA standard. Assuch, before removal begins aCompetent Person trained underrequirements set forth in the


Settlement Agreement may assessthe job and make a negativeexposure assessment when:

! Compliant (Recommended)Work Practices will be used. Work practices R1 and R2 arebased on “Recommended WorkPractices for the Removal ofResilient Floor Coverings,” revisedAugust, 1995, published by theResilient Floor Covering Institute(RFCI) and Armstrong WorldIndustries, Inc. OSHA has agreedthat these “Recommended WorkPractices” are an example ofcompliant work practices. If thesework practices need to be modifieddue to specific circumstances of afacility, caution should be used toinsure that the changes do notchange their status as examplesrecognized by OSHA.. If anychange is going to be made to thework procedures, the O&Mdesigner should refer to theoriginal “Recommended WorkPractices” and the OSHACompliance Directive to insurethat the new procedure is still a“Compliant Work Practice”

! Workers are properly trained.Workers using the RecommendedWork Practices for the removal ofresilient floor covering materialsmust have completed an 8-hourtraining program as required by theOSHA regulation 29 CFR1926.1101 and the compliancedirective. The course must coverasbestos subjects as well astraining in the Recommended

Work Practices. A CompetentPerson involved in removal ofintact flooring material usingcompliant work practices musthave completed an 8-hour workertraining program and additional 4hours of training (a total of 12hours of training) as required bythe Settlement Agreement.

! The resilient flooring is intactand is likely to remain intactthroughout the removal process. Intact in this instance means thatthe ACM has not crumbled, beenpulverized, or otherwisedeteriorated so that it is no longerlikely to be bound with its matrix. In the Settlement AgreementOSHA agreed that the incidentalbreakage of flooring material,including slicing of sheet vinylfloor covering with a sharp-edgedinstrument, during removaloperations using “Compliant WorkPractices” does not mean that thematerial is not removed in an“intact” condition. Rather, theissue of whether flooring materialis “intact” is determined bywhether the flooring material(whether broken or not) hascrumbled, been pulverized, or hasotherwise deteriorated so that it isnot likely to be bound with itsmatrix.

A Negative Exposure Assessment isnot justified if these three conditionsare not met. If a negative exposureassessment is not or cannot be made,


or if applicable OSHA exposure limitsare exceeded, other provisions andrequirements of the OSHA asbestosregulation remain in full force andeffect.

If a job begins as an intact removal,but the material being removedbecomes non-intact or no longer canbe removed intact, work must bestopped until workers and a competentperson with the appropriate trainingand engineering controls required fornon-intact (or aggressive) removalmethods, are put into place. For adiscussion of these removal methods,refer to the NIBS Model GuideSpecifications Asbestos Abatement andManagement in Buildings specificationsection 02087, “Resilient FlooringRemoval - Aggressive AsbestosAbatement.” OSHA reserved the rightto reconsider its determination that anegative exposure assessment forparticular floor removal operationsmay be based solely on the data in therulemaking record if OSHA field dataor other information, weighed againstthe data in the rulemaking record,show that exposures during particularfloor removal operations in whichcompliant work practices are used arelikely to exceed the TWA or ExcursionLimit.

! A “Competent Person” mustsupervise the work and haveauthority to take promptcorrective measures to eliminatehazards to the health and safetyof workers. This does not meanthat the Competent Person isrequired to be on-site at all times

during the work, but that personmust inspect the job site frequentlyand regularly, at any time at anemployee request, and at otherappropriate times, such as to accessif conditions have changed. (Notethat a project may have more thanone Competent Person.) For workon intact resilient flooring, theCompetent Person must, as aminimum, have the 12 hours oftraining required by OSHA for aCompetent Person involved inremoval of intact flooring materialusing compliant work practices. Ifnon-intact resilient flooring isinvolved, or if the flooring cannotbe removed intact, then thecompetent person must havecompleted a 40 hour trainingcourse meeting the criteria ofEPA’s Model Accreditation Planfor supervisors. The trainingrequired for intact resilient flooringremoval differs from that requiredfor competent persons for otherasbestos abatement activities. Most other abatement activitiesrequire a minimum of 40 hours oftraining for a Competent Person, asopposed to the 12 hours requiredfor intact resilient flooring work. The training required for resilientflooring work could be included inthe longer course, but this needs tobe verified by the designer.

! Recommended Work practicesmust be used. The designer mustinsure that the work proceduresused in a facility are equivalent tothe “Recommended Work


Practices” published by theresilient flooring manufacturers. Work practices R1 and R2 areequivalent to the “RecommendedWork Practices” which OSHA hasaccepted as an example of“Compliant Work Practices.” Ifthese work practices need to bemodified to suit conditions in aparticular facility, the designershould make a determination aboutwhether the work practice isequivalent to the “RecommendedWork Practices.” A negativeexposure assessment will benecessary before using a workprocedure that is changed enoughthat it is no longer equivalent. Refer to the NIBS Model GuideSpecification Asbestos Abatementand Management in Buildingsspecification Section02085"Resilient Flooring Removal- Resilient Floor Covering

Manufacturers’ RecommendedWork Practices,” for informationon additional work practices.

! Compliance with OSHA is aminimum requirement. If theowner or O&M designer wants tospecify more stringent standardsthan OSHA requires, then refer tothe section later in this introductionon “Optional Quality ControlMeasures.”

! Compliance with state and localregulations: In addition to federalregulations, various other state andlocal government agencies haveregulations governing the removalof in-place ACM. Some state andlocal regulations differ fromfederal regulations and may bemore stringent. It is recommendedthat the specifier determinewhether such regulations apply.

CONSIDERATIONS REGARDING THE USE OF WORKPRACTICES R1 AND R2: The use of work practices R1 and R2is dependent upon a competent personmaking a Negative ExposureAssessment (NEA) as describedabove. The O&M designer and theAsbestos Program Manager should befamiliar with the requirements for theNEA and with the OSHA ComplianceDirective (2-2.63 November 3, 1995)that sets forth these requirements. TheO&M designer should be convincedthat it is realistic to make an NEA formaterials and conditions in the facility.

Compliant work practices such as the

Manufacturers’ Recommended WorkPractices upon which work practicesR1 and R2 are based, when followed,can provide an effective means tocontrol occupational exposures belowthose limits set by OSHA. [The airmonitoring performed for OSHAexposure monitoring does notdistinguish between asbestos and non-asbestos fibers and cannot measure theshort or thin fibers that may bedetected using transmission electronmicroscopy (TEM) analysis.] Refer toAPM-6 for more information on air


monitoring

O&M program designers consideringresilient flooring removal workpractices should consider means toprevent influence of other asbestosrelated work on any clearancemonitoring (especially using TEManalysis) which may be specified forthe flooring removal. The reverse, i.e.,preventing influence from the flooringremoval project on the TEMclearances of other asbestos relatedwork, should also be considered. Methods to consider include propersequencing of the different removalprojects, use of critical barriers andproject decontamination procedures,and having the resilient flooringremoval performed using the“Optional Quality Control Measures”discussed later in this introduction.

Use of compliant work practices suchas the Manufacturers’ RecommendedWork Practices upon which workpractices R1 and R2 are based, havebeen found by OSHA to consistentlyresult in worker exposures below theTWA and Excursion Limit establishedby the revised OSHA standard. However, under certain circumstancessuch as sanding, drilling, sawing, ormechanical chipping the flooringmaterial may be rendered (or alreadyhave been rendered) friable or notintact. In general, Level B+ workerand area protection work practices

should be used if flooring material hasbeen found to be asbestos-containingand is or becomes friable or not intact,or if additional quality controlmeasures are desired.

If asbestos-containing resilient floorcovering material is found to befriable, or becomes friable duringremoval, it is regulated as ACM underthe NESHAP, and NESHAPnotification, emission control,transportation and waste disposalrequirements may apply. Similarly, iffloor covering in schools (grades K-12) is or becomes friable, removalperformed as an abatement action iscovered by EPA Asbestos EmergencyResponse Act (AHERA, 40 CFR763.90(I)(v)) regulations, and design,contractor and abatement workeraccreditation, and area clearancerequirements apply for work greaterthan small-scale, short duration.

To obtain a complete copy of the workpractices booklet and/or a copy of the reports discussed above, contact:

Resilient Floor Covering Institute966 Hungerford Drive, Suite 12-bRockville, Md 20850(301)340-8580

Armstrong World Industries, Inc.P.O. Box 3001Lancaster, Pa 17604(800) 438-5954


Optional Quality Control Measures

This section presents several optionalquality control measures that thedesigner may want to consider whenworking in occupied buildings,although these measures are notrequired by OSHA. These optionalmeasures can provide a range ofquality assurances for the ownerincluding: assurance that asbestosfibers will not migrate beyond thework area in case of method failure;indication of whether the workpractices are performing as expected;and indication of whether additionalclean-up is necessary.

! Critical Barriers: Criticalbarriers over openings into thework area may be specified: if theowner or designer wants tophysically isolate the work fromadjacent areas, for example, inoccupied buildings, or if there is arequirement for TEM clearancesampling in an adjacent abatementwork area. This can be specifiedby adding Worker GeneralProcedure W5 “Critical Barriers”to the work practice.

! Air Monitoring: The Owner mayspecify air monitoring inside thearea where work is occurring toverify that the work practices areresulting in airborne asbestoslevels within the owner’sparameters. Air monitoring maybe performed in adjacent areas toassure that these areas are notaffected by the work. Airmonitoring may be desired to help

avoid conflicts with TEMclearance of adjacent asbestosabatement project areas. This canbe specified by adding WorkerGeneral Procedure W 8“Beginning and Conduction AirMonitoring” and/or W16 “VisualInspection and Completing AirMonitoring” to the work practice.

! Full-time On-site CompetentPerson: The owner or O&Mdesigner may specify a full-timeon-site competent person tosupervise the work and help assurethat flooring materials stay intactduring the entire work process andthat proper work practices arefollowed throughout the job. Thiscan be accomplished by addingthis specification at the beginningof the work practice.

! Respirators: The owner ordesigner may specify respiratoryprotection for workers to assureminimal exposure to airborneasbestos, including fibers whichare not counted under the OSHAstandard. This can be specified byadding Worker General ProcedureW6 “Putting On Respirators andPerforming Fit Checks” to thework practice.

! Worker Decontamination: TheOwner to Designer may specifyworker decontamination (e.g.workers HEPA vacuuming offclothing while standing on dropcloths) as an additional assurance


that asbestos-containing debris ordust will not be carried to areasoutside the work area, or toworkers’ homes. If respirators arespecified, there should be somesort of worker decontaminationprocedure to precede removal ofrespirators. Worker GeneralProcedure W15 “WorkerDecontamination and Removal ofProtective Clothing andRespiratory,” contains workpractices such as changing suitsand HEPA vacuuming workers as a

dry decontamination procedure. These work practices can beadapted by adding W15 to thework practice.

! Other Controls: If other controlssuch as bagging and labelingclothing and equipment can bespecified by adding the appropriateWorker General Procedure to thework practice.

CLEANING, POLISHING AND BUFFING RESILIENTFLOORING:Level A: This work is defined in terms of“housekeeping” in the general industrystandard (29 CFR 1910.1001) and theconstruction standard (29 CFR1926.1101(l). It encompasses certainhousekeeping operations, such ascleaning, buffing or polishing of resilientflooring, governed by the general industrystandard, 29 CFR 1910.1001, whereeither: (1) a determination has been madethat these activities using the workpractices in this manual (which are basedon those contained in the OSHAregulations ) are not reasonably expectedto result in exposures exceeding the PEL;(2) the employer has monitored afterMarch 31, 1992 for the TWA permissibleexposure limit and/or excursion limit andthe monitoring satisfies the requirementsof 1910.1001(d); or (3) the employer hasrelied on objective data (see pg. 4-8 forexplanation of objective data). Inaddition, housekeeping operationsperformed incidental to construction work

are governed by the construction standard,29 CFR 1926.1101(l), and are also withinLevel A when an NEA has been made inaccordance with paragraph1926.1101(f)(2). See Level A2 in Figure2 in the introduction for a checklist ofrequirements.

Work practices: required for this workare those set forth in the OSHA generalindustry standard for non-construction-related housekeeping activities.Awareness training is required forworkers. Paragraph (k) of the generalindustry standard has specificrequirements for stripping of finishes andburnishing or dry buffing asbestos-containing flooring. Work practices R5“Wet Strip Floor Wax from ResilientFlooring,” R6 “Dry or Spray BuffingResilient Asbestos Flooring,” and R7“Cleaning Resilient Asbestos Flooring,”are based on the OSHA work practices.


NESHAP: The NESHAP regulates the disposal ofACM. Non-friable materials such asresilient flooring are treated differentlyfrom friable materials such as surfacingmaterials and thermal system insulation. Resilient floor covering is classified by theEPA NESHAP as Category 1 non-friableACM. If Category I ACM has becomefriable, or will become friable, or has been

or will be subjected to sanding, grinding,cutting or abrading, it is defined asRegulated ACM by NESHAP, and itswetting, labeling and disposalrequirements apply. State and localregulations may have differentrequirements, and these may be morestringent.

OTHER CONSIDERATIONS:Careful work practices should be theprimary means used to prevent releases ofasbestos fibers during O&M work. Suchpractices include control measures such aswetting and local exhaust that control orcollect fibers at the source. The goal of allasbestos O&M work should be to prevent

any exposure of the worker andunnecessary contamination of the workarea, drop cloths, mini-enclosures andother secondary control devices. Mini-enclosures should never be used to excusesloppy work or creation of "bigger"messes.


R1 . SummaryRemoval of resilient asbestos floor tiles

SummaryThis work practice covers the O&M procedures for removing small amounts of asbestos-containing floor tile and/or mastic. The work practices are based on the RFCMprocedures.

ExamplesLevel A: A. Replacement of several floor tiles that are loose or can be removed with minimal or

no breakage, and tile and/or mastic does not become friable.

B. Remove a small area of well-adhered tile and/or mastic that is not likely to becomefriable.

C. Remove several floor tiles and mastic to drill hole(s) in subfloor to attach object tofloor or install a pipe or conduit.

Level B+: A. Replacement of a small area of tiles that are sufficiently damaged that the tile and/ormastic will become friable during removal.

B. Remove a tile and mastic which may become friable during removal.

C. Remove several floor tiles and mastic that are sufficiently damaged that the tileand/or mastic will become friable during removal to drill hole(s) in subfloor to attachobject to floor or install a pipe or conduit.

Related Work PracticesR 2 Replacement of vinyl sheet flooring with ACM backing.

Worker Recommendations: One worker for Level A work. One or two workers for Level B+ depending upon safetyand efficiency considerations. For Level B+ a person with air monitoring training mightbe required. This person can be a worker.


R1 . Level AReplacement of resilient asbestos floor tiles

ExampleThe following are examples of work that can be performed using the procedures of thisLevel A work practice.

A. Replacement of several floor tiles that are loose or can be removed with minimal orno breakage, and tile and/or mastic does not become friable.

B. Remove a small area of well-adhered tile and/or mastic that is not likely to becomefriable.

C. Remove of several floor tiles and mastic to drill hole(s) in subfloor to attach object tofloor or install a pipe or conduit.

NotesRFCM Procedure. This work practice is based on the resilient floor coveringmanufacturers recommended work practice. You must have had a minimum of 8 hoursof training in the use of the recommended work practices including hands on training todo the work of this procedure. A Negative Exposure Assessment must have been madeby a Competent Person before this work practice is used.

Warning: Do not sand resilient flooring. Do not use this procedure for activities thatcrumble, pulverize, or otherwise deteriorate resilient flooring to the extent that it is nolonger bound with its matrix.

If job conditions change, stop work and notify your supervisor.


2. Verify that a negative exposure assessment (NEA) has been made. If an NEA cannotbe verified, stop work and notify your supervisor.

3. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Weighted scraper with long handlec. Wall scraper 2-3" (50-75 mm) wide stiff blade w/short handled. Commercial-type hand-held hot air blower or radiant heat source e. Safety glassesf. Wet/dry type HEPA vacuum with hose and attachments with metal floor toolg. Garden sprayer with amended waterh. Hammeri. Crushed dry ice (for procedure 5B) - approximately 1 lb (0.5 kg) per sq.ft. (0.1 )


5. Complete Worker General Procedure W4 “Secure Work Area “

R1 . Level A ... continued


6. Use the following procedure to remove resilient tile floor covering:

a. Floor tiles must be wetted (misted with a garden sprayer) before actual removalbegins, unless heat will be used to remove tiles.

b. Start removal by carefully wedging a wall scraper in the seam of two adjoiningtiles and gradually forcing the edge of one of the tiles up and away from thefloor. Continue to force the balance of the tile up by working the scraper beneaththe tile. Exert both a forward pressure and a twisting action on the blade topromote release of the tile from the adhesive and the floor.

c. When the tile is removed place it, without breaking it further into smaller pieces,in a waste bag or waste container.

d. If it is necessary to remove more tiles to accomplish the work, after the first tile isremoved and accessibility to other tiles is improved, force the wall scraper underthe exposed edge of another tile. Continue to exert a prying twisting force to thescraper as it is moved under the tile until the tile releases from the floor. Again,dispose of the tile, by placing in a waste bag or waste container withoutadditional breaking. Continue in this manner until enough tiles are removed toaccomplish the work.

e. Force the scraper through tightly-adhered areas by striking the scraper handlewith a hammer using blows of moderate force while maintaining the scraper at a25 to 30 degree angle to the floor. The resilient floor covering manufacturers’work practices recommend the use of safety goggles during this work.

f. Continue to wet (mist) the tiles throughout the procedure

g. It should be the goal to remove individual tiles as a complete unit, althoughbreakage of tiles is unavoidable.

h. If the procedure above is inadequate to loosen tiles use heat to soften adhesive, oralternatively, without first prying up floor tiles using a scraper, thoroughly heatthe tile(s) with a hot air gun or radiant heat source until the heat penetratesthrough the tile and softens the adhesive, and remove tiles by hand or by using ascraper. The resilient floor covering manufacturers work practices recommendthat the hot air gun or radiant heat source, tiles and adhesive be carefullyhandled to avoid burns, and that heated tiles and adhesive be handled only withsuitable glove protection for hands. Caution: Over-heating resilient tile mightproduce harmful vapors, and a respirator with organic vapor cartridges might beneeded.

i. Deposit tiles in a waste bag or leak-tight container. Do not attempt to break tilesafter they are in bag.

j. Wet scrape residual adhesive.



7. Dry ice tile removal procedures: This method can be used as an alternative to themanufacturers’ recommended work practices for removal of tiles:

a. Caution: The use of dry ice produces carbon dioxide that can result in anoxygen deficiency in the work area. Dry ice can also cause frostbite to workersand damage building materials.

b. Spread crushed dry ice over tiles to be removed. Let dry ice freeze mastic andrelease tile. Use short-handled scraper to pry up tiles.

c. When the tile is removed, place it, without breaking it, in disposal bags orcontainers which will be used for disposal. Removed tiles can be placed inempty tile cartons first and then placed in the disposal bags. To prevent tearingof the bag, place a maximum of one full carton of removed tile in a bag.

d. Wet scrape residual adhesive.

8. Wet Scrape Residual Adhesive: After removing tile always wet scrape the residualadhesive to remove any loose material using the following procedure so that noridges or puddles are evident and what remains is a thin, smooth film.

a. Moisten the adhesive with water mixed with liquid dishwashing detergent (to aidin wetting the adhesive). Wet scrape with a stiff-bladed wall or floor scraperremoving ridges and any loose adhesives.

b. Place loosened adhesive residues into a waste bag or waste container

c. Wet vacuum standing water with HEPA wet/dry vacuum. Use Work PracticeM31 if HEPA vacuum needs maintenance, or if bag or filter needs to be replaced.

d. Continue the above steps until what remains of the residual asphaltic “cut-back”adhesive is a thin, smooth film.

9. Wet Remove residue of adhesive from Concrete with Wet Sand and RubbingStones: If work that could disturb the adhesive residue, such as drilling through thefloor, is going to occur, completely remove residue of adhesive left after removal ofresilient floor tile using either this procedure or the removal solution procedure thatfollows:

a. Place a small amount of cutting sand (enough to cover area of removed tile) intoa container, add water mixed with liquid detergent (1 ounce ( 30 ml) of liquiddishwashing detergent to 1 gallon (3.79 liters) of water) to dampen the sand (20pounds (9.07 kg ) of sand to ½ gallon (1.89 liters) of solution).

b. Place sand over area of removed tile and wet remove the existing adhesiveresidue with a hand held rubbing stone. The sand and subfloor must becontinuously kept wet.

c. Occasionally push away cutting sand from the subfloor with a wall or floorscraper to check for complete removal.

d. Wet-scrape sand into a pile using a stiff-bladed floor or wall scraper and placesand and adhesive residue in a waste bag or waste container.



e. Rinse area with clear clean water using a hand sprayer. Avoid getting sand onboots. Worker’s boots should also be rinsed and cleaned if necessary

f. Wet-vacuum standing water with HEPA wet/dry vacuum with a metal floorattachment (no brush).

g. Continue with the above steps until adhesive is completely removed in therequired area.

h. Allow subfloor to dry and vacuum up any remaining dirt or sand using a vacuumequipped with a HEPA filter and metal floor attachment (no brush).

i. Use Work Practice M22 if HEPA vacuum needs maintenance, or if bag or filterneeds to be replaced. .

j. Wet-wipe and/or wash down all equipment used during the work.

10. Wet Remove residue of adhesive from Concrete with Removal Solution: If workthat could disturb the adhesive residue, such as drilling through the floor, is going tooccur, completely remove residue of adhesive left after removal of resilient floor tileusing either the following procedure or the previous wet sand and rubbing stoneprocedure:

a. Put the removal solution onto the residual adhesive with a hand sprayer or ragover the area of removed tile. Put enough removal solution (e.g. “mop on, mopoff, no machine scrub” stripping solution) to ensure that the area is thoroughlywet. Allow the area to soak for 5-10 minutes. Remove the adhesive by handscrubbing with a piece of a black floor pad (or equivalent). The subfloor must bekept continuously wet.

b. Occasionally push away the adhesive slurry from the subfloor with a wall orfloor scraper to check for complete removal. Continue to scrub the floor with theblack pad, in the same area until the concrete subfloor is cleaned to the desireddegree.

c. Wet HEPA vacuum the adhesive slurry. When the HEPA vacuum is full, place acommercially suitable water absorbent into the HEPA container until theadhesive slurry is absorbed. Use Work Practice M22 if HEPA vacuum needsmaintenance, or if bag or filter needs to be replaced.

d. Rinse area with clear clean water using a hand sprayer or mop. Avoid gettingremover on boots. Worker’s boots should also be rinsed and cleaned ifnecessary.

e. Wet-vacuum standing water with HEPA wet/dry vacuum with a metal floorattachment (no brush).

f. Continue with the above steps until adhesive is completely removed in therequired area.

g. Allow subfloor to dry and vacuum using a vacuum equipped with a HEPA filterand metal floor attachment (no brush).

h. Use Work Practice M22 if HEPA vacuum needs maintenance, or if bag or filterneeds to be replaced.



i. Wet-wipe and/or wash down all equipment used during the work.

11. Perform required clean-up and tear-down steps on Level A checklist to completework.


R1 . Level B+Replacement of resilient asbestos floor tiles

ExampleThe following are examples of work that can be performed using the procedures of thisLevel B+ work practice.

A. Replacement of a small area of badly damaged tiles that are sufficiently damaged thatthe tile and/or mastic will become friable during removal.

B. Remove a tile and mastic which may become friable during removal.

C. Remove several floor tiles and mastic that are sufficiently damaged that the tileand/or mastic will become friable during removal to drill hole(s) in subfloor to attachobject to floor or install a pipe or conduit.

NotesBefore starting work you must have, at no cost to you, have: been supplied with theproper respirator and trained in its use, have received at least 32 hours of training as anasbestos abatement worker and in safe work practices and in the use of the equipmentfound on the job, and had a medical examination made available. If these things have notbeen done, stop work, and notify your supervisor.

Warning: Do not sand resilient flooring.

Use caution to prevent fire in the work area if heat sources are used.

Work Practice1. Perform Pre-work activities on Level B+ checklist.


3. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Weighted scraper with long handlec. Wall scraper 2-3" (50-75 mm) wide stiff blade w/short handled. Commercial-type hand-held hot air blower or radiant heat source e. Safety glassesf. Wet/dry type HEPA vacuum with hose and attachments with metal floor toolg. Garden sprayer with amended waterh. Hammeri. Crushed dry ice (if needed) - approximately 1 lb (0.5 kg) per sq.ft. (0.1 )



6. Complete Worker General Procedure W5 “Critical Barriers”

R1 . Level B+ ... continued


7. Use the following procedure to remove resilient tile floor covering:

a. Floor tiles must be wetted (misted with a garden sprayer) before actual removalbegins, unless heat will be used to remove tiles.

b. Start removal by carefully wedging a wall scraper in the seam of two adjoiningtiles and gradually forcing the edge of one of the tiles up and away from thefloor. Continue to force the balance of the tile up by working the scraper beneaththe tile. Exert both a forward pressure and a twisting action on the blade topromote release of the tile from the adhesive and the floor.

c. When the tile is removed place it, without breaking it further into smaller pieces,in a waste bag or waste container.

d. If it is necessary to remove more tiles to accomplish the work, after the first tile isremoved and accessibility to other tiles is improved, force the wall scraper underthe exposed edge of another tile. Continue to exert a prying twisting force to thescraper as it is moved under the tile until the tile releases from the floor. Again,dispose of the tile, by placing in a waste bag or waste container withoutadditional breaking. Continue in this manner until enough tiles are removed toaccomplish the work.

e. Force the scraper through tightly-adhered areas by striking the scraper handlewith a hammer using blows of moderate force while maintaining the scraper at a25 to 30 degree angle to the floor. The resilient floor covering manufacturerswork practices recommends use of safety goggles during this work.

f. Continue to wet (mist) the tiles throughout the procedure

g. It should be the goal to remove individual tiles as a complete unit, althoughbreakage of tiles is unavoidable.

h. If the procedure above is inadequate to loosen tiles use heat to soften adhesive, oralternatively, without first prying up floor tiles using a scraper, thoroughly heatthe tile(s) with a hot air gun or radiant heat source until the heat penetratesthrough the tile and softens the adhesive, and remove tiles by hand or by using ascraper. The resilient floor covering manufacturers work practices recommendthat the hot air gun or radiant heat source, tiles and adhesive be carefullyhandled to avoid burns, and that heated tiles and adhesive be handled only withsuitable glove protection for hands.

i. Deposit tiles in a waste bag or leak-tight container. Do not attempt to break tilesafter they are in bag.

j. Wet scrape residual adhesive.

8. Dry ice tile removal procedures: This method can be used as an alternative to themanufacturers’ recommended work practices for removal of tiles:

a. Caution: The use of dry ice produces carbon dioxide that can result in anoxygen deficiency in the work area. Dry ice can also cause frostbite to workersand damage building materials.



b. Spread crushed dry ice over tiles to be removed. Let dry ice freeze mastic andrelease tile. Use short-handled scraper to pry up tiles.

c. When the tile is removed, place it, without breaking it, in disposal bags orcontainers which will be used for disposal. Removed tiles can be placed inempty tile cartons first and then placed in the disposal bags. To prevent tearingof the bag, place a maximum of one full carton of removed tile in a bag.

d. Wet scrape residual adhesive.

9. Wet Scrape Residual Adhesive: After removing tile always wet scrape the residualadhesive to remove any loose material using the following procedure so that noridges or puddles are evident and what remains is a thin, smooth film.

a. Moisten the adhesive with water mixed with liquid dishwashing detergent (to aidin wetting the adhesive). Wet scrape with a stiff-bladed wall or floor scraperremoving ridges and any loose adhesives.

b. Place loosened adhesive residues into a waste bag or waste container

c. Wet vacuum standing water with HEPA wet/dry vacuum. Use Work PracticeM22 if HEPA vacuum needs maintenance, or if bag or filter needs to be replaced.

d. Continue the above steps until what remains of the residual asphaltic “cut-back”adhesive is a thin, smooth film.

10. Wet Remove residue of adhesive from Concrete with Wet Sand and RubbingStones: If work that could disturb the adhesive residue, such as drilling through thefloor, is going to occur, completely remove residue of adhesive left after removal ofresilient floor tile using either this procedure or the removal solution procedure thatfollows:

a. Place a small amount of cutting sand (enough to cover area of removed tile) intoa container, add water mixed with liquid detergent (1 ounce ( 30 ml) of liquiddishwashing detergent to 1 gallon (3.79 liters) of water) to dampen the sand (20pounds (9.07 kg ) of sand to ½ gallon (1.89 liters) of solution).

b. Place sand over area of removed tile and wet remove the existing adhesiveresidue with a hand held rubbing stone. The sand and subfloor must becontinuously kept wet.

c. Occasionally push away cutting sand from the subfloor with a wall or floorscraper to check for complete removal.

d. Wet-scrape sand into a pile using a stiff-bladed floor or wall scraper and placesand and adhesive residue in a waste bag or waste container.

e. Rinse area with clear clean water using a hand sprayer. Avoid getting sand onboots. Worker’s boots should also be rinsed and cleaned if necessary

f. Wet-vacuum standing water with HEPA wet/dry vacuum with a metal floorattachment (no brush).

g. Continue with the above steps until adhesive is completely removed in therequired area.



h. Allow subfloor to dry and vacuum up any remaining dirt or sand using a vacuumequipped with a HEPA filter and metal floor attachment (no brush).

i. Use Work Practice M22 if HEPA vacuum needs maintenance, or if bag or filterneeds to be replaced. .

j. Wet-wipe and/or wash down all equipment used during the work.

11. Wet Remove residue of adhesive from Concrete with Removal Solution: If workthat could disturb the adhesive residue, such as drilling through the floor, is going tooccur, completely remove residue of adhesive left after removal of resilient floor tileusing either the following procedure or the previous wet sand and rubbing stoneprocedure:

a. Put the removal solution onto the residual adhesive with a hand sprayer or ragover the area of removed tile. Put enough removal solution (e.g. “mop on, mopoff, no machine scrub” stripping solution) to ensure that the area is thoroughlywet. Allow the area to soak for 5-10 minutes. Remove the adhesive by handscrubbing with a piece of a black floor pad (or equivalent). The subfloor must bekept continuously wet.

b. Occasionally push away the adhesive slurry from the subfloor with a wall orfloor scraper to check for complete removal. Continue to scrub the floor with theblack pad, in the same area until the concrete subfloor is cleaned to the desireddegree.

c. Wet HEPA vacuum the adhesive slurry. When the HEPA vacuum is full, place acommercially suitable water absorbent into the HEPA container until theadhesive slurry is absorbed. Use Work Practice M22 if HEPA vacuum needsmaintenance, or if bag or filter needs to be replaced.

d. Rinse area with clear clean water using a hand sprayer or mop. Avoid gettingremover on boots. Worker’s boots should also be rinsed and cleaned ifnecessary.

e. Wet-vacuum standing water with HEPA wet/dry vacuum with a metal floorattachment (no brush).

f. Continue with the above steps until adhesive is completely removed in therequired area.

g. Allow subfloor to dry and vacuum using a vacuum equipped with a HEPA filterand metal floor attachment (no brush).

h. Use Work Practice M22 if HEPA vacuum needs maintenance, or if bag or filterneeds to be replaced.

i. Wet-wipe and/or wash down all equipment used during the work.

12. Perform required clean-up and tear-down steps on Level B checklist to completework.


R2 . SummaryReplacement of vinyl sheet flooring with ACMbacking

SummaryThis work practice covers the O&M procedures for the replacement of small amounts ofvinyl sheet flooring with ACM backing. Wet scraping of residual felt is included in bothLevels.

ExamplesLevel A: A. Replacement of a small area of loose or perimeter-adhered vinyl sheet flooring with

ACM backing.

B. Replacement of a small area of adhered vinyl sheet flooring with ACM backing thatcan be removed using non-aggressive, primarily manual methods. Some separationof backing and wear layer will occur.

C. Remove small amounts of resilient asbestos flooring covering to drill hole(s) insubfloor to attach object to floor or install a pipe or conduit.

Level B+: A. Replacement of a small area of vinyl sheet flooring with ACM backing which issufficiently damaged to be friable

B. Removal of a small area of vinyl sheet flooring with ACM backing which maybecome friable during removal.

C. Remove small amounts of resilient asbestos flooring covering which may becomefriable during removal to drill hole(s) in subfloor to attach object to floor or install apipe or conduit.

Related Work PracticesR 1 Replacement of resilient asbestos floor tiles.

R 3 Install new resilient flooring or carpet over resilient asbestos flooring.

R 8 Remove carpet over resilient asbestos flooring.

Worker Recommendations: Two workers for Level A or B+ depending upon safety and efficiency considerations. For Level B+ a person with air monitoring training might be required. This person canbe a worker.


R2 . Level AReplacement of vinyl sheet flooring with ACMbacking

ExampleThe following are examples of work that can be performed using the procedures of thisLevel A work practice.

A. Replacement of a small area of loose or perimeter-adhered vinyl sheet flooring withACM backing.

B. Replacement of a small area of adhered vinyl sheet flooring with ACM backing thatcan be removed using non-aggressive, primarily manual methods. Some separationof backing and wear layer will occur.

C. Remove small amounts of resilient asbestos flooring covering to drill hole(s) in subfloorto attach object to floor or install a pipe or conduit.

NotesRFCM Procedure. This work practice is based on the resilient floor coveringmanufacturers recommended work practice. You must have had a minimum of 8 hoursof training in the use of the recommended work practices including hands on training todo the work of this procedure. A Negative Exposure Assessment must have been madeby a Competent Person before this work practice is used.

Warning: Do not sand resilient flooring. Do not use this procedure for activities thatcrumble, pulverize, or otherwise deteriorate resilient flooring to the extent that it is nolonger bound with its matrix.



3. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Weighted scraper with long handlec. Wall scraper 2-3" (50-75 mm) wide stiff blade w/short handled. Commercial-type hand-held hot air blower or radiant heat source e. Safety glassesf. Wet/dry type HEPA vacuum with hose and attachments with metal floor toolg. Garden sprayer with amended waterh. Hammeri. Hook knife





6. Use the following procedure to completely remove adhered resilient sheet flooring.

a. Use a minimum of two workers for this procedure.

b. Slice around area to be removed. Make a series of parallel slices, with a knife, 4to 8 inches (102 to 203 mm) apart parallel to a wall.

c. Pry up the corner of the first strip, separating the backing layer. As the strip isbeing removed, spray a constant mist of the detergent solution into thedelamination nip point to minimize any airborne dust particles. When doneproperly, any felt remaining on the floor and on the back of the strip will bethoroughly wet. Peel the strip either by pulling upward at an angle that permitsthe best separation or by rolling around a core.

d. Roll the strip tightly as it is removed. Tie or tape securely and immediately placein a waste bag or waste container for disposal.

e. If parts of the foam inner-layer remain stuck to the backing, attempt to eliminatethis condition by pulling the strips loose from the opposite end. Peel the foaminner-layer from the floor while spraying the detergent solution into thedelamination nip point.

f. Some resilient flooring is not readily strippable by hand. When these conditionsare encountered, a sharp stiff blade scraper may be used to assist cleavage of thewearlayer from felt. If this procedure is used the distance between slices mustbe narrowed to a width of 3 to 5 inches (76 to 127 mm).

g. Regardless of whether stripping of the wear surface is accomplished by handpeeling alone or with the assistance of a stiff blade scraper, detergent solutionmust be sprayed into the delamination nip point to minimize any airborne dustparticles.

h. After removing three strips of the wear surface, remove the remaining residualfelt by wet scraping using the procedures "Wet Scraping Residual Felt," in thissection. During the stripping process, do not stand or walk on the exposed felt.

i. After removing the three strips of flooring and residual felt vacuum the exposedfloor using a wet/dry vacuum equipped with a HEPA filter and metal floorattachment (no brush).

j. Repeat the operation (wetting the delamination nip point while removing the nextthree strips, then wet scrape the residual felt, then vacuum the exposed floor). Repeat as necessary until enough flooring is removed to accomplish the work. Do only one three-strip area at a time.

k. Place all flooring strips and felt scrapings immediately while wet into waste bagsor waste containers. Close full bags and containers tightly and seal securely fordisposal.

l. Do not dry sweep. Avoid creating dust.

m. When all floor covering has been completely removed, let the floor dry. Vacuum up any dirt using a vacuum with a HEPA filtration system and a metalfloor attachment (no brush). Stand only in the vacuumed area as the work



proceeds across the floor. Position the vacuum cleaner so the discharge air doesnot blow on the floor being cleaned.

n. After vacuuming, remove used HEPA filters and cleaner bags in accordance withPractice M22.

7. Remove any residual felt remaining on the floor after removal of the wearlayer ofadhered vinyl sheet flooring by using the following procedure:

a. Thoroughly wet residual felt with detergent solution. Avoid excessive wetting orstanding water. Wait a few minutes to allow solution to soak into felt.

b. Stand on the remaining floor covering (not the felt) and use a stiff-bladed scraperor a floor scraper with a replaceable blade to remove the wet felt.

c. Re-wet the felt if the solution has not completely penetrated, if drying occurs orif dry felt is exposed during scraping. Scrape all felt from each three-strip areabefore proceeding further. Pick up the scrapings as they are removed from thefloor and place in a waste bag or waste container.

d. Wet residual felt as above but do not excessively soak or flood wood floors withdetergent solution. Excessive water can damage wood floors to the extent thatnew underlayment could be required. A floor that has been wet scraped must beallowed to dry thoroughly before new resilient flooring is installed.

e. As removal progresses, vacuum the area using a vacuum cleaner equipped with aHEPA filter and metal floor attachment (no brush).

f. After removal is complete and the entire floor has dried, vacuum using a HEPAvacuum with a metal floor attachment (no brush).

g. After vacuuming, remove used HEPA filters and cleaner bags in accordance withPractice M22.

8. Disposal of materials: Dispose of friable materials in accordance with WorkerGeneral Procedure W17 “Waste Transportation, Storage and Disposal.”

9. Perform required clean up and tear-down steps on Level A checklist to completework.


R2 . Level B+Replacement of vinyl sheet flooring with ACMbacking

ExampleThe following are examples of work that can be performed using the procedures of thisLevel B+ work practice.

A. Replacement of a small amount vinyl sheet flooring with ACM backing which issufficiently damaged to be friable

B. Removal of a small amount vinyl sheet flooring with ACM backing which maybecome friable during removal.

C. Remove small amounts of resilient asbestos flooring covering which may becomefriable during removal to drill hole(s) in subfloor to attach object to floor or install apipe or conduit.

NotesBefore starting work you must have, at no cost to you, have: been supplied with theproper respirator and trained in its use, have received at least 32 hours of training as anasbestos abatement worker and in safe work practices and in the use of the equipmentfound on the job, and had a medical examination made available. If these things have notbeen done, stop work, and notify your supervisor.

This work practice is based on the resilient floor covering manufacturers recommendedwork practice. A Negative Exposure Assessment must have been made by a CompetentPerson before this work practice is used.

Warning: Do not sand resilient flooring.



3. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Weighted scraper with long handlec. Wall scraper 2-3" (50-75 mm) wide stiff blade w/short handled. Commercial-type hand-held hot air blower or radiant heat source e. Safety glassesf. Wet/dry type HEPA vacuum with hose and attachments with metal floor toolg. Garden sprayer with amended waterh. Hammer



i. Hook knife



6. Use the following procedure to completely remove adhered resilient sheet flooring.

a. Use a minimum of two workers for this procedure.

b. Slice around area to be removed. Make a series of parallel slices, with a knife, 4to 8 inches (102 to 203 mm) apart parallel to a wall.

c. Pry up the corner of the first strip, separating the backing layer. As the strip isbeing removed, spray a constant mist of the detergent solution into thedelamination nip point to minimize any airborne dust particles. When doneproperly, any felt remaining on the floor and on the back of the strip will bethoroughly wet. Peel the strip either by pulling upward at an angle that permitsthe best separation or by rolling around a core.

d. Roll the strip tightly as it is removed. Tie or tape securely and immediately placein a waste bag or waste container for disposal.

e. If parts of the foam inner-layer remain stuck to the backing, attempt to eliminatethis condition by pulling the strips loose from the opposite end. Peel the foaminner-layer from the floor while spraying the detergent solution into thedelamination nip point.

f. Some resilient flooring is not readily strippable by hand. When these conditionsare encountered, a sharp stiff blade scraper may be used to assist cleavage of thewearlayer from felt. If this procedure is used the distance between slices mustbe narrowed to a width of 3 to 5 inches (76 to 127 mm).

g. Regardless of whether stripping of the wear surface is accomplished by handpeeling alone or with the assistance of a stiff blade scraper, detergent solutionmust be sprayed into the delamination nip point to minimize any airborne dustparticles.

h. After removing three strips of the wear surface, remove the remaining residualfelt by wet scraping using the procedures "Wet Scraping Residual Felt," in thissection. During the stripping process, do not stand or walk on the exposed felt.

i. After removing the three strips of flooring and residual felt vacuum the exposedfloor using a wet/dry vacuum equipped with a HEPA filter and metal floorattachment (no brush).

j. Repeat the operation (wetting the delamination nip point while removing the nextthree strips, then wet scrape the residual felt, then vacuum the exposed floor). Repeat as necessary until enough flooring is removed to accomplish the work. Do only one three-strip area at a time.

k. Place all flooring strips and felt scrapings immediately while wet into waste bagsor waste containers. Close full bags and containers tightly and seal securely fordisposal.



l. Do not dry sweep. Avoid creating dust.

m. When all floor covering has been completely removed, let the floor dry. Vacuum up any dirt using a vacuum with a HEPA filtration system and a metalfloor attachment (no brush). Stand only in the vacuumed area as the workproceeds across the floor. Position the vacuum cleaner so the discharge air doesnot blow on the floor being cleaned.

n. After vacuuming, remove used HEPA filters and cleaner bags in accordance withPractice M22.

7. Remove any residual felt remaining on the floor after removal of the wearlayer ofadhered vinyl sheet flooring by using the following procedure:

a. Thoroughly wet residual felt with detergent solution. Avoid excessive wetting orstanding water. Wait a few minutes to allow solution to soak into felt.

b. Stand on the remaining floor covering (not the felt) and use a stiff-bladed scraperor a floor scraper with a replaceable blade to remove the wet felt.

c. Re-wet the felt if the solution has not completely penetrated, if drying occurs orif dry felt is exposed during scraping. Scrape all felt from each three-strip areabefore proceeding further. Pick up the scrapings as they are removed from thefloor and place in a waste bag or waste container.

d. Wet residual felt as above but do not excessively soak or flood wood floors withdetergent solution. Excessive water can damage wood floors to the extent thatnew underlayment could be required. A floor that has been wet scraped must beallowed to dry thoroughly before new resilient flooring is installed.

e. As removal progresses, vacuum the area using a vacuum cleaner equipped with aHEPA filter and metal floor attachment (no brush).

f. After removal is complete and the entire floor has dried, vacuum using a HEPAvacuum with a metal floor attachment (no brush).

g. After vacuuming, remove used HEPA filters and cleaner bags in accordance withPractice M22.

8. Disposal of materials: Dispose of friable materials in accordance with WorkerGeneral Procedure W17 “Waste Transportation, Storage and Disposal.”

9. Perform required clean up and tear-down steps on Level B checklist to completework.


R3 . SummaryInstall new resilient flooring or carpet overresilient asbestos flooring

SummaryThis procedure covers the work required to prepare resilient asbestos flooring for theinstallation of new resilient flooring or carpet. This procedure works with work practiceR5 for stripping asbestos flooring and assumes that any damaged flooring has beenrepaired or replaced using applicable work practices such as R1 and R2.

Examples

Level A: A. New carpet being installed over well-adhered resilient asbestos floor tile or vinylsheet flooring with ACM backing in good condition.

Related Work PracticesR 1 Replacement of resilient asbestos floor tiles

R 2 Replacement of vinyl sheet flooring with ACM backing.

R 5 Wet strip floor wax from resilient asbestos flooring

R 6 Buffing resilient asbestos flooring

R 7 Cleaning resilient asbestos flooring

Worker Recommendations:

One worker is usually sufficient. Two or more workers may be needed to increaseefficiency or for additional health and/or safety considerations. A person with airmonitoring training might be required. This person can be a worker.


R3 . Level AInstall new resilient flooring or carpet overresilient asbestos flooring

ExampleThe following is an example of work that can be performed using the procedures of thisLevel A work practice.

A. New carpet being installed over well-adhered resilient asbestos tile or vinyl sheetflooring with ACM backing in good condition.

NotesThis work practice must be used in conjunction with General Procedure W1 and a LevelA Worker Checklist. The worker checklist includes tasks that must be performed beforethese work practices are begun.

Review manufacturer's recommendations concerning installation of new flooring overexisting before proceeding with this work.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Wall scraper 2-3" (50-75 mm) wide stiff blade w/short handle



5. HEPA vacuum.

6. Strip wax/finish from existing floor using O&M work practice R5 “Wet Strip Waxfrom Resilient Asbestos Flooring.

7. Level off any minor high spots on floor using scraper. Promptly remove anyscrapings with a HEPA vacuum. Do not sand or grind flooring.

8. Fill any low areas using manufacturers recommended underlayment or Levelingcompound.

9. Vacuum floor using a vacuum equipped with a HEPA filter and metal floorattachment (no brush).

10. Use Work Practice M22 if HEPA vacuum needs maintenance, or if bag or filter needsto be replaced.

11. Wet-wipe and/or wash down all equipment used scrape floor during the work.

12. Install new flooring or carpet as recommended by manufacturer.

13. Perform clean-up and tear-down on Level A checklist to complete work


R4 . SummaryInstall partition over resilient asbestosflooring

SummaryThis work practice describe the proceduresfor installing a wall over resilient asbestosflooring that will remain in place. Ifflooring will be removed for wallinstallation, use work practice R1 or R2.

Note: It may be more efficient to removeflooring using R1 or R2 and then installpartition.

ExamplesLevel A: A. Install partition over resilient asbestos flooring that is well adhered and in good

condition.

Level B+: A. Install partition over resilient asbestos flooring that becomes friable during thepartition installation.


R 2 Replacement of vinyl asbestos sheet flooring with ACM backing.


Worker Recommendations: One worker. Two workers may be beneficial for erecting partition. A person with airmonitoring training might be required. This person can be a worker.


R4 . Level AInstall partition over resilient asbestosflooring


A. Install partition over resilient asbestos flooring that is well-adhered and in goodcondition.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Anchoring devices and equipmentc. Non-asbestos adhesive


4. Install base plate of wall on full bed of adhesive and attach to floor using appropriateanchoring devices.

5. HEPA vacuum any chips or dust generated during fastening operation. Use WorkPractice M22 if HEPA vacuum needs maintenance, or if bag or filter needs to bereplaced.

6. Complete installation of wall.

7. Perform cleanup and tear down steps on Level A checklist to complete work.


R4 . Level B+Install partition over resilient asbestosflooring

ExampleThe following is an example of work that can be performed using the procedures of thisLevel B+ work practice.

A. Install partition over resilient asbestos flooring that becomes friable during thepartition installation.

NotesIt might be more efficient to remove flooring using R1 or R2 and then install partition.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Anchoring devices and equipmentc. Non-asbestos adhesive


4. Complete Worker General Procedure W10 “Setting Up Work Areas”

5. Complete Worker General Procedure W5 “Critical Barriers”


7. Using garden sprayer with amended water, adequately wet flooring area where workis to be done.

8. Level off any minor high spots on floor using scraper. Do not sand or grind flooring.

9. Remove any damaged vinyl asbestos flooring in area of work using O & M workpractice R1 or R2.

10. Fill any low areas using manufacturers recommended Leveling compound.

11. Install base plate of wall on full bed of adhesive and attach to floor using appropriateanchoring devices.

12. HEPA vacuum any chips or dust generated during fastening operation. Use WorkPractice M22 if HEPA vacuum needs maintenance, or if bag or filter needs to bereplaced.

13. Complete installation of wall.

14. Perform cleanup and tear down steps on Level B checklist to complete work.


R5 . SummaryWet strip floor wax from resilient asbestosflooring

SummaryThis work practice covers the proceduresfor stripping floor wax or finish fromresilient asbestos flooring. Do not stripdamaged flooring. Any loose or damagedflooring should be repaired or replacedbefore stripping is started. Wet stripping,if performed properly, should not causedamage to resilient flooring. If anyflooring damage occurs during stripping,

stop work and make repairs usingapplicable work practice(s). Do not drystrip, scrape, sand, or grind resilientasbestos flooring to remove any blemishesor imperfections.

This procedure is based on the OSHArequirements issued in 1994 as set forth in29 CFR 1910.1001(l).

ExampleLevel A: A. Stripping floor wax or finish coat from resilient asbestos flooring that is well adhered

and in good condition.



R 6 Dry or Spray Buffing resilient asbestos flooring.

R 7 Cleaning resilient asbestos flooring.

Worker Recommendations: One worker trained in wet stripping procedures for resilient asbestos flooring. A personwith air monitoring training might be required. This person can be the worker.


R5 . Level AWet strip floor wax from resilient asbestosflooring

ExampleThe following is example of work that can be performed using the procedures of thisLevel A work practice.

A. Strip floor wax or finish coat from resilient asbestos flooring that is well-adhered andin good condition.

NotesDo not strip damaged flooring. Any loose or damaged flooring should be repaired orreplaced before stripping is started. Wet stripping, if performed properly, should notcause damage to resilient flooring. If any flooring damage occurs during stripping, stopwork and make repairs using applicable work practice(s). Do not dry strip, scrape, sand,or grind resilient asbestos flooring to remove any blemishes or imperfections.

This procedure is based on OSHA requirements as set forth in 29 CFR 1910.1001(l).

Stripping pads should be kept wet during use and rinsed thoroughly immediately after useand prior to storage. Dispose of pads, if contaminated, as ACM waste in labeled disposalbags.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. "Caution - Wet Floor" signsc. Floor stripping machined. Stripping Pads (least abrasive pad possible)e. Buckets with water for rinsingf. Mops (for stripping, rinsing and polishing)g. Chemical stripper - recommended amount for area to be strippedh. Floor wax or finishi. Walk-off mats

3. Place tools, equipment and materials needed in work area. Place walk-off matswhere required to prevent tracking of stripping solution to other areas. Position"Caution - Wet Floor" signs.

4. After proper mixing of stripping chemical, adequately wet floor by mop applyingliberal amounts of the solution. Allow chemical to soak for amount of timerecommended by manufacturer. If areas become dry, reapply solution to keep flooradequately wet.



5. After wax or finish has softened, strip flooring using least abrasive pad and low speedsetting (300 RPM maximum). Keep floor adequately wet during machine operation. Do not overstrip. Stop stripping when the old wax or finish is removed. Work smallareas at a time.

6. Remove dirty stripping solution with wet vacuum or "strip" mop.

7. With "rinse" mop, apply liberal amount of clean water to area stripped and removewater with wet vacuum or mop. Repeat rinse procedures.

8. If some spots of wax or finish remain, restrip those areas.

9. If new flooring will be installed over the stripped floor, do not apply wax or finish. When applying new wax or finish, do so according to manufacturer'srecommendations.



R6 . SummaryDry or spray buffing resilient asbestosflooring

SummaryThis work practice covers the proceduresfor spray buffing the polish to restoregloss on resilient asbestos flooring. Donot buff damaged flooring. Any loose ordamaged flooring should be repaired orreplaced before buffing is started. Thispractice assumes that the floor hasadequate coats of polish, and that the

flooring itself will not be damaged orcontacted by the buffing equipment. Ifany flooring damage occurs duringbuffing, stop work and make repairs usingapplicable work practice(s). If polish is inpoor condition, use work practice R6 orR8.

ExampleLevel A: A. Dry or spray buff the polish on resilient asbestos flooring to remove minor surface

imperfections and restore gloss.

Related Work PracticesR 5 Strip floor wax from resilient asbestos flooring.

R 7 Cleaning resilient asbestos flooring.


One worker trained in spray buffing procedures for asbestos flooring. A person with airmonitoring training might be required. This person can be the worker.


R6 . Level ADry or spray buffing resilient asbestosflooring


A. Dry or spray buff the polish on resilient asbestos flooring to remove minor surfaceimperfections and restore gloss.

NotesDo not buff damaged flooring. Any loose or damaged flooring should be repaired orreplaced before buffing is started. This practice assumes that the floor has adequate coatsof polish, and that the flooring itself will not be damaged or contacted by the buffingequipment. If any flooring damage occurs during buffing, stop work and make repairsusing applicable work practice(s). If polish is in poor condition, use work practice R5 orR7.

Dispose of pads, if contaminated, as ACM waste in labeled disposal bags.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. "Caution - Wet Floor" signsc. Floor buffing machined. Buffing Pads (least abrasive - tan, red, or equivalent)e. Buckets with mop wringerf. Mops (for damp or spot mopping)g. Chemical cleanerh. Hand-held scraperi. Spray buffing compound, appropriately diluted, compatible polish and restorer

chemical

3. Place tools, equipment and materials needed in work area. Position "Caution-WetFloor" signs.

4. Pick up any large loose debris and place into disposal bags. Using scraper and water,remove all foreign matter from the finished surface (gum, tar, stickers, etc.).

5. Spot or damp mop to remove stains and spills. Mix chemical cleaner or restorer withwater and apply according to manufacturers recommendations. Spot or damp mop toremove stains and spills. If dry buffing will be performed, apply restorer chemical asrequired.



6. Allow floor to dry thoroughly.

7. Spray or dry buff as appropriate:

a. To spray-buff, spray small area with spray-buff solution and buff usingmanufacturer's recommended pad or brush at recommended RPM. Repeatprocedure until entire area is spray-buffed.

b. To dry buff, buff or dry burnish with manufacturer's recommended pad or brushat recommended RPM.



R7 . SummaryCleaning resilient asbestos flooring

SummaryThis work practice covers the procedures for cleaning (or scrubbing) the polish onresilient asbestos flooring prior to buffing or application of additional polish. Do notpolish loose or damaged resilient flooring. Any damage should be repaired beforecleaning begins using the applicable work practice(s). Stop work if any damage occursduring cleaning and make repairs needed.

ExampleLevel A: A. Clean or scrub resilient asbestos flooring with adequate coats of floor polish on

flooring before buffing or application of additional polish.

Related Work PracticesR 5 Wet strip floor wax from resilient asbestos flooring.

R 6 Dry or spray buffing resilient asbestos flooring.


One worker trained in cleaning procedures for asbestos flooring. A person with airmonitoring training might be required. This person can be the worker.


R7 . Level ACleaning resilient asbestos flooring


A. Clean or scrub resilient asbestos flooring with adequate coats of floor polish onflooring before buffing or application of additional polish

NotesDo not polish loose or damaged resilient flooring. Any damage should be repaired beforecleaning begins using the applicable work practice(s). Stop work if any damage occursduring cleaning and make repairs needed.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. "Caution - Wet Floor" signsc. Floor scrubbing machined. Pads (least abrasive)e. Buckets with mop wringerf. Scraper 2-3" (50-75 mm) wide stiff bladeg. Mops (for scrubbing, rinsing)h. Measuring device for mixing chemical cleaneri. Walk-off matsj. Chemical cleaner

3. Place tools, equipment and materials needed in work area. Place walk-off mats toprevent tracking of scrubbing solution to other areas. Position "Caution - Wet Floor"signs.

4. Install polyethylene sheet on adjoining floors for protection from any spilled cleaningsolution.

5. Mix scrubbing chemical with water as recommended by manufacturer and applyliberal amount (do not flood) using mop. Allow to soak for amount of timerecommended by manufacturer. Keep floor adequately wet by reapplying cleaningsolution if drying occurs. Work small areas at a time.

6. Using floor scrubbing machine, manufacturer's recommended pads and operatingspeed, clean floor to remove embedded dirt and surface marks.

7. Remove spent scrubbing solution with wet vacuum or mop.



8. Rinse area using clean mop and clean rinse water. Remove water with wet vacuumor mop. Damp mop area to clean up any remaining water or streaks.



R8 . SummaryRemove carpet over resilient asbestosflooring

SummaryThis work practice describes theprocedures to be used for removing asmall area of carpet installed over resilientasbestos flooring for O&M work. Theseprocedures assume that the carpetadhesive or mastic does not containasbestos, and that contamination is not

present on the top side of the carpet. If alarge area is involved, the work mightrequire that abatement procedures be used. If carpet mastic contains asbestos, seeWork Practice R1. Removal of well-adhered carpet can pull up resilientasbestos flooring beneath the carpet.

ExamplesLevel A: A. Remove carpet that is non-adhered or weakly adhered to resilient asbestos flooring.

Level B+: A. Remove carpet adhered to good condition resilient asbestos flooring where masticand/or a small number of tiles may be pulled up, or flooring may be pulled upwithout separation of backing and wear layer. Resilient flooring mastic may or maynot contain asbestos.

Related Work PracticesR1 Replacement of resilient asbestos floor tiles.

R2 Replacement of vinyl sheet flooring with ACM backing.

R3 Installation of new resilient flooring or carpet over resilient asbestos


One worker for Level A work. One or two workers for Level B depending upon safetyand efficiency considerations.


R8 . Level ARemove carpet over resilient asbestosflooring


A. Remove carpet that is non-adhered or weakly adhered to resilient asbestos flooring.

NotesThese procedures assume that the carpet adhesive or mastic does not contain asbestos,and that contamination is not present on the top side of the carpet. If a large area isinvolved, the work might require that abatement procedures be used. If carpet masticcontains asbestos, see Work Practice R1.

Review manufacturer's recommendation concerning installation of new carpet over oldflooring and/or adhesive before proceeding with this work. If asbestos-containingadhesive must be removed, refer to wet-scraping procedures in Work Practice R1.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Metal straightedge for use when cutting carpetc. Scraper 2-3" (50-75 mm) wide stiff blade


4. Find a seam or corner where carpet removal can begin. If no seams or corners exist,make a cut around the piece to be removed. Cut carpet using utility knife with a newblade.

5. Pry up corner or seam of carpet using scraper. Pull back a section large enough(approximately one square foot [0.1 m2]) to hang onto while removing carpet. HEPAvacuum exposed flooring and back of carpet.

6. Pull carpeting back slowly and HEPA vacuum exposed flooring & back of carpet. Remove carpet in pieces no larger than 200 square feet (18.6 m2).

7. If carpet and adhesive are non-ACM, roll up carpet and dispose of as non-ACMwaste. If portions of asbestos-containing flooring remain attached to carpet backing,dispose of carpet as ACM or in accordance with applicable regulations.

8. HEPA vacuum surface of flooring after carpet is removed. If residual asbestos-containing adhesive or residual felt backing needs to be removed, follow wet-scraping procedures in work practice R1 or R2, respectively. Allow substrate to drybefore installing new flooring.



9. Use Work Practice M22 if HEPA vacuum needs maintenance, or if bag or filter needsto be replaced.



R8 . Level B+Remove carpet over resilient asbestosflooring

ExampleThe following is an example of work that can be performed using the procedures of thisLevel B+ work practice. If job conditions vary from the examples stop work and notifyyour supervisor.

A. Remove carpet adhered to good condition resilient asbestos flooring where masticand/or a small number full tiles may be pulled up, or flooring might be pulled upwithout separation of backing and wear layer. Resilient flooring mastic may or maynot contain asbestos.

NotesThese procedures assume that the carpet adhesive or mastic does not contain asbestos,and that contamination is not present on the top side of the carpet. If a large area isinvolved, the work might require that abatement procedures be used. If carpet masticcontains asbestos, see Work Practice R1.

Review manufacturer's recommendation concerning installation of new carpet over oldflooring and/or adhesive before proceeding with this work. If asbestos-containingadhesive must be removed, refer to wet-scraping procedures in Work Practice R1. Avoidfoot traffic on any exposed mastic.


2. Tools, equipment and materials: a. Tools as needed from the lists in General Procedure W1 b. Scraper 2-3" (50-75 mm) wide stiff bladec. Metal straightedge for use when cutting carpet



5. Find a seam or corner wherever carpet removal can begin. If no seams or cornersexist, a cut will need to be made around the piece to be removed. Wet the areas thatneed to be cut using amended water. Cut carpet using utility knife with a new blade.

6. Pry up corner or seam of carpet using scraper. Pull back a section large enough(approximately one square foot [0.1 m2]) to hang onto while removing carpet. Adequately wet flooring and adhesive exposed.

7. Pull carpeting back slowly and spray amended water on flooring and adhesive as theyare exposed. Remove carpet in pieces no larger than approximately 200 square feet(18.6 m2).

8. If carpet and adhesive are non-ACM, roll up carpet and dispose of as non-ACMwaste. If portions of asbestos-containing flooring remain attached to carpet backing,



dispose of carpet as ACM. Loose vinyl asbestos flooring shall be disposed of indisposal bags or containers.

9. HEPA vacuum surface of flooring after carpet is removed. If residual asbestos-containing adhesive or residual felt backing needs to be removed, follow wet-scraping procedures in work practice R1 or R2, respectively. Allow substrate to drybefore installing new flooring.


APPENDICES

A2 # Appendices # Table of Contents # © NIBS 1996 # Page 398

Appendices

Appendix A - Job Request Form for Maintenance Work . . . . . . . . . . . . . . . . 399Appendix B - Maintenance Work Authorization Form . . . . . . . . . . . . . . . . . 401Appendix C - Evaluation of Work Affecting

Asbestos-Containing Materials . . . . . . . . . . . . . . . . . . . . . . . . 403Appendix D - Waste Tracking Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 405Appendix E - Resilient Floor Covering Form . . . . . . . . . . . . . . . . . . . . . . . . 407Appendix F - Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 411Appendix G - References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 417Appendix H - General Safety Considerations . . . . . . . . . . . . . . . . . . . . . . . . . 420Appendix I - Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 425Appendix J - NIBS Feedback Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 463

A3 # Appendix A # Job Request Form # © NIBS 1996 # Page 399

Appendix AJob Request Form for Maintenance Work(from EPA Green Book)

A4 # Appendix A # Job Request Form # © NIBS 1996 # Page 400

Job Request Form for Maintenance Work

Name: Date:

Telephone No. Job Request No.

Requested starting date: Anticipated finish date:

Address, building, and room number(s) (or description of area) where work is to be performed:

Description of work:

Description of any asbestos-containing material (ACM) that might be affected. if known (include location and type):

Name and telephone number of requestor:

Name and telephone number of supervisor:

Submit this application to:

(The Asbestos Program Manager)

NOTE: An application must be submitted for all maintenance work whether or not ACM might be affected. An authorization mustthen be received before any work can proceed.

______ Granted (Job Request No. __________________)______ With conditions*______ Denied

*Conditions:

A5 # Appendix B # Maintenance Work Authorization Form # © NIBS 1996 # Page 401

Appendix BMaintenance Work Authorization Form(from EPA Green Book)

A6 # Appendix B # Maintenance Work Authorization Form # © NIBS 1996 # Page 402

Maintenance Work Authorization Form No. ________________

AUTHORIZATION

Authorization is given to proceed with the following maintenance work:

PRESENCE OF Asbestos-containing material (ACM)

______ ACM is not present in the vicinity of the maintenance work.

______ ACM is present. but its disturbance is not anticipated: however, if conditions change, the Asbestos Program Manager will re-evaluate thework request prior to proceeding.

______ ACM is present. and may be disturbed.

Work Practice if Asbestos-Containing Materials Are Present

The following work practices shall be employed to avoid or minimize disturbing asbestos:

Personal Protection if Asbestos-Containing Materials Are Present

The following equipment/clothes shall be used/worn during the work to protect workers:

(manuals on personal protection can be referenced)

Special Practices and/or Equipment Required:

Signed:__________________________________________________________________________ Date:_________________________(Asbestos Program Manager)

A7 # Appendix C # Evaluation of Work Affecting ACM # © NIBS 1996 # Page 403

Appendix CEvaluation of Work Affecting Asbestos-Containing Materials(from EPA Green Book)

A8 # Appendix C # Evaluation of Work Affecting ACM # © NIBS 1996 # Page 404

Evaluation of Work Affecting Asbestos-Containing Materials

This evaluation covers the following maintenance work:

Location of work (address, building, room number(s), or general description):

Date(s) of work: _________________________________________________________________________________________________________

Description of work: ______________________________________________________________________________________________________

Work approval form number: ______________________________________________________________________________________________

Evaluation of work practices employed to minimize disturbance of asbestos:

Evaluation of work practices employed to contain released fibers and to clean up the work area:

Evaluation of equipment and procedures used to protect workers:

Personal air monitoring results: (in-house worker or contract?)

Worker name ____________________________________________ Results: ______________________________________________

Worker name ____________________________________________ Results: ______________________________________________

Handling or storage of ACM waste: _________________________________________________________________________________________

Signed: ________________________________________________________________ Date:_____________________________________________(Asbestos Program Manager)

A10 # Appendix D # Waste Tracking Form # © NIBS 1996 # Page 406

Waste Tracking Form

PART 1 - TO BE COMPLETED BY WORKERS:

Maintenance Work Authorization No.

Work Location: Building:

Room # or Area:

Type of ACM Removed:

Quantity of Waste generated: _____________________________________________________________ Bags

Other containers:

Waste transported to:

Transported by:

Tracking Form given to:

PART 2 - TO BE COMPLETED BY ASBESTOS PROGRAM MANAGER

Waste Properly Packaged & Labeled: Yes _____ No _____

EXCEPTIONS:

Waste Storage Location:

Waste Disposal Location:

Waste Shipment Records Received:

Date:

Signed: (Asbestos Program Manager)

Date:

A11 # Appendix E # Resilient Floor Covering Form # © NIBS 1996 # Page 407

Appendix EResilient Floor Covering Form(from Using Compliant Work Practices to Remove Resilient Floor Covering)

Section 11: Brief Checklist of Requirements (Prior to the start of job) to comply with the OSHAAsbestos Standard in Removing Asbestos-Containing Floor Covering using the RecommendedWork Practices Date:

(A) Competent Person Requirement has successfully completed the 12-hour competent person training courseInitial Employee Name in accordance with the provisions of the OSHA standard and is qualified to conduct the

negative exposure assessment (NEA) and supervise the removal activities on this job. Competent person will conduct “on-site" NEA inspection prior to start of job and will be available during the removal operations to inspect the job site at employee request or as necessary as a result of changed conditions that may prevent completion of the work using the RWP. (B.) Negative Exposure Assessment

Job site has been surveyed to confirm that the flooring material is intact, that the Recommended Work Initial Practices can effusively be used to remove flooring on this job, and that the flooring is likely to remain Intact

throughout the removal process. (Intact meaning that the flooring has not crumbled, been pulverized, ordeteriorated so that it is no longer likely to be bound within its matrix. Incidental breakage of floor tiles duringremoval operations using the recommended work practices does not mean that the material is not removed inan Intact condition.

Conditions of removal work to be completed on this job closely resemble the processes, type of material,Initial control methods, work practices, and environmental conditions in the jobs outlined on page 5 of this brochure

and further described in the Environ Report dated May 1, 1992.

The TWA and excursion limits during proposed job are anticipated to resemble those in the Environ test Initial reports (See Pages 3 and 4).

This form and RWP booklet will be readily available at the job site for inspection by OSHA officials.Initial The work practices described in the Recommended Work Practices for the Removal of Resilient FloorInitial Covering will be followed.

If workplace conditions on the job change during the removal of resilient floor covering, and do not resembleInitial those removal jobs described in the Environ Report or the Recommended Work Practices are no longer used

on this job, I understand that the NEA is no longer valid and additional protective steps (regulated area) mustbe taken in accordance with the OSHA Asbestos Standard. (C) Worker Training Requirements

The following individuals who will be performing the resilient floor covering removal workhave successfullyInitial completed an approved 8-Hour training course covering asbestos subjects as well as

training in the use of the Recommended Work Practices in accordance with theprovisions of the OSHA standard. Employee Name Date Completed Training Course Employee Name Date Completed Training Course Employee Name Date Completed Training Course

I have reviewed the job records of the individuals listed above and confirm that those employees who haveInitial worked with ACM have done so at levels below the PEL and for less than 30 days this calendar year. If an

employee has worked with ACM 30 or more days or at or above the PELs, I understand that the employeemust have a medical examination before participating in this removal job and annually thereafter. (D.) Notification and Demarcation

Before the start of this removal job the following individuals must be notified of the presence and location of ACMInitial and of the planned removal activity: (1 ) employees performing the removal work, (2) employers of employees

working in adjacent areas (not separated from the work area by either a wall, closed door or window, or otherimpermeable barrier), and (3) the building owner.

Warning signs have been posted and area has been demarcatedInitial

Job Information

Job/Order Number:

Date of work operation:

Name of work site:

Address of work site:

Description of work operation:

(include type and size of resilient floor covering material removal methods used and time duration of removal activity).

Names of Employees Involved in Work Operation: Social Security Nos

This completed form should be maintained by the employer in the employee personnel file for 30 years. The employershould have a copy of the Environ Report dated May 1, 1992, in its possession.

Signature of Authorized Representative of Employer Who Has Assigned Competent Person to this Job

Signature of Competent Person

Name of Employer

Address

Date

(Local Reproduction Of This Form Authorized)

A15 # Appendix F # Glossary # © NIBS 1996 # Page 411

Appendix FGlossary

Acoustical Plaster Soundabsorbing finishing material mill-formulated for application in areaswhere a reduction in soundreverberation or noise intensity isdesired. These materials usually areapplied in a minimum thickness of ½"(13 mm). The finish material is appliedover gypsum plaster, plaster brown coator other base plaster. The surfacematerial is usually friable and has arough surface appearance.

Acoustic Tile Tile-shaped blocks ofsound absorbent material used forceilings or as wall facing. May be gluedto substrate or laid in a rigid grid work.

ACM (ACBM) Asbestos-ContainingMaterial (Asbestos-containing BuildingMaterial). Any material containingmore than one percent asbestos.

Adequately Wet Adequately Wetmeans sufficiently mix or penetrate withliquid to prevent the release ofparticulates. If visible emissions areobserved coming from asbestos-containing material, then that materialhas not been adequately wetted. However, the absence of visibleemissions is not sufficient evidence ofbeing adequately wet.

AHERA Asbestos Hazard EmergencyResponse Act

AIA American Institute of Architects

Air Monitoring The process ofmeasuring the fiber content of a specificvolume of air.

Amended Water Water to which asurfactant has been added for use inwetting ACM to control asbestos fibers.

APM Asbestos Program Manager

Asbestos Chrysotile, amosite,crocidolite, tremolite asbestos,anthophyllite asbestos, actinolite

asbestos and any of these minerals thathas been chemically treated and/oraltered.

Asbestos-Containing WasteMaterial Mill tailings or any wastethat contains commercial asbestos and isgenerated by a source regulated underNESHAP. This term includes filtersfrom control devices, friable asbestoswaste material, and bags or other similarpackaging contaminated withcommercial asbestos. As applied todemolition and renovation operations,this term also includes regulatedasbestos-containing waste and materialscontaminated with asbestos includingdisposable equipment and clothing.

Asbestos debris Pieces of ACBMthat can be identified by color, texture,or composition, or means dust, if thedust is determined by an accreditedinspector to be ACM.

Asbestos Hazard EmergencyResponse Act (AHERA) An EPAregulation published in the October 30,1987 Federal Register coveringasbestos-containing materials in schools. AHERA requires local educationagencies to identify ACM in their schoolbuildings, develop an asbestosmanagement plan and implement thisplan. An O&M program is onepermitted response action, whereappropriate.

Asbestos O&M Work Cleaning,maintenance, repair or renovation workinvolving asbestos containing materialswhere the intent of the activity is not toremove asbestos. NESHAP requiresthat the owner or operator of ademolition or renovation activityconduct a thorough inspection of theaffected facility or part of the facilitywhere demolition or renovation willoccur.


Asbestos Program Manager(APM) A building owner ordesignated representative whosupervises all aspects of the facilityasbestos management and controlprogram.

Breathing Zone A hemisphereforward of the shoulders with a radius ofapproximately 6" to 9" (150-250 mm).

Bridging encapsulant Anencapsulant that forms a discrete layeron the surface of an in situ asbestosmatrix.

CFR Code of Federal RegulationsClerk-of-the-works A representativeof the architect or owner who overseesconstruction, handles administrativematters, and ensures that theconstruction is in accordance with thecontract documents.

Competent Person means, inaddition to the defination in 29 CFR1926.32 (f), one who is capable ofidentifying existing asbestos hazardsin the workplace and selecting theappropriate control strategy forasbestos exposure, who has theauthority to take prompt correctivemeasures to eliminate them, asspecified in 29 CFR 1926.32(f): inaddition, for Class I and Class IIwork one who is specially trained ina training course which meets thecriteria of EPA’s ModelAccreditation Plan (40 CFR part763) for supervisor, or its equivilentand, for Class III and Class IV work,who is trained in a manner consistentwith EPA requirements for trainingof local education agencymaintenance and custodial staff asset forth at 40 CFR 763.92 (a)(2).

Compliance Instruction(Compliance Directive)Instruction issued by OSHA to establishpolicies and provide clarification to

ensure uniform enforcement of OSHAstandards.

Concealed Suspension orConcealed Spline CeilingSystem Presents a monolithic ceilingsurface, unobstructed by the cross-hatching of exposed grid members. Tiles are typically 12" x 12" (300 x 300mm) or 12" x 24" (300 x 600 mm) withslots or kerfs cut into the edges of tilesfor the purposes of accepting flat or "T"splines to support the tiles.

Confined Space A space that haslimited openings for entry and exit,unfavorable natural ventilation and/or aspace not designed for continuousworker occupancy. Examples includeboilers, furnaces, pits, septic tanks,manholes, silos and utility vaults.

Critical Barrier One or more layersof polyethylene taped in place overopenings into a work area. Openings tobe covered include doors, windows,diffusers, and any other opening thatcould allow outside air into a work area.

CSRF Construction Sciences ResearchFoundation

Decorative Acoustic Finish:Finishing material mill-formulated andspray applied up to about 3/8" (10 mm) thick over gypsum wallboard. Materialhas a rough surface and is similar inappearance to acoustic plaster but is notdesigned for sound absorption.

Delamination Separation of onelayer from another.

Disposal Bag Properly labeled 6mil (0.15 mm) thick (or thicker)leak-tight plastic bags used fortransporting asbestos waste from workand to disposal site.

Drop Cloth A layer of polyethyleneon the floor of a work area to protect thefloor below from contamination and tofacilitate the clean-up of dust or debrisgenerated during the work.

EJCDC Engineers Joint ContractDocuments Committee

EL See Excursion Limit


Encapsulant A material thatsurrounds or embeds asbestos fibers inan adhesive matrix, to prevent release offibers.

Enclosure The construction of anair-tight, impermeable, permanentbarrier around asbestos-containingmaterial to control the release ofasbestos fibers into the air.

EPA U.S. Environmental ProtectionAgency

Excursion Limit (EL) The OSHAterm used to define a maximum airborneconcentration of asbestos in fibers percubic centimeter as averaged over asampling period of thirty minutes.

Fiber Release Any uncontrolled orunintentional disturbance of ACBMresulting in visible emission.

Fireproofing Material applied tostructural elements or systems whichprovides increased fire resistance,usually serving no structural function. This material is typically applied usingspray equipment.

Friable Asbestos (See "RegulatedACM").

Glovebag A polyethylene orpolyvinyl chloride bag-like enclosureaffixed around an asbestos-containingsource (most often, TSI) so that thematerial may be removed whileminimizing release of airborne fibers tothe surrounding atmosphere.

HEPA Filter High-EfficiencyParticulate Air Filter. Such filters arerated to trap at least 99.97% of allparticles 0.3 microns (0.3 :m) indiameter or larger.

HMR Hazardous Material Rules underDept of Transportation regulations.

MAP EPA Interim Final ModelAccreditation Plan (MAP) for asbestosabatement worker training (40 CFR Part763, Subpart E, Appendix C).

Medical Surveillance A periodiccomprehensive review of a worker'shealth status. The required elements ofan acceptable medical surveillance

program are listed in the OccupationalSafety and Health Administrationstandards for asbestos.

Mini-Enclosure An enclosureconstructed of polyethylene sheetingused for small scale, short durationasbestos maintenance or renovationwork. Mini-enclosures can be smallenough to restrict entry to the asbestoswork area to one worker. Appendix Gto OSHA regulation 29 CFR 1926.58discusses mini-enclosures andrecommends that a change room beconstructed contiguous to the mini-enclosure.

Miscellaneous ACM Interiorasbestos-containing building material onstructural components, structuralmembers or fixtures, such as floor andceiling tiles; does not include surfacingmaterial or thermal system insulation.

NEA Negative Exposure Assessment

Negative ExposureAssessment A demonstration by theemployeer which complies with criteriain paragraph (f)(2)(iii) of 29 CFR1926.1101, that employee exposureduring an operation is expected to beconsistently below the PELs.

Negative Pressure System A localexhaust system intended to prevent theescape of contaminated air to thesurrounding environment. It utilizesHEPA filtration capable of maintaininga pressure differential with a lowerpressure inside the Work Area than inany adjacent area. This systemrecirculates clean air and/or generates aconstant flow of air from adjacent areasinto the work area.

Negative Pressure Respirator A respirator in which the air pressureinside the respiratory-inlet covering ispositive during exhalation in relation tothe air pressure of the outsideatmosphere and negative duringinhalation in relation to the air pressureof the outside atmosphere.

NESHAP National Emission Standardfor Hazardous Air Pollutants - EPA


Rules under the Clean Air Act(40 CFR Part 61).

NIOSH The National Institute forOccupational Safety and Health, whichwas established by the OccupationalSafety and Health Act of 1970. Primaryfunctions of NIOSH are to conductresearch, issue technical information,and certify respirators.

O&M Operations & Maintenance

Operations & Maintenance (O&M)Program A program of work practicesto maintain ACM in good condition,ensure clean up of asbestos fiberspreviously released, and prevent furtherrelease by minimizing and controllingACM disturbance or damage.

Occupied Area An area wherepersonnel are present and areperforming their normal activitiesintended for the area (such as in atypical office area from 8:00 to 5:00p.m., Monday through Friday).

OSHA Occupational Health & SafetyAdministration.

PAPR Powered Air PurifyingRespirator.

Penetrating Encapsulant Anencapsulant that is absorbed by the insitu asbestos matrix without leaving adiscrete surface layer.

PELs Permissable Exposure Limits.

Personal Air Samples An airsample taken with a sampling pumpdirectly attached to the worker with thecollecting filter and cassette placed inthe worker's breathing zone. Thesesamples are required by the OSHAasbestos standards and the EPA WorkerProtection Rule.

PCM Phase Contrast Microscopy

Phase Contrast Microscopy (PCM) A method of analysis using a lightmicroscope, used to find the concentration of airborne fibers. Doesnot distinguish among asbestos andother fibers. Used by OSHA to findpersonal exposures, and by EPA to find

area levels for AHERA projectclearance.

Plenum Any space to convey air in abuilding or structure. The space above asuspended ceiling is often used as an airplenum. This term is also used in thework practices to refer to spaces above aceiling not used to convey air.

PLM Polarized Light Microscopy

Polarized Light Microscopy (PLM) A method of analysis using a lightmicroscope to find the chemical ormineral types of samples, including theconcentration of asbestos in bulkmaterials. Used by EPA for AHERAand NESHAP, and by OSHA to see ifasbestos is involved in a project.

Project Representative Architect’srepresentative at the project site whoassists in the administration of theconstruction contract.

Protection Factor The ratio of theambient concentration of an airbornesubstance to the concentration of thesubstance inside the respirator at thebreathing zone of the wearer. Theprotection factor is a measure of thedegree of protection provided by arespirator to the wearer.

RCRA Resource Conservation andRecovery Act.

RACM Regulated ACM

Regulated ACM (RACM) Asdefined by NESHAP in the November20, 1990 Federal Register, regulatedasbestos-containing material(RACM) means (a) Friable asbestosmaterial, (b) Category I nonfriable ACMthat has become friable, (c) Category Inonfriable ACM that will be or has beensubjected to sanding, grinding, cutting,or abrading, or (d) Category IInonfriable ACM that has a highprobability of becoming or has becomecrumbled, pulverized, or reduced topowder by the forces expected to act onthe material in the course of demolitionor renovation operations regulated bythis subpart.


(Note: Regulated ACM is an EPANESHAP concept. OSHA makes nodistinction between friable and non-friableasbestos).

"Cutting" means to penetrate with asharp-edged instrument and includessawing, but does not include shearing,slicing or punching.

"Grinding" means to reduce powder orsmall fragments and includesmechanical clipping or drilling.

Friable asbestos materialmeans any material containing morethan 1 percent asbestos asdetermined using the methodspecified under AHERA (40 CFRPart 763, Sub-part F, Appendix A ,section 1, Polarized LightMicroscopy) that, when dry, can becrumbled, pulverized, or reduced topowder by hand pressure. If theasbestos content is less than 10percent as determined by a methodother than point counting bypolarized light microscopy (PLM),verify the as-bestos content by pointcounting using PLM.

Category I nonfriableasbestos-containing material(ACM) means asbestos-containingpackings, gaskets, resilient floorcovering and asphalt roofingproducts containing more than 1percent asbestos as determinedusing the method specified underAHERA.

Category II nonfriable ACMmeans any material, excludingCategory I nonfriable ACM.containing more than 1 percentasbestos as determined using themethods specified under AHERA,when dry, cannot be crumbled,pulverized, or reduced to powder byhand pressure.

Remove For Operations andMaintenance work on ACM, "remove"refers to the removal of ACM as neededto perform a maintenance or repair O &M activity.

Removal Encapsulant Apenetrating encapsulant specificallydesigned to minimize fiber releaseduring removal of asbestos-containingmaterials rather than for in situencapsulation.

Repair Returning damaged ACBM toan undamaged condition or to an intactstate so as to prevent fiber release.

Respirator A device designed toprotect the wearer from the inhalation ofharmful particulates.

Small-scale, Short-durationTerm formerly used by OSHA todescribe O&M work activities (in theprevious OSHA construction standard). This term has been superceded by thework class definitions in the currentOSHA standard.

Surfacing ACM Asbestos-containingmaterial that is sprayed-on, troweled-onor otherwise applied to surfaces, such asacoustical plaster on ceilings andfireproofing materials on structuralmember, or other materials on surfacesfor acoustical, fireproofing, or otherpurposes.

Survey An asbestos survey is whatEPA calls an inspection in the AHERAregulation. It consists of a visual andtactile inspection of a building toidentify, quantify and assess theaccessibility and condition of the ACMand suspected ACM present.

Suspended "T" Bar CeilingSystem A false or dropped ceilingcomposed of acoustic tiles laid into aninverted metal "T" bar grid framesuspended by wires from buildingframing members.

Surfactant A chemical wetting agentadded to water to improve penetration,thus reducing the quantity of waterrequired for a given operation or area.

TEM Transmission ElectronMicroscopy

Temporary Barriers One or morelayers of 6 mil polyethylene installed to


isolate a work area from other portionsof a facility.

Thermal System Insulation(TSI) Thermal system insulation -asbestos-containing material applied topipes, fittings, boilers, breeching, tanks,ducts or other interior structuralcomponents to prevent heat loss or gainor water condensation.

Time Weighted Average (TWA) In air sampling, this refers to theaverage air concentration ofcontaminants during a particular timeperiod.

TSI Thermal System Insulation

Transmission ElectronMicroscopy (TEM) A method ofanalysis using an electron microscope,used to find and analyze theconcentration of airborne or bulkasbestos fibers and structures. Distinguishes among asbestos and othermaterials; can detect smaller asbestosfibers than does PCM. Used by EPA tofind area concentrations for largeAHERA project clearance.

TSCA Toxic Substances Control Act

TWA Time Weighted Average.

Work Area The area where asbestos-related work or removal operations areperformed which is defined and/orisolated to prevent the spread ofasbestos dust, fibers or debris, and entryby unauthorized personnel.

Work Practices Proceduresdesigned to be followed to avoid orminimize fiber release during activitiesaffecting ACM.

A21 # Appendix G # References # © NIBS 1996 # Page 417

Appendix GReferences

EPARegulations

United States Environmental Protection Agency, Asbestos Abatement Projects;Worker Protection; Final Rule ("Worker Protection Rule") 40 CFR 763.120-126 ,Washington D.C., 1987.

United States Environmental Protection Agency, National Emission Standards forHazardous Air Pollutants (NESHAP) 40 CFR 61.140-157, Washington D.C., 1984,revised 1990.

United States Environmental Protection Agency, Asbestos-Containing Materials inSchools; Final Rule and Notice (Asbestos Hazard Emergency Response Act -AHERA) 40 CFR 763.80-99, Washington D.C., 1987.

United States Environmental Protection Agency, Interim Final Model AccreditationPlan (MAP) for asbestos abatement worker training (40 CFR Part 763, Subpart E,Appendix C).

EPA GuidanceDocuments

(Order by Calling TSCA Assistance Hotline in Washington, DC

at: (202) 554-1404).

United States Environmental Protection Agency, Managing Asbestos in Place("Green Book") EPA Publication #20T-2003, Washington D.C., 1990.

United States Environmental Protection Agency, Guidance for Controlling Asbestos-Containing Materials in Buildings ("Purple Book") EPA publication #560/5-85-024,Washington D.C., 1985.

United States Environmental Protection Agency, A Guide to Respiratory Protectionfor the Asbestos Abatement Industry ("White Book) EPA publication #560-OPTS-86-001, Washington D.C., 1986.

United States Environmental Protection Agency, Simplified Sampling scheme forSurfacing Materials (Pink Book") EPA publication #560/5-85-030a, WashingtonD.C., 1985.

United States Environmental Protection Agency, EPA Guidance for Service andMaintenance Personnel, EPA publication #560/5-85-018, Washington D.C., 1985.

United States Environmental Protection Agency, Model training course materials foraccrediting Asbestos Building Inspectors and Management Planners in accordancewith AHERA, Washington D.C., 1987.

United States Environmental Protection Agency, Abatement of Asbestos-ContainingPipe Insulation, Asbestos-in-Buildings Technical Bulletin 1986-2, Washington D.C.,1986.


OSHARegulations

Occupational Safety and Health Administration, Asbestos Regulations for theConstruction Industry 29 CFR 1926.58, Washington D.C., 1986.

Occupational Safety and Health Administration, Respiratory Protection for theConstruction Industry 29 CFR 1926.103, Washington, D.C., 1970.

Occupational Safety and Health Administration, Respiratory Protection for GeneralIndustry 29 CFR 1910.134, Washington, D.C., 1978.

Occupational Safety and Health Administration, Hazard Communication Standardfor the Construction Industry 29 CFR 1926.59, Washington D.C., 1987.

U.S. GeneralServicesAdministration(PMSE)

Documentation Package for Asbestos Operations & Maintenance Programs,Washington D.C., 1990.

AsbestosInformationCenter

(Air monitoring guidance, etc.)

MiscellaneousReferences

Institute for Environmental Assessment, 433 Jackson Street, Anoka, MN 55303:

1. Suggested Operations and Maintenance Procedures2. Guide to Asbestos Personal Monitoring3. Recognition of Damage, Deterioration and Delamination4. Aerodynamic Characteristics of Asbestos

Keyes, Dale L. and Chesson, Jean. Guide to Monitoring Airborne Asbestos inBuildings, Tuscon, AZ, 1989.

Health Effects Institute - Asbestos Research, Asbestos in Public andCommercial Buildings A Literature Review and Synthesis of Current Knowledge,Cambridge, MA, 1991.


O&M Program Element ReferencesElement Regulations & Guidance

DocumentsGreen Book Guidance

APM Appointment &Training

Purple Book, AHERA, White Book Pgs. 7 & 23 - 25

Worker Training Purple Book, AHERA, White Book,OSHA 29 CFR 1926.1101, OSHA InstructionCPL 2-2.63 dtd Nov 3, 1995

Pgs. 23 - 25

Work Practices AHERA, OSHA 29 CFR 1910.1001, 1926.1101,OSHA Instruction CPL 2-2.63 dtd Nov 3, 1995

Pgs 16 - 21

Building Inspection &Assessment

Purple Book, AHERA, Pink Book,OSHA 29 CFR 1910.1001, 1926.1101, OSHAInstruction CPL 2-2.63 dtd Nov 3, 1995

Pg. 7

OccupantNotification &Communication

AHERA, OSHA 29 CFR 1910.1001, 1926.1101,OSHA Instruction CPL 2-2.63 dtd Nov 3, 1995

Pgs. 12 - 13, 28 - 29

HazardCommunicationProgram

OSHA 29 CFR 1910.1200, 1926.59, OSHAInstruction CPL 2-2.63 dtd Nov 3, 1995

Pg. 22

Worker ExposureMonitoring

OSHA 29 CFR 1910.1001, 1926.1101, OSHAInstruction CPL 2-2.63 dtd Nov 3, 1995

Pgs. 17 - 18, 38

RespiratoryProtection Program

White Book, OSHA 29 CFR 1910.1001,1910.134, 1926.1101, OSHA Instruction CPL 2-2.63 dtd Nov 3, 1995

Pgs. 17 - 18

Medical Surveillance OSHA 29 CFR 1910.1001, 1926.1101, OSHAInstruction CPL 2-2.63 dtd Nov 3, 1995

Pg. 27

Work Permit System ------------------------ Pg. 15

Waste Disposal EPA NESHAP 40 CFR 61.145,150 OSHA 29 CFR 1910.1200, DOT 49 CFR Parts 171 & 180.

Pg. 28

Recordkeeping AHERA, OSHA 29 CFR 1910.1001, 1926.1101,OSHA Instruction CPL 2-2.63 dtd Nov 3, 1995

Pg. 22

Fiber Releases Purple Book, AHERA Pgs. 20 - 21

Periodic Surveillance& Reinspections

Purple Book, AHERA Pg. 14

Air Monitoring Purple Book, AHERAOSHA 29 CFR 1910.1001, 1926.1101, OSHAInstruction CPL 2-2.63 dtd Nov 3, 1995

Pgs. 10, 14 - 15

Confined Spaces OSHA 29 CFR 1910.1001, 1915.1001,1926.1101

------------------

General Safety Hazards

White Book Appendix D OSHA 29 CFR Part1926

------------------

A24 # Appendix H - General Safety Considerations # © NIBS 1996 # Page - 420

Appendix HGeneral Safety Considerations(This section is reprinted from Appendix D of the EPA's White Book for use bypersonnel performing O & M activities.)

Ronald L. StanevichNIOSH Division of Safety Research

This guide was primarily developed to provide recommendations concerning workerrespiratory protection within the asbestos abatement industry. However, employers mustnot lose sight of the safety hazards their employees are exposed to in performance of theirwork. Asbestos abatement operations can take place in a variety of industrial, commercialand public settings. Each has unique potential safety hazards that the employer mustcontrol. However, nearly all abatement operations have some common safety hazards. With proper job planning and supervision. the employer can control both the health hazardsand the safety hazards faced by their workers. The more common safety hazards associatedwith abatement operations and general recommendations to control them are discussedbelow. Sources for more specific safety information are listed to supplement and supportthe applicable OSHA regulatory standards.

I. Elevated Work SurfacesThe nature of asbestos abatement tasks usually requires workers to work from ladders.scaffolds, manlifts, or other elevated surfaces, which creates the potential for fall injuries.Slips and falls from ladders, scaffolds, and other elevated surfaces result in a major portionof the construction industry injuries. Many of these can be prevented by implementing afew control measures:A. General

(1) Avoid use of makeshift work platforms by providing portable ladders andscaffolds.

(2) Ensure that job-built elevated work surfaces are inspected by a competent personother than the individual who erects it.

(3) Avoid working from elevated surfaces where possible. Consider use of wands forspraying amended water or scrapers with extended handles.

B. LaddersEighty percent of ladder-related accidents result from improper use or application.

(1) Workers should face the ladder when climbing up, down, or working from it.(2) Workers should not carry objects in their hands while ascending or descending

ladders. While working from a ladder they should hold on with at least one hand.(3) Ladders should not be used as a substitute for planks, runways, or walkboards.(4) Ladders should be maintained in good condition. Defective ladders should be

destroyed so that no one uses them by mistake.(5) Ladders should have safety feet in good condition to keep the ladder from

slipping and cutting through polyethylene floor covers.


(6) Ladder rungs/steps should be kept free of contaminates such as amended waterand buildup of asbestos waste.

(7) Employees should work no higher than the fourth step/rung from the top of theladder.

(8) Employees should not attempt to "reach" distant objects from a ladder; otherplatforms should be used.

(9) Wood or fiberglass ladders should be provlded to help control exposure toelectrical hazards.

(10) Employees Should not straddle the space between a ladder and another object. (11) Employees should make a visual inspection of ladders before each shift.

Additional information sources:Ladders -- publication no. ISBN 0-919465-05-6Construction Safety Association of Ontario74 Victoria StreetToronto. Ontario Canada M5C 2A5

Safety Requirements for Portable Wood Ladders" -- ANSI A14.1 - 1982Safety Requirements for Job-Made Ladders -- ANSI A14.4 - 1979Safety Requirements for Portable Reinforced Plastic Ladders -- ANSI

A14.5 - 1982American National Standards Institute, Inc.

1430 BroadwayNew York, NY 10018

Portable Ladders -- Industrial Safety Data Sheet #665National Safety Council

444 North Michigan AvenueChicago Illinois 60611

Environmental Health and Safety DivisionGeorgia Tech Research InstituteGeorgia Institute of TechnologyAtlanta, Georgia 30332

C. ScaffoldsFalls from scaffolds result in about 2,000 injuries per month in the United States. Thesecan be reduced by

(1) providing guardrails around the perimeter of the work surface regardless ofscaffold height

(2) securing scaffold decks against slippage(3) keeping scaffold uprights vertical and pinned together when stacked(4) ensuring vertical members are braced to keep the scaffold plumb and level(5) decking the entire top portion of the work surface in lieu of using minimum

planking dimensions(6) extending planks at least 6" (150 mm) over their support and cleating or

restraining them from movement(7) ensuring that manufacturer built-in ladders are in good condition(8) maintaining mobile scaffold casters in good condition with position locking

devices secured when employees are working from the scaffold


(9) keeping mobile scaffolding height less than four times the minimum basedimension and with adequate cross-bracing

(10) never interchanging scaffolding pans from different units (11) never using defective scaffolding (12) designating only "Competent" persons to perform scaffolding repairs.

Additional information sources:Manually Propelled Mobile Ladder Stands and Scaffolds"

ANSI A92.1 - 1977 Manually Propelled Elevating Work Platforms -- ANSI A92.3 - 1980 Self-Propelled Elevating Work Platforms -- ANSI A92.6American National Standards Institute, Inc.1430 BroadwayNew York, NY 10018

II. Electrical HazardsAsbestos abatement is often related to renovation or remodeling activities. Normally theequipment, machinery, overhead lighting fixtures. and auxiliary furnishings are removed tofacilitate the abatement work. However, it is becoming more common that industrial andcommercial buildings remain partially occupied while abatement operations are performed.In either situation. the abatement operator must take positive actions to protect employeesfrom accidently coming into contact with energized electrical circuits.A. General

(1) Perform a pre-work walk-through of the abatement area to look for pre-existingelectrical hazards involved with the work.

(2) De-energize as many circuits as possible.(3) Verify that the circuits have been de-energized with a "Field Current Sensing

Device" circuit tester. Either lock out/tag out all de-energized circuits to preventthem from accidentally being energized.

(4) Use non-conductive tools such as scrapers and vacuum attachments made ofwood, plastic, or rubber.

(5) Provide workers with non-conductive rubber boots and/or gloves when workmust be done around energized wiring or equipment.

(6) Prohibit accumulation of puddles of water on the floor. Workers should betrained in the intelligent use of amended water. No water should be used aroundenergized circuits.

B. Permanent Building Circuitry(1) Ensure that all permanent circuits are provided with a grounding system. This

can be determined with a portable ground tester.(2) Ensure that electrical outlets are tightly sealed and taped to avoid water spray.(3) Determine what equipment must remain energized during the abatement process.(4) Insulate or guard energized equipment and Wiring from employee contact and

other conductive objects.(5) Avoid damaging permanent building wiring during the work.(6) Consider dry removal methods in the vicinity of electrical equipment which must

remain energized.


C. Temporary Power(l) All temporary circuits provided by the abatement operator must be provided with

a grounding system and protected by ground fault circuit interrupters.(2) Avoid stringing temporary wiring across floors (3) Elevated wiring should not be fastened with staples. nails, or wire.(4) Use care not to damage the wiring insulation during Installation or abatement

work.

D. Electrical Cords and Tools(1) Provide extension cords which have a ground conductor.(2) Ensure that cords are not damaged, contain no splices. and that the grounding lug

on the male plug is intact.(3) Position extension cords to eliminate stumbling/tripping hazards and to protect

them from damage by moving scaffolds.(4) Provide electrical tools which are either grounded or of the double-insulated type(5) Use shatterproof, guarded bulbs and heavy duty wiring for temporary lighting.(6) Where plugs enter receptacles, ensure that the connection is protected by use of

duct tape or by other means.Additional information sources:

National Electrical Safety Code -- ANSI C2-1984 National Electrical Code -- ANSI/NFPA 70-1984American National Standards Institute, Inc.1430 BroadwayNew York, NY 10018

Temporary Electric Wiring for Construction Sites -- Industrial Safety Data Sheet #515

National Safety Council444 North Michigan AvenueChicago, Illinois 60611

III. HousekeepingAsbestos abatement operations present continuous housekeeping problems. Theaccumulation of asbestos and other debris on polyethylene-covered floors create employeeslipping and tripping hazards. It is essential that accumulation of such debris be bagged andremoved from the floor as soon as possible. Even though this activity may initially requiremore effort. it will make final cleanup easier and the work area safer.

Additional information source:Supervisors Safety ManualNational Safety Council

444 North Michigan AvenueChicago, Illinois 60611

IV. Emergency PlanningThe abatement operator should develop emergency procedures for fires or severely injuredemployees. Since abatement work areas must be sealed off. thereby blocking normal exits.the operator must familiarize the workers with procedures for safe exit in case of fire.Furthermore, the operator should develop plans for obtaining emergency aid in case ofsevere employee injury. The plans should be compatible with decontamination proceduresyet provide for quick medical aid.


Additional information source:Environmental Health and Safety DivisionGeorgia Tech Research InstituteGeorgia Institute of TechnologyAtlanta, Georgia 30332

A29 # Appendix I # Regulations # © NIBS 1996 # Page - 425

APPENDIX I:FEDERAL OCCUPATIONAL AND ENVIRONMENTALREGULATIONS, STANDARDS AND GUIDELINESThis Appendix describes the principal federal regulations, standards and guidelinesgoverning occupational and environmental exposures to asbestos, as of the date of thispublication. A number of other federal occupational and environmental standards alsoapply to operations within the scope of this Manual and the reader should be familiarwith those requirements as well. It is also important to note that state and localregulations may have requirements that differ from federal regulations and some may bemore stringent than the federal regulations described in this Appendix.

THE OCCUPATIONAL SAFETY AND HEALTH ACT:OSHA Asbestos in Construction Standard (29 CFR 1926.1101) . . . . . . . . . 427OSHA Asbestos in General Industry Standard (1910.1001) . . . . . . . . . . . . . 443OSHA Hazard Communication Standard (1926.59) . . . . . . . . . . . . . . . . . . . . 445Head Protection (1926.100) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 446Hearing Protection (1926.101) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 446Eye and Face Protection (1926.102) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 446Respiratory Protection (1926.103) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 446Safety Belts, Lifelines, and Lanyards (1926.104) . . . . . . . . . . . . . . . . . . . . . . 447OSHA Fire Protection and Prevention (1926.150) . . . . . . . . . . . . . . . . . . . . . 447OSHA Disposal of Waste Material (1926.252) . . . . . . . . . . . . . . . . . . . . . . . 448OSHA Lockout and Tagging of Circuits (1926.417) . . . . . . . . . . . . . . . . . . . 448OSHA Scaffolding (1926.451) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 449OSHA Grounding for Protection of Employees (1926.954) . . . . . . . . . . . . . . 450

ENVIRONMENTAL PROTECTION AGENCY:EPA Asbestos Hazard Emergency Response Act (AHERA) . . . . . . . . . . . . . 451EPA Asbestos School Hazard Abatement Reauthorization Act (ASHARA) 453EPA Asbestos NESHAP (40 CFR 61.140-157) . . . . . . . . . . . . . . . . . . . . . . . 453

DEPARTMENT OF TRANSPORTATION:DOT Hazardous Material Rules . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 459


THE OCCUPATIONAL SAFETY AND HEALTH ACT The federal Occupational Safety and Health Act (OSH Act) is the primary source ofregulation of an employer's obligation to provide a safe and healthful workplace. TheOSH Act (1) requires that each employer comply with the occupational safety and healthstandards issued by OSHA; and (2), even in the absence of any specific standard, the Actalso imposes a general duty on each employer to provide a workplace that is free fromrecognized hazards that are causing or are likely to cause death or serious physical harmto employees.

Public sector workers in states with their own OSHA programs can have standards equalto or more stringent than OSHA. The EPA “Asbestos Abatement Projects: WorkerProtection Rule,” (40 CFR 763, Sub-part G) extends similar protection to publiclyemployed workers involved in asbestos abatement work. For schools, the AHERAregulation (40 CFR 763, Sub-part E) sets forth training requirements for abatement,custodial and O&M workers and describes work practices for O&M work. The Asbestosin Schools Hazard Abatement Re-authorization Act (ASHARA) regulation extendedthese training requirements to all public and commercial buildings.

OSHA has developed three specific standards governing exposure to asbestos in theworkplace: the construction standard, the shipyard standard, and the general industrystandard. In addition to these, this Appendix also briefly describes other OSHAstandards of more general applicability, as well as EPA and DOT regulations that applyto asbestos.

Major revisions to asbestos-specific standards were published in the Federal Register onAugust 10, 1994, and additional changes were published on June 29, July 13, andSeptember 29, 1995. In addition, OSHA has issued a compliance directive regardingthese revisions, Instruction CPL 2-2.63 dated November 3, 1995. The discussionincludes all changes made as of the date of publication. The reader should verify whetheradditional changes have been made as of the time of use.


OSHA:ASBESTOS IN CONSTRUCTION STANDARD(29 CFR 1926.1101)

The new standard, 29 CFR 1926.1101, replaces the previous one, 29 CFR 1926.58.

Scope and applicationMost activities within the scope of thisManual are subject to the asbestos inconstruction standard, which covers allconstruction activities performed byemployees, regardless of the primaryactivity of the employer; see paragraph(a)(7) of the standard. For example,maintenance or removal of an asbestos-containing gasket, even if performed in anindustrial plant, by the employer's ownmaintenance staff, is covered under theconstruction standard. 1926.1101regulates asbestos exposure in all work asdefined in 29 CFR 1910.12(b), includingbut not limited to the following:

C Demolition or salvage of structureswhere asbestos is present;

C Removal or encapsulation of materialscontaining asbestos;

C Construction, alteration, repair,maintenance, or renovation ofstructures, substrates, or portions

thereof, that contain asbestos;

C Installation of products containingasbestos;

C Asbestos spill/emergency cleanup; and

C Transportation, disposal, storage,containment of and housekeepingactivities involving asbestos orproducts containing asbestos, on thesite or location at which constructionactivities are performed.

C Coverage under the OSHA standard isbased on the nature of the workoperation involving asbestos exposure.

Examples of work falling outside thescope of the construction standard are:general housekeeping in industrial andcommercial operations where asbestosmay be contacted but not disturbed , andbrake and clutch repair (general industrystandard); and asbestos-related activitiesin shipyards (shipyard standard) .

DefinitionsThe OSHA standard should be consultedfor a complete listing of definitions. Thefollowing are selected definitions usefulfor this summary, but no more inherentlyimportant for OSHA compliance thanothers.

Asbestos-containing material: TheOSHA standard defines both asbestos-containing materials (ACM) and presumedasbestos-containing material (PACM). Thermal system insulation and surfacingmaterial in buildings constructed no later

than 1980 are treated as ACM unless it isproven that they are not.

C Asbestos-containing material(ACM): means any materialcontaining more than one percentasbestos.

C Presumed Asbestos ContainingMaterial: means thermal systeminsulation (TSI) and surfacing materialfound in buildings constructed no laterthan 1980. The designation of a


material as "PACM" may be rebuttedpursuant to paragraph (k)(5) of thissection.

Asbestos work: The OSHAconstruction standard establishes fourcategories or classes of asbestos work.

C Class I asbestos work means activitiesinvolving the removal of thermalsystem insulation (TSI) and surfacingasbestos-containing material (ACM) orpresumed asbestos-containing material(PACM) and includes picking up andbagging asbestos debris/dust duringClass I work. (In general this involveswork on friable materials.)

C Class II asbestos work meansactivities involving the removal ofasbestos-containing material (ACM)that is not TSI or surfacing materialand includes picking up and baggingasbestos debris/dust during Class IIwork. This includes, but is not limitedto, the removal of asbestos-containingwallboard, floor tile and sheeting,roofing and siding shingles, andconstruction mastics. (In general, thisinvolves work on non-friable materialsif the material is removed in asubstantially intact state.)

C Class III asbestos work means repairand maintenance operations whereACM, including TSI and surfacingACM and PACM may be disturbed andincludes picking up and baggingasbestos debris/dust during Class IIIwork. (This is O&M work thatgenerates no more than a singledisposal bag of waste filled only 1/3 to½ full.)

C Class IV asbestos work meansmaintenance and custodial activitiesduring which employees contact, butdo not disturb, ACM or PACM. ClassIV activities also include clean-up

work that takes place in an area after aClass I, II, or III job (including allclean-up and bagging of asbestos-containing waste) has been completed. Class IV clean-up encompassesprecautionary measures to be taken toavoid exposures in the event there isresidual dust/debris present in the workarea. In the event that residual dust ordebris is found in the Class IV workarea, a competent person must assessthe area and decide whether the clean-up work should be performed as aClass I, II, or III operation. Class IVrequires only awareness training. However, the EPA ModelAccreditation Program requiresaccredited abatement workers for ClassI and II clean-up where the work hasmade the material friable. All workersin a Class I, II or III work area shouldhave the training required for that classof work. Workers should wearrespirators if cleaning up a regulatedarea where respirators are required.

Some asbestos related work does notfall within a class; examples includeencapsulation (a)(2) and installation ofACM (a)(4), but are covered by certainprovisions of the standards.

Disturbance: means activities thatdisrupt the matrix of ACM or PACM,crumble or pulverize ACM or PACM, orgenerate visible debris from ACM orPACM. Disturbance includes cutting awaysmall amounts of ACM and PACM, nogreater than the amount which can becontained in one standard sized glove bagor waste bag in order to access a buildingcomponent. In no event shall the amountof ACM or PACM so disturbed exceedthat which can be contained in one glovebag or waste bag which shall not exceed60 inches in length and width.


Multi-employer worksitesOn multi-employer worksites, theemployer (abatement contractor) involvedin Class I, II or III asbestos control work isrequired to

C notify other employers of the nature ofwork being performed andrequirements for regulated areas,

C abate any asbestos contaminationcaused by their work.

Other employers on the site (such as othercontractors including the GeneralContractor) are responsible for

C protecting their workers in accordance

with OSHA requirements, and

C ascertaining the integrity of theabatement contractor’s enclosure andeffectiveness of the control methodsbeing used.

A general contractor on a constructionproject which includes abatement work isconsidered to have general supervisoryauthority over the abatement work even ifnot qualified to serve as the asbestos"competent person," and must require theabatement contractor to come intocompliance with the OSHA standard whennecessary.

Regulated areasA regulated area is required for all Class I,II and III work, any area where waste anddebris for asbestos work is accumulated,and any adjoining area where the PELmay be exceeded. See the section in thisappendix on “Requirements for IndividualClasses of Work” for discussions onregulated areas for different classes ofwork.

C The regulated area must be demarcated,

C access to the area must be limited toauthorized persons,

C respirators must be used if required,

C certain activities are prohibited (eating,drinking, smoking, chewing tobacco orgum, and applying cosmeticsa), and

C a competent person must supervisework performed in the area.

a. In a January 13, 1995 memo from the Director ofDirectorate of Compliance Programs to RegionalAdministrators, OSHA has stated that it will not issuecitations for “eating, drinking, chewing tobacco orgum, and applying cosmetics in a regulated areaunless worker exposure exceeds the PEL.”

Permissible exposure limits (PELs)The OSHA regulation sets two permissibleexposure limits (PELs) expressed in fibersper cubic centimeter (f/cc).

The Permissible Exposure Limits (PELs)are

C 0.1 f/cc based upon the averageexposure for a complete 8 hour workshift, referred to as the 8 hour TimeWeighted Average (TWA).

C The Excursion Limit (EL) of 1.0 f/cc isfor a 30 minute TWA, to address peakexposures a worker may experience.

In addition to requirements which apply atany exposure level, a number ofrequirements are triggered if either thePEL or EL are exceeded including onesfor respiratory protection and protectiveclothing and a regulated area (Seediscussion above on regulated areas).


OSHA uses, “exceeding the PEL,” or,“exceeding the PELs,” to mean,“exceeding either the 8-hour permissibleexposure limit (PEL) or the excursionlimit (EL).”

OSHA requires controls based on the kindof operation regardless of the measuresexposure levels.

Requirements at any Exposure LevelThe following provisions apply to any activity covered under the standard, regardless ofmeasured exposure levels.

General! Exposure assessments and monitoring

(f):

C Initial exposure assessment by a"competent Person" (f)(2). (Seebelow for competent personrequirements and duties.)

-- Negative exposure assessments(NEA) can be obtained from theinitial assessment, objective data, orhistorical data taken by theemployer on previous jobs withinthe past twelve months, underconditions closely resembling thecurrent work, and which provide ahigh degree of certainty that neitherthe time weighted average (TWA)nor the excursion limit (EL) will beexceeded (f)(2)(iii). A special NEArule for removals of resilientflooring is explained in flooringsection under Class II activities. Relevant historic data factorsinclude: processes, type andcondition of material, workpractices used, and the level oftraining and experience of theworkers.

-- Additional monitoring needed whenwork changes or other reason newor additional exposures above a PELmay occur.

-- Employees and their representativescan observe monitoring (f)(6).

-- Employer must notify employee ofmonitoring results(f)(5).

! Multi-employer worksites (d):

-- Employers establishing regulatedareas must tell other employers onthe site of the nature of the asbestoswork, regulated area requirements,and control measures used (d)(1).

-- Breaches and hazards are theresponsibility of the employer whocreated or controls thecontamination (d)(2).

-- All employers must take applicableprotective measures, e.g., relocation,even if they did not cause theexposure (d)(3).

-- Employers with workers next to theregulated area of another employermust check controls' effectivenessdaily (d)(4).

-- General contractors must ensure thatall subcontractors comply with thestandard (d)(5).

Controls! Engineering controls and work

practices must include (g)(1):

-- HEPA vacuums(except for someroofing operations; see below underClass II).

-- Wet methods (except whereinfeasible or create a safety hazard;or for certain removal of roofing orresilient flooring [see Class IIdiscussions, below]).

-- Prompt clean-up and disposal.

! Prohibited work practices and


engineering controls (g)(3):

-- High-speed abrasive disc saws.

-- Compressed air to remove asbestos(unless in enclosed ventilationsystem).

-- Dry sweeping or shoveling.

-- Employee rotation to reduceexposure.

! When vacuuming is used forhousekeeping on construction projects,HEPA vacuums must be used; and usedand emptied so as to minimize asbestosdispersal (l)(1).

! Waste, debris and accompanying dustin an area with accessible TSI orsurfacing ACM/PACM or visiblydeteriorated ACM shall be promptlycleaned up using wet dusting orsweeping, or HEPA vacuuming, anddisposed of in leak tight containers(I)(4) (see Class II discussion ofroofing operations).

! Medical monitoring (m):

-- Medical surveillance is required forworkers engaged in Class I, II or IIIwork, or exposed at or above thePEL, for a combined total of 30 ormore days a year (any day in whicha worker engages in Class II or IIIoperations or a combination thereofon intact material for one hour orless, including removal and cleanup,and fully adheres to the workpractices in the standard, shall notbe counted). Medical examinations’frequency, content, and informationgiven to and by the physician shallfollow the standard. A medicalexamination is also required beforea worker may be assigned to any jobwhere a respirator is required(h)(3)(iv) and 29 CFR 1926.103. The General Industry standardrequires medical monitoring for anyemployee exposed at or above thePEL on any day.

-- Employers shall ensure thatemployees required to wear a

negative pressure respirator aredetermined, at no cost to them, andunder the supervision of aphysician, to be physically able toperform the work and use therespirator (h)(3)(iv) and(m)(1)(I)(B).

! Procedures are specified for: 1.resilient flooring maintenance inconnection with construction work(l)(3), and 2. dust and debris cleanup inareas containing accessible thermalsystem insulation or surfacingACM/PACM or visibly deterioratedACM (l)(4).

Identification of Materials! Building/facility owner (which

includes a lessee) must determine thepresence, location and quantity ofACM and/or presumed asbestos-containing materials (PACM) at thework site before beginning any worksubject to the standard (k)(2)(I).

! Presume or inspect surfacing, thermalsystem insulation (TSI), or resilientflooring material at work site (k)(1):

C TSI and sprayed-on or troweled-onsurfacing materials in buildings orsubstrates constructed before 1980are PACM; resilient flooringmaterial installed before 1980 isalso presumed to be ACM, althoughthe term "PACM" is not used for it(k). Can rebut presumptions:

-- For PACM, an AHERAinspection, or testing of thematerial being worked on by anAHERA-accredited inspector ora Certified Industrial Hygienist,is required; a nationallyrecognized testing program(National Voluntary LaboratoryAccreditation Program [NVLAP]or equivalent) must be used foranalysis (k)(5)(ii).

-- For resilient flooring material, anindustrial hygienist must userecognized analytical techniques


(k)(5)(iii).

Communication! The building/facility owner must

notify, in writing or personally, thepresence, location and quantity ofACM or PACM at the work sites to(k)(2)(ii):

-- Prospective employers whoseemployees will work in or next toareas with ACM or PACM.

-- Owner's employees who will workin or next to such areas.

-- All employers on multi-employerworksites whose employees willwork in or next to such areas.

-- Tenants who will occupy such areas.

! Before work begins, the employer mustinform the building/facility owner, itsown employees, and other employerswhose employees will work in or nextto the area, of the presence, locationand quantity of ACM and/or PACM,and precautions to be used (k)(3)(ii). For work within a regulated area, theemployer must also inform otheremployers of the nature of the workand regulated area requirements (d)(1).

! The employer shall, if asked, makeavailable for examination and copying:

-- All records required to bemaintained, to OSHA and NIOSH;

-- all required exposure records, toaffected current and formeremployees, their designatedrepresentatives, and OSHA; and

-- required employee medical records,to the employee, and person withthe employee’s written consent, andOSHA (n)(7).

! By 10 days after completion of work,the employer must inform thebuilding/facility owner, its employees,and other employers whose employeeswork or will work in the area, of the

current location and quantity of PACMand/or ACM remaining, and any finalmonitoring results (k)(3)(iii).

! Within 24 hours of discovery, theemployer must inform thebuilding/facility owner and otheremployers whose employees work inthe area, of the presence, location andquantity of newly discovered ACMand/or PACM (k)(4).

! The employer and building/facilityowner must identify PACM as ACM incommunications to employees, andtreat as ACM materials they know orshould have known through theexercise of due diligence to be ACM(k)(1).

Warning Signs and Labels! Signs at entrance to regulated areas

(k)(7).

! Signs at entrance to mechanicalrooms/areas with ACM or PACM(k)(6). Signs can be on outside ofentrance or inside room if visible topeople entering (Compliance Directive,p. C-36).

! Labels must be placed on productscontaining asbestos, including wastecontainers and, where feasible,installed products, unless asbestosfibers are bound so that no foreseeablework will release them above PEL orEL, or when less than 1% (k)(8).

! Employers/building owners must postor affix signs or labels with respect toall ACM or PACM (k)(8)(vii). Signsrequired by (k)(6) may be posted inlieu of labels so long as they containinformation required for labeling.

! Signs and labels must becomprehensible to non-Englishspeaking employees (k)(7).


Training! Employers must train employees in

recognizing and avoiding unsafeconditions, applicable regulations, thepotential hazards, safe handling and useof harmful or toxic substances, andpersonal hygiene and personalprotective measures required (29 CFR1926.21(b)).

! Employers must train all employeesdoing Class I-IV work, and asbestosproduct installers, before or at initialassignment and then at least annually(k)(9)(I)-(ii).

! Any training done must be in a manneremployee is able to understand (e.g.,language) and must take place with aknowledgeable instructor present (k)(9)(viii).

! Employer must make readily availableat no cost to employees, writtenmaterials on the employee trainingprogram, and inform them about, andprovide if asked, approved self-helpsmoking cessation program material;and give OSHA and NIOSH allemployee information and trainingprogram materials if asked (k)(10).

! Minimum training requirements foreach Class are outlined later in thisappendix.

Record Retention! Exposure monitoring records, including

those for a negative exposureassessment (NEA) based on current orhistorical data: 30 years (n)(2). Records based on objective data; whileemployer relies on data (n)(1). Exposure measurements may be keptby either the employer or competent

organizations, e.g., trade or employeegroups (n)(2).

! Medical surveillance records: Employment plus 30 years (n)(3).

! Training records: Employment plusone year (n)(4).

! Data to rebut PACM: While employerrelies on data (n)(5).

! Notifications received andcommunicated about ACM and PACM,and their content, must be maintainedby the building/facility owner andtransferred to its successive owners(n)(6).

! The employer must meet the recordtransfer rules of 29 CFR 1910.20(h); ifit stops doing business without asuccessor employer to keep the recordsas required, it must tell NIOSH at least90 days before disposal and send therecords to NIOSH if asked (n)(8).

Competent Person! The employer must have a "competent

person" able to identify asbestos andother hazards and unsanitary ordangerous conditions, and selectcontrol strategies, and with theauthority to take prompt correctivemeasures to eliminate hazards (o)(1). The competent person may be theemployer, an employee, or a contractorof the employer.

! The competent person must inspect thejob site, materials and equipmentfrequently and regularly (o)(2).

! The competent person must havetraining specific to the class of asbestosproject (o)(4).


Requirements When Asbestos Levels Exceed TWA(0.1 f/cc) or EL (1.0 f/cc)! All items required at any asbestos

level.

! Regulated area (e)(1).

-- Signs at regulated areas, even ifbelow PELs (k)(7).

! Periodic monitoring when expect toexceed a PEL, with exceptions foremployees in some supplied-air orpositive pressure respirators (f)(3)(ii).

! Additional engineering controls andwork practices to get to or below thePELs (g)(2):

-- Local exhaust ventilation withHEPA filters.

-- Enclosure or isolation.

-- Directed make-up air with HEPAfilter exhaust.

-- Other feasible engineering and workpractices controls.

! Respiratory protection (h), withminimum types used (h)(2) and Table1, and respiratory protection program(h)(3)-(4).

! Protective clothing provided when overa PEL or, when required, a negativeexposure assessment (NEA) notproduced (I)(1). Inspect for rips ortears (I)(4). Laundering allowed undercertain conditions (I)(2).

! Additional training for all employeeslikely to be exposed above a PEL,before or at initial assignment and thenat least annually using applicable ClassI-IV curriculum, or else (k)(9)(viii)curriculum(k)(9)(I), (ii), (vii).

Class I ActivitiesActivities involving removal of TSI or surfacing ACM or PACM. Large Class I jobs,those involving removal of over 25 linear or 10 square feet of TSI or surfacing material,have additional requirements.

General! All items required at any asbestos

level.

! Regulated area (e), with warning signs(k)(7).

! Presumption of exposure in excess of aPEL unless an NEA is produced(f)(2)(ii).

! Daily monitoring, unless an NEA isproduced, or employees use a controlmethod in (g)(4)(I)-(iii) with supplied-air respirators operated in pressuredemand mode or other positivepressure mode respirator (f)(3).

! All work supervised by competentperson (g)(4)(I).

! AHERA abatement worker training(four days) (k)(8)(iii).

! Medical surveillance; see descriptionabove (m).

! The competent person must:

-- Inspect the site at least once perwork shift and at any time atemployee request (o)(3).

-- Do or supervise specified controlduties (o)(3)(I).

-- Currently be accredited from anAHERA supervisor's course (fivedays), or an equivalent (o)(4)(I).


Controls! Additional controls and work practices

for large Class I jobs; for small Class Ijobs, where an NEA has not beenproduced; or for work adjacent to aregulated area (g)(4):

-- Critical barriers or other measures toisolate area (g)(4)(ii).

-- HVAC system isolation (g)(4)(iii).

-- Impermeable dropcloths (g)(4)(iv)-(v).

-- Directed make-up air if no NEA orover PEL (g)(4)(vi).

! At least one of these control methods,as applicable (g)(5):

-- Negative pressure enclosures(g)(5)(I).

— Glove bag. Do not move orreuse bag; use at least twopersons for Class I work(g)(5)(ii).

-- Glovebags used on elbows and otherconnections must be specificallydesigned for such use(g)(5)(ii)(A)(2).

-- Negative pressure glove bag system(g)(5)(iii).

-- Negative pressure glove box system(g)(5)(iv).

-- Water spray process system(g)(5)(v).

-- Mini-enclosure (g)(5)(vi).

! Supplied Air Respirators, unless 8-hr.TWA below 1 f/cc, then tight-fittingpowered air purifying respirators(PAPRs) (h)(1) and (h)(2)(v)

! Protective clothing for large jobs, or asotherwise required (I)(1).

! Hygiene facilities and practices (j).

-- Large jobs: Equipment room;shower area; clean change room;lunch areas; decontamination ofworkers, equipment and containers(j)(1).

-- Small jobs: Equipment room,decontamination of workers,equipment, and containers (j)(2).

! Alternative controls may be used(g)(6). To do so, a Certified IndustrialHygienist or licensed ProfessionalEngineer who is an AHERA projectdesigner must evaluate the plannedwork based on data for worst-caseconditions and equivalent employeetraining and experience, and certify theplanned controls as adequate (g)(6)(ii);a competent person may evaluate andcertify small jobs (g)(6)(ii)(A). OSHAmust be notified in advance for largejobs (g)(6)(iii).

Class II ActivitiesActivities involving removal of ACM which is not TSI or surfacing material. Thisincludes, but is not limited to, the removal of asbestos containing wallboard, floor tile andsheeting, roofing, and siding shingles and construction mastics.


level.

! Regulated area (e), with warning signs(k)(7).

! Daily monitoring, unless an NEA isproduced, or employees use supplied-

air respirators operated in pressuredemand mode or other positivepressure mode respirator (f)(3).

! All work supervised by competentperson (g)(7)(I).

! AHERA abatement worker training,unless working with only one genericcategory of building material, then job-


specific training (8 hours for roofing,flooring, siding, ceiling tile, or transitepanel work) based on (k)(9)(viii)curriculum and specific relevant workpractices and engineering controls (g),with hands -on training (k)(9)(iv). (Seebelow for training on roofing andresilient flooring removal.)



-- Inspect sufficiently to assesswhether conditions have changed,and at reasonable time uponemployee request (o)(3).

-- Do or supervise specified controlduties (g)(7)(I), (o)(3)(I).

-- Currently be accredited from anAHERA supervisor's course (fivedays), or an equivalent (o)(4)(I).

! Special rules for resilient flooringremovals and roofing work (seebelow).

Controls! Critical barriers, or other isolation

method required if: (1) no NEA; (2)TWA/EL exceeded; or (3) material isnot removed intact (g)(7)(ii).

! Impermeable drop cloths beneath allremoval activity, except removal offlooring or roofing material from asolid substrate underneath the material(g)(7)(iii).

! Equipment room or area covered byimpermeable drop cloth for entry anddecontamination when exceed a PEL orno NEA produced (j)(2).

! Work practices set forth in (g)(1).

! Respiratory protection where ACM notremoved in substantially intact state,wet methods not used (except for intactremoval of sloped roofing ACM withan NEA, or certain non-wet removal ofintact resilient flooring material usingheat, see below), no NEA produced, a

PEL exceeded, or in an emergency(h)(1). An employer must informemployees that a tight-fitting PAPRmust be provided in lieu of a negativepressure respirator, at the employee’srequest (h)(2)(iii)(B).

! Hygiene facilities and practices where aPEL is exceeded or no NEA produced:equipment room, decontamination ofworkers, equipment, and containers(j)(2).

! Additional controls and practices, asapplicable (g)(8):

-- Glove bag or glove box, only iffully enclose the material to beremoved (g)(8).

-- Vinyl and asphalt flooring material(g)(8)(I).

-- Roofing material (g)(8)(ii).

-- Cementitious siding or shingle, orTransite panel (g)(8)(iii).

-- Gasket (g)(8)(iv).

-- For other Class II materials: use wetmethods; remove intact if feasible;no cutting, abrading or breaking(unless nothing better);wrap or bagdebris (g)(8)(v).

! Alternative controls may be used(g)(8)(vi). To do so, a competentperson must evaluate the planned workunder all expected conditions, based ondata for closely similar conditions andequivalent employee training andexperience, and certify the plannedcontrol method as adequate(g)(8)(vi)(A), (B).

! Rules Unique to Intact Removal ofResilient Flooring

-- NEA may be based on data inOSHA rulemaking record when allthree criteria are met: (1) only thosework practices for flooring removalreferred to as “compliant workpractices” in OSHA ComplianceDirective C.P.L. 2-2.63, at D-34 toD-36 (Nov 3, 1995) (“OSHACompliance Directive”), as


implemented in WP R-1A and R-2A of this Manual, are used; (2) allworkers have completed therequired 8-hour intact resilient floorcovering removal training course(Compliance Directive at D-50 toD-52); and (3) prior to the removal,a competent person assesses the joband determines that the flooring isintact and likely to remain intactthroughout the removal process.

-- "Intact" means that flooring materialhas not crumbled, been pulverized,or otherwise deteriorated so that it isno longer likely to be bound with itsmatrix. Incidental breakage orslicing of flooring material whenusing work practices specifiedabove does not mean that thematerial is non-intact.

-- Competent persons supervisingintact flooring removal operationsonly must have the 8-hour workertraining course, plus four hours ofsupervisory training (ComplianceDirective at D-53 to D-54).

-- Respirators not required if materialremoved intact, even if heat is usedalong with other compliant workpractices and wet methods are not. (Note: respirators may be needed forreasons other than asbestos. Forexample, if tiles are overheated,harmful fumes might be releasedand a respirator with organic vaporcartridges might be needed.)

-- Caution: If the material is notremoved intact, additionalprotections, such as critical barriers,respirators, and additional trainingfor employees and competentpersons is required before work cancontinue (See OSHA ComplianceDirective at D-40 Paragraph 3 andD-44 Paragraph 10). Mechanicalchipping is prohibited unlessperformed in a negative exposureenclosure (g)(8)(I)(F).

-- For employers who remove ‘intact’flooring materials using compliant

work practices, the requirement tonotify employers of employees whowork on adjacent areas (k)(3)(ii)(B)applies only to employers ofemployees who, during removal offlooring material, work in areas notseparated from the work area by animpermeable barrier, which mayinclude a wall, closed door orwindow.

! Rules Unique to Removal/Repair ofAsbestos-Containing Roofing:

-- Remove intact to extent feasible. Isolate roof level heating andventilation air intake sources or shutdown ventilation system(g)(8)(ii)(A),(G).

-- Wet methods: Remove roofing wetif it is or will become non-intact,unless wet methods infeasible orwill create safety hazards(g)(8)(ii)(B). Wear respirators ifwet methods not used, except forintact removal of sloped roof ACMwith an NEA (h)(1)(iii). Continuously mist cutting machines,unless it substantially decreasesworker safety (g)(8)(ii)(C). (Seebelow for small scale work.)

-- To remove built-up roofs withasbestos-containing roofing feltsusing a power roof cutter: Foraggregate or smooth surface, collectresulting dust by a HEPA dustcollector or HEPA vacuuming; forsmooth surface, resulting dust mayalso be collected by gently sweepingand then carefully and completelywipe up all the still-wet dust anddebris, Immediately bag dust anddebris or place in covered containers(g)(8)(ii)(D). (See below for smallscale work.)

-- Wastes: Carry or pass roofing to theground by hand, or lower it viacovered, dust-tight chute, crane orhoist; do not drop or throw it to theground. Lower ACM to the groundas soon as practicable during the


work shift. While non-intactremoved ACM is on the roof, keepit wet, in an impermeable waste bag,or wrapped in plastic sheeting. Transfer unwrapped ACM to aclosed receptacle upon its beinglowered to the ground, precludingdust dispersion (g)(8)(ii)(E),(F).

-- Small scale work exception: Wetmethods or HEPA vacuuming notrequired when remove or repairunder 25 square feet of an intactroof on one day by manual methodswhich do not render the materialnon-intact or create visible dust(g)(8)(H).

Alternative methods for intactinstallation, removal (Class II), andrepair and maintenance (Class III)(g)(11):

-- Employer may use these methods; ifemployer does not, or material doesnot remain intact, general controlprovisions (g)(8) apply (g)(11).

-- Competent person inspects worksitebefore work and as needed duringjob to determine if roofing is intactand will likely remain so (g)(11)(I).

-- Train employees using (k)(9)(viii)curriculum (g)(11)(ii).

-- Use manual methods which do notrender roofing non-intact. Do notsand, abrade, or grind roofing(g)(11)(iii).

-- Carry or pass roofing to the groundby hand, or lower it via covered,dust-tight chute, crane or hoist; donot drop of throw it to the ground. Lower ACM to the ground as soonas practicable during the work shift(g)(11)(iv).

-- Employer notifies building owner ofpresence and location of AC roofingproducts installed on non-residentialroofs by end of job (g)(11)(v).

Class III ActivitiesRepair and maintenance operation where ACM, including TSI and surfacing ACM andPACM, is likely to be disturbed, limited in size to amounts that can be contained in astandard size glove or waste bag.


level.

! Regulated area (e), with signs (k)(7).

! Periodic monitoring when expect toexceed a PEL (f)(3)(ii).

! AHERA operations and maintenancecourse or equivalent (16 hours), unlessit does not cover the training neededfor the specific work, in which case,train on (k)(9)(viii) curriculum andspecific relevant work practices andengineering controls (g), with hands ontraining (k)(9)(v).


! Glove bag, mini-enclosure or otherisolation method required if TSI orsurfacing is cut, drilled, sawed, sandedabraded, chipped, or broken (g)(9)(iii).


-- Inspect sufficiently to assesswhether conditions have changed,and at any reasonable time uponemployee request (o)(3).

-- Currently be accredited in anAHERA operations andmaintenance course (16 hours), oran equivalent; or the supervisorcourse (o)(4)(ii).


! See discussion of roofing repair andmaintenance in Class II text, above.

Controls! Control include wet methods; local

exhaust ventilation where feasible;impermeable drop cloths, and mini-enclosures or glove bags when drilling,cutting, abrading, sanding, chipping,breaking.

! Impermeable drop cloths and mini-enclosure, glove bag, or other isolationmethod, when drilling, cutting,abrading, sanding, chipping, breakingor sawing TSI or surfacing (g)(9)(iii).

! On all other Class III operations, useimpermeable dropcloths and plasticbarriers, or glove bag, etc., if no NEA

or if PEL is exceeded.

! Respiratory protection where wetmethods are not used, except for intactremoval of sloped roofing ACM withan NEA; NEA not produced; TSI orsurfacing ACM or PACM beingdisturbed; a PEL exceeded; or in anemergency (h). An employer mustprovide an employee with a tight-fitting PAPR, in lieu of a negativepressure respirator, at the employee’srequest.

! Hygiene facilities and practices, whereexposures exceed a PEL, or no NEAproduced: Equipment room;decontamination of workers,equipment, and containers (j)(2).

Class IV ActivitiesMaintenance and custodial activities during which employees contact but do not disturbACM or PACM, and activities to clean up waste and debris resulting from Class I, II, andII activities.


level.

! Periodic monitoring when expect toexceed a PEL (f)(3)(ii).

! EPA awareness training course formaintenance and custodial workers orequivalent (2 hours) (k)(9)(vi). EPAdoes not consider 2-hour awarnesstraining adequate for Class IV workerscleaning up dust, waste and debris fromClass I, II and III work. These workersshould receive the training appropriatefor the Class of work involved. Caution to employers: do not allowworkers with only two hrs training todisturb asbestos.

! Assume waste and debris in areas withaccessible friable TSI or surfacingmaterials contain asbestos (g)(10)(ii);assume dust in close proximity to

deteriorated ACM also is ACM (C.P.L.2-2.63 at C-18).


-- Inspect sufficiently to assesswhether conditions have changed,and at any reasonable time uponemployee request (o)(3).

-- Currently be accredited in anAHERA operations andmaintenance course (16 hours), oran equivalent; or the supervisorcourse (o)(4)(ii).

Controls! Controls include wet methods, HEPA

vacuums, prompt clean up of debriscontaining ACM or PACM (g)(10).

! Respiratory protection where Class IVwork done in regulated areas where


other work requires respirators; a PELexceeded; or in an emergency(g)(10)(I), (h)(1).

! Hygiene facilities and practices:

-- When in regulated area, same as for

other work (j)(3).

-- When cleaning up TSI or surfacingACM or PACM debris and material,provide (j)(2) decontaminationfacilities (j)(3).


Minimum Training Requirements29 CFR 1926.1101

Training is the employer's responsibility,and must be provided (k)(9)(I)-(ii): ! at the employer's expense;

! prior to initial assignment; and! at least annually thereafter.

WorkersClass I:32 hr. EPA/AHERA (k)(9)(iii)

Class II:! all asbestos-containing materials.

except surfacing and TSI

C if work requires critical barriers,equivalent isolation or a negativepressure enclosure, then 32 hr.EPA/AHERA abatement workertraining is required.

! roofing, flooring, siding ceiling tiles,transite panels: 8 hr. minimumtraining time for each category ofmaterial, covering (k)(9)(iv):

C all (k)(9)(viii) elements;

C all applicable paragraph (g)elements

C The minimum curriculum forintact resilient flooring removaltraining course is set forth inOSHA Compliance directive at D-50 to D-52.

C "hands-on" training

! other miscellaneous materials: at leastfour hours for each category ofmaterial, but covering:




C If Class II materials are friable orbecome friable during removal,EPA requires the full 32 hourworker training course.

Class III:16 hr. EPA/AHERA O&M course(k)(9)(v)

Exception: where competent persondeems such training inadequate, and thentraining must include for each category ofmaterial worked with:




Class IV:2 hr. EPA/AHERA Awareness TrainingCourse or equivalent (k)(9)(vi)

Other Workers:! exposed at any level, even below PEL:

C General Safety training (29 CFR1926.21) and hazardcommunication (hazcom) training(29 CFR 1926.59)

! Employees likely to be exposed abovePEL (k)(9)(vii):

C training to include all (k)(9)(viii)elements.

! EPA does not consider 2 hours ofawareness training as adequate forworkers cleaning up dust, waste anddebris from Class I, II or III work. Workers involved in these activitiesshould have the training appropriate tothe class of work involved.


Competent PersonsClass I and II:40 hr. EPA/AHERA supervisor trainingcourse (o)(4)(I)

Exception:Class II intact1, resilient flooring removaloperations: 4 hr. supervisor coursesupplemental to basic 8 hr. workertraining course

Class III and IV:16 hr. EPA/AHERA O&M WorkerTraining Course or 40 hr. EPA/AHERAsupervisor training course. (o)(4)(ii). Thecompetent person for Class IV workinvolving clean-up of dust, waste anddebris from Class I, II or III activitiesshould have 40 hr. EPA/AHERAsupervisor training course.

1. These operations are described asnon-aggressive in the NIBS ModelGuide Specifications.


OSHA :ASBESTOS IN GENERAL INDUSTRY STANDARD (1910.1001):

Scope of coverageThe industry standard covers employeeexposure to asbestos in a wide variety ofindustrial and commercial settings wherethe employee is not engaged inconstruction activity. For example, thisstandard covers:

! General housekeeping involving

asbestos containing material inindustrial and commercial facilitiesunless such housekeeping occursduring or after construction activities.

! Repair and replacement of automotivebrakes and clutches.

General! Exposure, Assessments and Monitoring

-- Initial monitoring of employees whoare, or may reasonably be expectedto be, exposed to the time-weightedaverage (TWA) of 0.1 f/cc or theexcursion limit (EL) of 1 f/cc (30minute average) unless datagenerated after March 31, 1992 orobjective data show that the TWAand EL will not be exceeded.

-- Periodic monitoring required unlessinitial monitoring, if required, orperiodic monitoring statisticallyindicates that the employeeexposures are below the TWA orEL.

-- Additional monitoring needed whenwork changes or the other reasonmay cause new or additionalexposures above the TWA or EL.

-- Employer must notify employee ofmonitoring results.

! General controls

-- Use wet methods insofar aspracticable.

-- Compressed air to remove asbestos

is prohibited (unless in enclosedventilation systems).

-- Employee rotation to reduceexposure is prohibited.

-- When vacuuming asbestoscontaining waste and debris, HEPAvacuums are required and must beused so as to minimize asbestosdispersal.

-- Dry sweeping and shoveling onlywhere vacuuming and/or wetcleaning are not feasible.

-- Asbestos waste must be sealed inimpermeable labeled bags orcontainers so as to minimizeasbestos dispersal.

! Controls for Care of AsbestosContaining Flooring

-- Sanding is prohibited.

-- Stripping of finishes must use lowabrasion pads at speeds lower than300 rpm and wet methods.

-- Burnishing or dry buffing may beused only on floors with sufficientfinish so that pad does not contactACM.


Identification of Materials and Communication! Building/facility owner (which

includes a lessee) must informemployers of employees, andemployers must inform employees,who perform housekeeping activities inareas which contain ACM and/orpresumed asbestos-containing material(PACM) of the presence and locationof ACM and PACM in such areas.

! Presume or inspect surfacing, thermalsystem insulation (TSI), or resilientflooring material in housekeeping area:

-- TSI and sprayed-on or troweled-onsurfacing materials in buildings orsubstrates constructed before 1980are PACM; resilient flooringmaterial installed before 1980 isalso presumed to be ACM, although

the term “PACM” is not used for it.

-- Can rebut presumptions:

C For PACM, an AHERAinspection, or testing of thematerial being worked on by anAHERA-accredited inspector ora Certified Industrial Hygienist,is requires; a nationallyrecognized testing program(National Voluntary LaboratoryAccreditation Program (NVLAP)or equivalent) must be used foranalysis.

C For resilient flooring material, anindustrial hygienist must userecognized analytical techniques.

Warning LabelsLabels must be placed on productscontaining asbestos, including wastecontainers and, where feasible, installedproducts, unless asbestos fibers are bound

so that no reasonably foreseeable workwill release them above TWA or EL, orwhen less than 1%.

Training! Employer at no cost to employee who

performs housekeeping operations inareas which contain ACM or PACMmust provide an asbestos awarenesstraining course (2 hours) which covers(1) health effects of asbestos exposure;(2) location of ACM and PACM; (3)recognition of ACM and PACMdamage; (4) housekeepingrequirements; and (5) proper responseto fiber release episodes.

! For employees exposed to asbestos ator above the TWA or excursion limit,the employer must provide moreextensive training which covers (1)health effects of asbestos exposure; (2)smoking risks; (3) nature of asbestos

operations that could result in asbestosexposure; (4) engineering controls andwork practices; (5) respirators andprotective clothing; (6) medicalsurveillance and (7) warning signs andlabels.

! Record Retention

-- Exposure monitoring records: 30years. Records based on objectivedata: while employer relies on data.

-- Medical surveillance records:Employment plus 30 years.

-- Training records: Employment plusone year.

-- Data to rebut PACM: Whileemployer relies on data.


Requirements when Asbestos Levels Exceed TWA orExcursion Limit! All items required above.

! Regulated areas, which includesdemarcating the area from the rest ofthe workplace, limiting access toauthorized personnel, and postingwarning signs.

! Feasible engineering controls and workpractices to reduce exposures to PELand excursion limit and below.

! Respiratory protection which meetsselection requirements and respiratoryprotection program.

! Protective clothing, includinginspection for rips or tears. Launderingallowed under certain conditions.

! Hygiene facilities which include achange room, showers, and lunchroomfacility.

! Medical surveillance which includes anannual medical examination wheneveran employee is exposed at or above thePELs.

! Additional training.

OSHA Hazard Communication Standard(1926.59)

! The purpose is to ensure that thehazards of all chemicals produced orimported are evaluated, andinformation concerning their hazards istransmitted to employers and employees.

! The standard applies to any chemicalwhich is known to be present in theworkplace in such a manner thatemployees may be exposed undernormal conditions of use or in aforeseeable emergency.

! Chemicals must be evaluated todetermine if they are hazardous.

C Chemical manufacturers andimporters are required to performevaluations on chemicals theyproduce or import.

C Employers can rely on evaluationsperformed by manufacturers and/or

importers, or they can choose toperform their own evaluation.

! Employers are required to develop,implement and maintain a writtenhazard communication program at theworksite. The written program mustcontain information addressing thefollowing issues:

- Labeling containers and other formsof warning.

- Material safety data sheets.

- Employee information and training.

- A list of the hazardous chemicalsknown to be present at the worksite.

- The methods the employer will useto inform employees of the hazardsof non-routine tasks.


OSHAHead Protection(1926.100)

! Employees working in areas wherethere is a possible danger of headinjury from falling or flying objects, orfrom electrical shock and burns, mustbe protected by protective helmets.

! Protective helmets must meet thespecifications contained in ANSI Z89.1(impact and penetration), or ANSIZ89.2 (electrical shock and burns).

OSHAHearing Protection(1926.101)

Whenever it is not feasible to reduce noiselevels below the levels specified in 29CFR 1926.52, employees must beprovided with, and use, adequate hearingprotection.

OSHAEye and Face Protection(1926.102)! If the potential for eye or face injury

exists, employees must be providedwith eye and face protection. Thepotential for injury may come fromphysical, chemical or radiation agents.

! The eye and face protection must meetthe requirements specified in ANSIZ87.1.

OSHARespiratory Protection(1926.103)The standard contains some generalrequirements for respiratory protection. 29 CFR 1926.1101 contains some specificrequirements for respirator use duringconstruction activities involving asbestos. The requirements of 1926.1101 should be

followed, with 1926.103 (or other specificstandards, such as 1926.62, for lead) beingreferenced for issues not covered by1926.1101.


OSHASafety Belts, Lifelines, and Lanyards(1926.104)! Safety belts, lifelines and lanyards can

only be used for employeesafeguarding. A device must beimmediately removed from serviceafter being subjected to a service load.

! Specifications for safety belts, lifelinesand lanyards are given in the standard.

OSHAFire Protection and Prevention(1926.150)

Fire protection and prevention standardsare contained in Subpart F of 29 CFR1926.

Fire Protection (1926.150)

! The employer must develop a fireprotection program, which must befollowed throughout all phases of theproject. The program should ensure:

- There is no delay in providing thenecessary firefighting equipment.

- Access to the equipment ismaintained at all times.

- Firefighting equipment will beconspicuously located.

- Firefighting equipment will beperiodically inspected andmaintained in operating condition.

- If warranted by the project, a trainedand equipped fire brigade will beprovided by the employer.

- A temporary or permanent watersupply, sufficient for the firefightingequipment will be provided.

! Portable firefighting equipment will beprovided as follows:

- Portable fire extinguishers, oracceptable substitutes must beprovided for each worksite asspecified in the standard.

- Portable fire extinguishers shall beinspected periodically andmaintained in accordance withNFPA No. 10A-1970.

- Acceptable fire hoses withappropriate connections may besubstituted for fire extinguishers asspecified in the standard.

! Fixed firefighting equipment shall bemaintained operational as long aspossible during demolition projects.

! Employers shall establish fire alarmsystems to alert employees and the firedepartment during constructionprojects.

! Fire walls and exit stairways will begiven priority during construction, andfire cutoffs will be retained as long aspossible during alterations orrenovation.


OSHADisposal of Waste Material(1926.252)! Whenever materials are dropped more

than 20 feet to any point lying outsidethe exterior walls of the building, anenclosed chute shall be used.

! When debris is dropped through holesin the floor without the use of chutes,the area onto which the material isdropped shall be completely enclosedwith barricades constructed inaccordance with the standard.

OSHALockout and Tagging of Circuits(1926.417)

! The employer must maintain a writtencopy of the lockout/tagout procedures,and make the copy available toemployees.

! Electric circuits and equipment must bede-energized prior to employeesworking on them.

- Only qualified employees, asdefined by the standard, can performde-energization procedures.

- Safe procedures for the de-energization must be determinedprior to de-energizing circuits orequipment.

- Stored electric energy which mightendanger personnel must bereleased.

- Capacitors must be discharged andhigh capacitance elements must beshort-circuited and grounded if thestored electric energy mightendanger personnel.

- A qualified person must use testequipment to check that the circuitelements and electrical parts whichemployees will be exposed to areactually de-energized. The qualified person must also verifythat the equipment cannot berestarted after de-energization.

! Locks and/or tags must be placed on

each disconnecting means used to de-energize circuits and equipment asspecified in the standard.

- Locks must be applied in a way thatwill prevent any person fromoperating the disconnecting meanswithout using undue force.

- Each tag should contain a statementprohibiting unauthorized operationof the disconnect and removal of thetag.

- If a tag is used without a lock, whenpermitted in the standard, at leastone additional safety measure mustbe used which provides a level ofsecurity equivalent to the use of alock.

! Re-energization steps outlined in thestandard must be followed in order.

- A qualified person must conducttests and visual inspections, asnecessary, to verify that all tools,electrical jumpers, shorts, grounds,and other such devices have beenremoved prior to re-energizingcircuits or equipment.

- All employees exposed to thehazards associated with re-energizing the equipment must bewarned to stand clear.

- Each lock and/or tag must be


removed by the person who appliedit, or under his/her directsupervision, except as allowed bythe standard.

- A visual determination must bemade that all employees are clear ofthe hazards associated with re-energizing equipment and circuits.

! When employees are exposed to partsof fixed electric equipment or circuitswhich have been de-energized, thecircuits must be locked out, tagged out,or both in accordance with thestandard.

OSHAScaffolding(1926.451)

! Scaffolds must be erected inaccordance with the standard.

! The footing or anchorage for scaffoldsmust be sound, rigid and capable ofcarrying the maximum intended loadwithout settling or displacement. Unstable objects cannot be used tosupport scaffolds.

! A competent person, as defined by thestandard, must supervise the erection,movement, alteration, and dismantlingof scaffolds.

! Guardrails and toeboards must beinstalled on all open sides and ends ofplatforms more than ten feet above theground or floor, with the exception ofneedle beam scaffolds and floats. Scaffolds 4 feet to 10 feet in height,having a minimum horizontaldimension in either direction of lessthan 45 inches, must have standardguardrails installed on all open sidesand ends. Guardrails, midrails, andtoeboards must meet the requirementsset forth in the standard.

! Scaffolds and their components must

be capable of supporting 4 times themaximum intended load. Any scaffoldcomponent, including accessories mustbe immediately repaired or replacedwhen damaged or weakened by anycause.

! Lumber used in the construction ofscaffolding must meet thespecifications in the standard.

! An access ladder or other equivalentsafe access must be provided.

! The height of free-standing mobilescaffold towers cannot exceed fourtimes the minimum base dimension.

! The force necessary to move a mobilescaffold must be applied as near to thebase as practicable, and the tower mustbe stabilized during movement fromone location to another.

! Scaffolds can only be moved on levelfloors, free of obstructions andopenings.

! Employees must not ride on manuallypropelled scaffolds unless theconditions listed in 1926.451 are met.


OSHAGrounding for Protection of Employees(1926.954)! All conductors and equipment must be

treated as energized until tested orotherwise determined to be de-energized, or until grounded.

! Grounds should be placed between thework location and all sources of energy

and as close as practicable to the worklocation. The ground end should beattached first, and the other endattached and removed using insulatingtools or other suitable devices.


EPA Asbestos Hazard Emergency Response Act(AHERA)! Signed into law on October 22, 1986.

! Required EPA to developed regulationswhich provide a comprehensiveframework for addressing asbestosproblems in public and privateelementary and secondary schools. The regulations had to address:

- The inspection of all public andprivate school buildings for ACBM.

- The identification of circumstancesrequiring response actions involvingfriable ACM.

- Friable ACM means ACM, whendry, which may be crumbled,pulverized or reduced to powder byhand pressure and includespreviously non-friable materialwhich becomes damaged to theextent that when dry it may becrumbled, pulverized, or reduced topowder by hand.

- A description of the appropriateresponse actions involving friableACM.

- The implementation of responseactions involving friable ACM,including non-friable ACM thatbecomes friable when being workedon.

- The establishment of a reinspectionand periodic surveillance programfor ACM.

- The establishment of an operationsand maintenance program for friableACM.

- The preparation and implementationof asbestos management plans bylocal educational agencies (LEAs)and the submission of themanagement plans to StateGovernors.

- The transportation and disposal offriable waste ACM from schools.

- A model accreditation plan forpersons who inspect for asbestos,develop management plans, anddesign or conduct response actions.

- An accreditation program forlaboratories which analyze asbestosbulk and air samples.

Summary of AHERA regulationsRegulations were issued as Asbestos-Containing Materials in Schools; Final Rule andNotice (40 CFR Part 763)

! Requires local education agencies(LEAs) to identify friable andnonfriable ACM in public and privateelementary and secondary schoolbuildings. Inspections of schools inexistence at the time the standard wasissued must have been completed byOctober 12, 1988. Buildings acquiredafter October 12, 1989, which will beused as schools, must be inspectedprior to use as a school building (foremergency use they must be inspected

within 30 days).

! Inspections and reinspections mustfollow the protocol specified in thestandard (763.85), as must sampling(763.86), analysis (763.87) andassessment (763.88).

! Every time an assessment orreassessment is performed theaccredited inspector must provide awritten assessment of all friable knownor assumed asbestos-containing


building material (ACBM) in theschool building.

! LEAs must have submittedmanagement plans to the Governor oftheir State by October 12, 1988, begunimplementation of the managementplans by July 9, 1989, and completedimplementation in a timely fashion.

! LEAs must use accredited persons toconduct inspections, reinspections, andassessments, develop managementplans, or perform response actionsinvolving friable ACM, including non-friable ACM that becomes friable whenbeing worked on.

! LEAs must provide for thetransportation and disposal of friableasbestos in accordance with EPAguidance documents.

! LEAs must ensure that all maintenanceand custodial employees are properlytrained according to Federal and/orState regulations.

! LEAs must ensure that workers andbuilding occupants, or their legalguardians, are informed at least onceeach school year about asbestosinspections, reinspections, responseactions involving friable ACM, andpost-response action activities,including periodic reinspection andsurveillance activities that are plannedor in progress.

! LEAs must provide short term workerswho may come in contact with ACBMwith information about the location ofACM and material assumed to beACBM.

! Warning labels, meeting therequirements of the standard, must beposted.

! Management plans must be availablefor inspection.

! A person must be designated to ensurethat the requirements of the standardare met. The designated person mustreceive adequate training to perform allthe duties required by the standard.

! Reinspections of schools must beperformed at least once every threeyears after a management plan is ineffect. The reinspection must followthe protocol set forth in the standard.

! The LEA must select and implementappropriate response actions involvingfriable ACM consistent withinspections and assessments whichhave been conducted by accreditedinspectors Accepted response actionsinvolving friable ACM are outlined in763.90.

! LEAs must implement asbestosoperations and maintenance (O&M)programs whenever any friable ACBMis present or assumed to be present in abuilding it leases, owns or otherwiseuses as a school building. O&Mactivities must follow the specificationsof 763.91. Training of individualsinvolved with O&M activities mustfollow 763.92.

! At least once every 6 months after amanagement plan is in effect, aperiodic surveillance of schoolbuildings containing known or assumedACBM must be performed.

! Management plans must be developedaccording the requirements of 763.93.

! Records associated with ACM inschools must be maintained inaccordance with 763.94.


EPAAsbestos School Hazard AbatementReauthorization Act(ASHARA)

! Enacted on November 28, 1990.

! Applies to public and commercialbuildings.

! Did not require public and commercialbuildings to perform inspections forACM.

! Expanded the accreditationrequirements of AHERA to apply tocertain persons who work with asbestosin public and commercial buildings.Specifically, accreditation is requiredfor any person engaged in:

- Inspecting for ACM.

- Designing ACM response actionsinvolving friable ACM, includingnon-friable ACM that becomesfriable when being worked on.

- Conducting response actionsinvolving friable ACM. Thenumber of training hours forasbestos abatement worker trainingwas increased from 32 to 40.

- Provided for a civil penalty forcontractors who failed to complywith TSCA accreditation.

EPA Asbestos NESHAP (40 CFR 61.140-157)

Section 112 of the Clean Air Act (42U.S.C. 7401 and following sections),enacted in 1970, requires the EPA toaddress hazardous air pollutants. Thefollowing year, EPA designated asbestosas a hazardous air pollutant under the Act,and later issued its National EmissionStandard for Asbestos (40 CFR 61.140-157) as one of the National EmissionStandards for Hazardous Air Pollutants(NESHAP).

In general, the asbestos NESHAP requiresthat the owner or operator of a facility orof a renovation or demolition activity atthe facility:

• Inspect at least the area of the facilityto be renovated or demolished for thepresence of asbestos.

• Remove, transport and dispose ofRegulated Asbestos-containingMaterial RACM, as defined below,without releasing visible emissions,usually by using wet removal methods.

• Notify the EPA (or a State- or local-delegated agency) in advance of theremoval, above specified projectamounts or annual amounts, of theseregulated ACM. Note: All demolitionprojects require notification, regardlessof presence, or absence, of asbestos.

• Dispose of regulated asbestos-containing waste or convert it to non-asbestos material at an EPA-approvedfacility, and have a waste shipmentrecord, signed by the waste generator,transporter(s) and disposal facility,returned promptly to the owner oroperator.


NESHAP CoverageThe asbestos NESHAP covers mostasbestos removed from buildings otherthan single-family houses or apartments of4 or fewer units, which are not addressedby the standard. Before any renovation ordemolition project, the affected area mustbe thoroughly inspected for the presenceof asbestos. (The OSHA asbestos inconstruction standard describesrequirements for this inspection for mostbuildings; the EPA AHERA standard doesso for K-12 schools. See the discussion ofthese standards in this NIBS regulatoryappendix.)

The standard requires agency notification(par.145(b)), control of asbestos emissions(par.145(c)), and control of asbestos wastedisposal (par.150), for removing regulatedACM (defined below) of at least thefollowing threshold amounts (par.145(a)):

• 260 linear feet (80 meters) on pipes,

• 160 square feet (15 square meters) onother facility components, or

• 35 cubic feet (1 cubic meter) offfacility components where the length orarea could not be measured previously,

• All demolition projects, even if noasbestos is present.

These amounts apply to a singlerenovation or demolition project. Theyalso apply to work over a calendar year,such as from a series of renovations,demolitions, or an operations andmaintenance program.

For demolitions involving smalleramounts of regulated ACM, or a facility

being demolished under a State or localgovernment order because it is structurallyunsound and in danger of imminentcollapse, certain notification and controlsare retained, but some are eliminated. (Seebelow for descriptions.)

For the NESHAP, regulated ACM(RACM) is essentially ACM that mayrelease fibers during or after the removalwork. More formally, it is defined(par.141) as:

• Friable ACM, that is, ACM which,when dry, can be crumbled, pulverized, orreduced to powder by hand pressure.

• Category I nonfriable ACM (packing,gasket, resilient floor covering, or asphaltroofing product ACM) that has becomefriable, or will be or has been sanded,ground, abraded, or cut (but not sheared,sliced or punched).

• Category II nonfriable ACM (othernonfriable ACM) that has a highprobability of becoming or has beencrumbled, pulverized, or reduced topowder by the forces expected to act onthe material.

Based on this definition, Category Inonfriable ACM that has not and will notbecome friable, sanded, ground, abraded,cut, sawed, sheared, sliced, or punchedand Category II nonfriable ACM that hasnot and will not become crumbled,pulverized, or reduced to powder, are notRACM, and need not be removed prior todemolition. Mere breakage does not causenonfriable ACM to become RACM.

NotificationFor renovations involving the removal ofRACM above the threshold amounts, andfor all demolitions, the owner or operatormust notify the EPA (or a State- or local-delegated agency) fully in advance on aproject-by-project basis or annually(par.145(a)). Each individual project iscovered, even if some or all of them arebelow the threshold amounts, when the

threshold amounts are met or exceededover a calendar year by all of the activitiesat a facility together (par.145(a)(4)(iii)). Note: Individual O&M activities whichremove an amount of RACM above thenotification threshold must be separatelynotified as specific planned projects.


Content:These notifications for work at or abovethe threshold amounts must include thefollowing items (par.145(c)(4)), using aform similar to the form in the standard(par.145(b)(5)). (Note that States orlocalities may have additional notificationrequirements).

• Whether it is an original notice, orrevises or cancels a previous notice.

• Contacts: Names, addresses and phonenumbers of owner, removal contractor,and other contractor(s).

• Facility description: Address, worklocation, size of affected area, age,present and prior use.

• Operation description:

-- Whether work is renovation ordemolition (taking out any load-supporting structural member andrelated handling, or intentionalburning).

-- Inspection, sampling and analyticalmethods to detect RACM andnonfriable ACM. Note that theseinspections generally must beperformed by an EPA-MAPaccredited person and many statesrequire them to be licensed, as well. However, EPA does not requireMAP accreditation for inspectionsof resilient flooring prior to removalor repair of flooring that has notbeen sanded, ground, mechanicallychipped, drilled, abraded, or cut(sawed, but not sheared, sliced orpunched).

-- Estimated amount of RACM to beremoved.

-- Estimated amount of nonfriableACM that will not be removedbefore any demolition.

-- Scheduled starting and completiondates of asbestos-related work, andof all of the demolition orrenovation work.

-- Renovation, demolition, andasbestos emission control methods,and affected components.

-- Name and location of EPA-

approved asbestos waste disposalsite.

-- Certification that at least one “on-site representative” of managementtrained in the NESHAP will bepresent during the asbestosdemolition or renovation work(par.145(c)(8)). An OSHA‘competent person’ may satisfy thisrequirement if trained in NESHAPrequirements.

-- Procedures to be followed ifunexpected RACM is found orCategory II nonfriable ACMbecomes friable.

Schedule:These notifications for work at or abovethe threshold amounts must be deliveredto the agency:

• By regular mail, commercial deliveryor hand delivery, but not facsimile ore-mail (par.145(b)(1)).

• For a single project, at least 10 workingdays before the start of work whichmay disturb asbestos (par.145(b)(3)(I)).

• For a calendar year’s worth of projects,at least 10 working days before thestart of the calendar year. (Delivery byDecember 11 satisfies this requirementin every year.) For annual notification,the period of work in the notice is thewhole year.

• For a delayed start, by telephone andwritten notice as soon as possiblebefore the original starting date. For anadvanced start, by written notice atleast 10 working days before theasbestos work or demolition.

• When items in the notification change,including when the amount of asbestosaffected changes by 20% or more orchanges in start or completion dates.


Special cases:For demolitions involving amounts ofRACM smaller than the threshold(par.145(a)(2)): (However, note that allfriable asbestos, in any amount, must beremoved prior to demolition.)

• Notice must be delivered at least 10working days before demolition starts.

• The form in the standard need not beused.

• Certain notification elements need notbe provided:

-- Scheduled starting or completiondates of asbestos-related work,although the dates for the wholedemolition or renovation work muststill be given.

-- Renovation, demolition, or asbestosemission control methods, oraffected components.

-- Waste disposal site name orlocation; or the transporter(s)contact information.

-- Having an “on-site representative,”although a “competent person”under the OSHA constructionstandard, with generally similartraining, must still supervise thework.

For demolition under a State or localgovernment order because a facility isstructurally unsound and in danger ofimminent collapse:

• Deliver a copy of the order, and certainrelated information (par.145(b)(xv)).

• Some notification elements are reduced(par.145(a)(3)):

-- The notice must be delivered asearly as possible before the asbestoswork, but never later than theworking day following its start.

-- Scheduled starting and completiondates of asbestos-related work neednot be provided, but the dates of thewhole demolition or renovationwork must be submitted.

For emergency renovations resulting fromsudden, unexpected events(par.145(a)(4)(iv)):

• The notice must be delivered as earlyas possible before the asbestos work,but never later than the working dayfollowing its start (par.145(b)(3)(iii)).

• No revised notice need be submitted ifthe starting date changes(par.145(b)(3)(iv)).

ControlsIn general:

• Adequately wet all RACM (par.145(c)(6)). (Note: user should becomefamiliar with EPA Booklet,“Asbestos/NESHAP Adequately WetGuidance” (Dec., 1990).) Certainexceptions are described below forusing HEPA filtered control ofstripping or leak-tight wrapping. Another exception is if the temperatureat the point that would be wet is below32oF (0oC), in which case (par.145(c)(7)): (Note that EPA must givewritten permission for dry removal,except for freezing weatherconditions.)

-- Remove facility components with

RACM in units or sections to themaximum extent possible.

-- Record temperatures at the start,middle and end of the workday, andkeep records on site at least 2 years.

• Carefully lower RACM to the groundor floor (do not drop, throw, slide orotherwise damage or disturb it) (par.145(c)(6)); if RACM is removed over50 feet (15 meters) above ground level,transport it in leak-tight chutes orcontainers (par. 145(c)(6)(iii)).

• Have at least one on-site representativeof management trained in the NESHAPand the means of complying with it, present during stripping, removal orhandling or disturbance of RACM (par.


145(c)(8)).

-- The training of the on-siterepresentative shall follow thecurriculum in par. 145(c)(8), withdocumentation posted, and refreshedat least every 2 years.

-- The EPA accepts persons who areaccredited as asbestoscontractor/supervisors underAHERA as being trained as on-siterepresentatives under the NESHAP. A “competent person” or “qualifiedperson” under the OSHA asbestos inconstruction or shipyard standards,respectively, may also be an on-siterepresentative if that person’straining covers the NESHAP as wellas OSHA requirements.

Before demolishing a building by burning,remove all ACM, including friable ACM,Category I nonfriable ACM, and CategoryII nonfriable ACM, in accordance with theNESHAP (par. 145(c)(10)).

Before a renovation or demolition thatwould break up, dislodge or similarlydisturb RACM or preclude access to it forsubsequent removal, remove all affectedRACM (par. 145(c)(1)); except that theaffected RACM need not be removed ifthe RACM is:

• Category I nonfriable ACM not in poorcondition or friable.

• Category II nonfriable ACM unlikelyto be made friable during or after thework.

• On a facility component encased inconcrete or similarly hard material andis kept adequately wet wheneverexposed during demolition.

• Untested because it was inaccessibleuntil demolition, and the demolitionhas made its removal unsafe. This

RACM and any asbestos-contaminatedwaste must be kept adequately wetuntil their disposal as asbestos-containing waste.

To remove a facility componentcontaining, covered or coated withRACM, in units or sections:

• During removal, adequately wetRACM exposed, and carefully lowereach unit or section (do not drop,throw, slide or otherwise damage ordisturb the RACM) (par. 145(c)(2)).

• After removal, strip it of RACM,keeping the RACM adequately wetduring stripping, or use a HEPAfiltered local exhaust ventilation andcontrol system during stripping (pars.145(c)(4)).

• If it is a large facility component (e.g.,reactor vessel, large tank, steamgenerator, but not a beam), it need notbe stripped if it is encased in leak-tightwrapping with an asbestos danger labeland handled without disturbing ordamaging the RACM (par. 145(c)(5)).

To strip RACM from a facility componentremaining in the facility (par. 145(c)(3)),adequately wet the RACM duringstripping, unless the owner or operator:

• Has written approval by the EPA ordesignated agency (with the approvaldocument on site) based on safetyhazard or unavoidable equipmentdamage, and

• Uses an alternative control method:HEPA filtered local exhaust ventilationand collection system, a appropriateglove bag system, leak-tight wrappingbefore dismantling, or other EPA-approved method equivalent in itscontrol efficiency (with the approvaldocument on site).


Waste DisposalRACM waste must meet NESHAPwetting and labeling requirements (par.150). In general, waste collection,processing, packaging and transportingasbestos-containing waste must yield novisible emissions of asbestos to the outsideair.

• This is generally met by adequatelywetting asbestos-containing waste:

-- For most waste disposal, the wasteis sealed in leak-tight containers orwrapping labeled with OSHAasbestos warning labels, the namesof the waste generator, and thelocation of waste generation (par.150(a)(1)), and deposited as soon aspractical (pars. 150(b)(1),(2)) at aregulated waste disposal site or afacility that converts asbestos wasteto asbestos-free waste approved bythe EPA and operated as describedin sec.155.

-- For demolitions where some RACMwas not removed beforehand, theasbestos-containing waste must bekept wet after demolition, duringhandling and loading for transport. The waste may be sealed in leak-tight containers or wrapping ortransported and disposed of in bulk(par. 150(a)(3)).

-- EPA-approved alternative methodsof emission control during wastedisposal may be used (par.150(a)(4)).

Vehicles transporting asbestos-containingwaste must be visibly marked withasbestos danger signs during loading andunloading of waste (par. 150(c)).

For all asbestos-containing waste beingtransported off the generating buildingsite, a waste shipment record must be

completed by the facility or removalproject owner or operator.

• The waste shipment record mustidentify the EPA (or its designatedagency) office, waste generator, wastetransporter(s), and disposal site orconversion facility; and characterizeand certify the correctness of theclassification, packing, marking andlabeling of the waste (par. 150(d)(1)).

• The waste shipment record must be:

-- Signed by representatives of theowner or operator, the transporter(s)and the disposal site or conversionfacility.

-- Returned to the owner or operatorwithin 35 days after its departurefrom the building (par.150(d)(1),(3)). (If it is not returnedwithin 45 days, this must bereported to the EPA (par.150(d)(4)).)

-- Retained for at least 2 years (par.150(d)(5)).

Make all records relating to waste disposalavailable for EPA inspection (par. 150(e)).

• Exceptions:

-- Nonfriable ACM waste that did notbecome crumbled, pulverized, orreduced to powder need not meetNESHAP wetting and labelingrequirements (par. 150(a)(5)).

-- Category I nonfriable ACM wastethat has not nor will not becomefriable, sanded, ground, cut, orabraded need not be deposited at aregulated waste disposal site orwaste conversion facility (par.150(b)(3)).


DOT Hazardous Material Rules

The Department of Transportation (DOT)issues hazardous material rules (HMR)under the Hazardous MaterialsTransportation Act, to help ensure thatadequate information is available totransporters for their safety and that of thepublic, about materials being shippedcommercially over public roads,waterways and airways.

The HMR does not cover asbestos fixed ina binder such as cement, plastic, asphalt,resins or mineral ore (e.g., non-friable

asbestos-containing material (ACM) thathas not become crumbled, pulverized orreduced to powder), or asbestos containingmanufactured products (e.g., pipegaskets). Similarly, the HMR does notcover shipments under 1 pound of friableACM.

Packaging of ACM for commercialtransportation must meet hazardousmaterial rule requirements (found mostlyin 49 CFR 171-173) and generally beprotective, marked and labeled.

Small quantities:! Bulk samples over 1 ounce (30 grams)

each of friable ACM are subject to theHMR if the whole package contains1 pound or more.

! A “small quantity" shipment of bulksamples is exempt from the HMR if thesamples are each 1 ounce (30 grams) orless in cushioned, securely sealed andpacked inner containers of plastic (atleast 8 mil (0.2 mm) thick), glass, metal

or earthenware.

! The entire, strong package must weigh64 pounds (29 kg) or less, and bespecially marked.

! Packages of air sample filters are notsubject to the HMR, since they containless than 1 pound of friable asbestos.

Limited quantities:! A "limited quantity" shipment is

exempt from marking if it weighs 66pounds (30 kg) or less with innerpackagings up to 11 pounds (5 kg) eachin the strong outer packaging.

! It is also exempt from labeling unless itis being shipped by air.

Labeling:! Packages must generally have a class 9

label, unless excepted. (See "Smallquantities," "Limited quantities," and

"DOT exceptions".)


Shipping papers:! Entries used in the hazardous material description on shipping papers are:

RQ, Reportable Quantity, if 1 lb or more friable asbestos.

WASTE For waste material, if applicable.

ASBESTOS Shipping name; for domestic transportation only; seeNote below.

MIXTURE, For asbestos mixed with a binder or filler, etc.

9, Class 9, Miscellaneous Hazardous Materials, includesasbestos.

NA2212, North American identification number; for domestictransportation only; see Note below.

PG III Packing Group; for domestic transportation only; seeNote below.

LTD QTY, Limited quantity, if applicable.

20 OZ Total quantity of material described; may abbreviateunit.

Note: See international transportation requirements, below.

Marking:! Packaging must be marked, except for small quantities, limited quantities, and exempt

packages. See "Small quantities."

! Entries for non-bulk packagings:

RQ, Reportable Quantity, if 1 lb or more friableasbestos.

WASTE, For waste material, if applicable, or use EPAmark.

ASBESTOS, Shipping name; for domestic transportationonly; see Note below.

MIXTURE, For asbestos mixed with a binder or filler, etc.

NA2212, North American identification number; fordomestic transportation only; see Note below.

JANE Q. PUBLIC INTL. CO. Consignee or consignor name and address;

1234 MAIN ST. except some direct road or train transport.

OURTOWN, ZZ 99999Note: See international transportation requirements, below.

! A bulk packaging (uncommon for asbestos waste shipments) must be marked with apanel, placard or other display.


Shipping limitation:! For domestic transportation, asbestos

shipments are limited to 440 pounds(200 kg) by aircraft or passenger-

carrying railcars, unless the asbestos isstabilized in a binder.

Vehicle marking:! A vehicle transporting asbestos-

containing waste subject to the HMRmust be marked with asbestos danger

signs during loading and unloading ofthe waste.

Waste shipment record:! The record must be completed as

required for each shipment of ACMwaste subject to the HMR.

! A copy signed by the transporter mustbe given to the waste generator, (i.e.,the building owner or operator, suchas a maintenance or abatementcontractor) when the waste leaves the

building site, and a copy signed by thedisposal site must be received in 45days.

! If the record is not received within 35days, the transporter or disposal sitemust be contacted to determine thestatus of the waste shipment.

International transportation:! The HMR defines:

-- Crocidolite asbestos as "blueasbestos."

-- Amosite and mysorite asbestos as"brown asbestos."

-- Chrysotile, actinolite,anthophyllite and tremoliteasbestos as "white asbestos."

! Shipping limitations:

-- "Blue" or "brown" asbestos, other than a "small quantity" shipment or ACMwhich is stabilized in a binder (e.g., nonfriable ACM in good condition; see"DOT exceptions"), is forbidden from aircraft or passenger-carrying railcars.

-- "White" asbestos is limited to 440 pound (200 kg) shipments by aircraft orpassenger-carrying railcars, unless it is similarly stabilized in a binder.

-- Information: For international transportation, the following United Nations (UN)shipping names, identification numbers and packing groups must be used. (Theymay also be used for domestic transportation.)

WHITE (or BLUE UN shipping names; see "shipping limitations," or BROWN) ASBESTOS below.

UN2590 (or UN2212, UN identification numbers.

or UN2212)


PG III (or II or II), Packing Groups; II and III are medium andminor; use II if mixed shipment.

-- Marking mixed international shipments: When asbestos of two or more UNdescriptions are mixed in an international shipment, each is listed on the markand shipping papers. For example, a shipping paper might show: "RQ, Wasteblue and white asbestos mixture, 9, UN2212 and UN2590, PG II, Ltd Qty,22 lbs."

DOT Exceptions:! The HMR does not cover asbestos

fixed in a binder such as cement,plastic, asphalt, resins or mineral ore(e.g., non-friable ACM that has notbecome crumbled, pulverized orreduced to powder), or asbestoscontaining manufactured products(e.g., pipe gaskets).

! The HMR does not cover shipmentsunder 1 pound of friable ACM.

! Packaging of ACM must meet specificrequirements, but need not meet HMRperformance oriented packagingspecifications for Packing Groups IIand III.

A67 # Appendix J # NIBS Feedback Form # © NIBS 1996 # Page - 463

Appendix J - Feedback FormThis form is to be used to provide comments to NIBS concerning use of the Guidance Manual: Asbestos O&M Work Practices. Comments and suggestions submitted will be considered duringfuture revisions to the manual. Any relevant data derived from the use of the work practices may besubmitted.

Date:_____________________

Comment applies to section: I II III IV V VI VII

Work Practice (if applicable):___________ Level: A B C

Comment/recommendation:______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Supporting data orinformation:_______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Submitted by: ________________________________________________________________________________________________________________________________________________________________________________________________

Phone: ________________________________________________________________

Please Return to: NIBS1201 L Street, N.W. Fourth FloorWashington, D.C. 20005(202) 289-7800 FAX: (202) 289-1092

Project Committee S Steering Committee Members

Chairman: S Ralls C. Melotte,AIA - Analytical Design Group, Inc.Vice-Chairman: S Casimer Szewczak - Navy Environmental Health CenterSecretary: S Robert J. DeFrank - University of Maryland, College Park

S Walter D. Anderson - Resilient Floor Covering Institute (RFCI)Richard A. Baker, CPS - Ramsey-Schilling Consulting Group, Inc.William Basta - Environmental Science & Engineering, Inc.Karone Blondin, CIH - GSA, Office of Property Management (PM-2) Rm 4321Richard Bodane - New York State Office of General ServicesMary Frances Branton - U.S. Department of Veterans AffairsWilliam J. Brendle - Foster Products CorporationJames O. Bynum - U.S. Army Research LaboratoryJeffrey C. Camplin, C.S.P. - Camplin Environmental Services, Inc.Marvin J. Cantor, FAIA - Marvin J. Cantor, AIA & AssociatesR. Wayne Crandlemere - R.W. Crandlemere & Associates, Inc. S Neil Davis, CIH - Carpenters Health and Safety FundR. Landon Doggett - Law Engineering, Inc.Adrian Ducharme, REM - Aguirre Engineers, Inc. S Paul L. Elkourie - BellSouth TelecommunicationsJames B. Evans - O'Brien & Gere Engineers, Inc.William M. Ewing, CIH - Compass Environmental, Inc.Pedro Fernandes - Chastain-Skillman, Inc.James Fite - White Lung Association S William H. Freeman, Jr. - Armstrong World IndustriesNeal B. Freuden - EnviroScience Consultants, Inc. S Warren Friedman, Ph.D., CIH - Office of Lead-Based Paint;Dept. of Housing and Urban DevelopmentChristopher K. Gale - Gale/Jordan Associates, Inc.C. Michael Gambone - James River Environmental Services, Inc.Robert A. Georgine - Building & Construction Trades Department, AFL-CIOJoseph D. Green, CIH, CSP - Occupational Health and Hygiene Corporation of AmericaPaul J. Grogan - New England Power Service Company (NEPSCO)William N. Hall, Esquire - Winston & Strawn S Richard L. Hatfield - Law Engineering, Inc.George Hatt - Veritech Environmental Services S Steve M. Hays,P.E., CIH - Gobbell Hays Partners, Inc.Paul Heffernan - EC & CA S William H. Hoffman - QuestCo, Inc.Lawrence A. Holbrook - Towson State UniversitySteven Hughes - PSIBethann Jakoboski - Armstrong World Industries, Inc.Robert Jordan, Ph.D. - U.S. Environmental Protection AgencyNorbert W. Kaleta - National Gypsum Co.Robert W. Kemp - A & B Asbestos Abatement, Inc.Jan Koehn - Jan Koehn, M.S., CIH, Inc.Bill Kojola - Laborers' Health and Safety Fund of North AmericaBrent Kynoch - AAS Environmental, Inc. S Nora Leyland - Sherman, Dunn, Cohen, Leifer & Yellig

Chris Lovelace - NCDEHNR-Asbestos BranchRichetta L. Lynch - Law EngineeringGeorge T. Macaluso - Laborers' Health & Safety Fund of North AmericaMichael McGuinness, CIH/CET - R.K. Occupational & Environmental Analysis, Inc.Nish Messerian - U.S. Department of Veterans AffairsRobert Molseed, AIA, FCSI - AIA Master Spec, Inc.Nicolaus P. Neumann, P.E., C.P.G., DEE - NPN Environmental Engineers, Inc.Jeannie Nordstrom - U.S. Department of Veterans AffairsB. J. Pigg - Asbestos Information Association/North AmericaRita D. Pittillo - U.S. Department of Veterans AffairsRobert E. Robb, Jr. - The Environmental Group, Inc.Gordon L. Rosby - AEC, Inc.Robert Schmitter - Georgia Tech Research InstituteScott Schneider, CIH - Center to Protect Workers' RightsThom Snyder - Naval Facilities Engineering CommandCharles Swink - Walt Disney World CompanyJohn Sylvester, Jr. - Sylvestor & Company S William A. Tippin, IV - EnviroControl, Inc.Daniel R. Twilley - General Physics Corp. S James L. Werner - U.S. Dismantlement CorporationJudith A. Whelan - Whelan Associates, Inc.Michael A. Wiegard - Paul, Hastings, Janofsky & WalkerChrystene Wyluda - N.J. Department of Community Affairs

Contractor

Roger G. Morse, AIA, Postenkill, N.Y.

NIBS Project Staff

Alexander T. Shaw, III, Program ManagerPamela W. Towns, Manager - Publications/Membership RecordsPatricia Cichowski, Administrative Assistant

CONSULTATIVE COUNCIL

Chairman: William Kojola - Laborers International Union, Health & Safety Department, Washington, DCVice Chairman: Marvin J. Cantor, FAIA - Architectural Offices, Alexandria, VASecretary: William H. Freeman, Jr. -Armstrong World Industries, Lancaster, PA

Francis W. Biehl, P.E. - Biehl Engineering, Inc., Menomonee Falls, WI Kenneth E. Bland, P.E. - American Forest & Paper Association, Washington, DCLiza K. Bowles - NAHB Research Center, Upper Marlboro, MD Gregory L. F. Chiu -Insurance Institute for Property Loss Reduction ,Boston, MADr. Andrew J. Fowell - Bldg&Fire Research Lab, Natl. Institute of Standards &Technology, Gaithersburg, MDTom Frost - BOCA International, Country Club Hills, IL David C. Haataja - Underwriters Laboratories, Inc., Washington, DC Whayne H. Haffler, AIA - Architect, Washington, DC David M. Hammerman, P.E. - Howard County Inspections, Licenses and Permits, Ellicott City, MD David B. Hattis - Building Technology, Inc., Silver Spring, MD Donald M. Holmes, P.E. - Clapp & Holmes Consulting Engineers, Harrisburg, PA John B. Kelso, AIA - Kelso & Easter, Inc., Alexandria, VA Rita E. Knorr - American Society of Civil Engineers, Reston, VA David L. Ledvinka - Construction Industry Consultants Group, Westerville, OH Gabor Lorant, FAIA - Lorant Group, Inc., Phoenix, AZ Joseph R. Loring, P.E. - Joseph R. Loring & Associates, New York, NY W. Max Lucas, Ph.D. - University of Kansas, Lawrence, KS Vernon McDougall - United Brotherhood of Carpenters, Health & Safety Fund, Washington, DCAnthony R. O'Neill - National Fire Protection Association, Arlington, VA W. Lawrence Schwab, CSP - State Farm Fire & Casualty Company, Bloomington, IL Dr. Paul A. Seaburg - University of Nebraska, Omaha, NE Kenneth M. Sedor - Real Estate Support Services, Inc., Minneapolis, MN Lloyd H. Siegel, FAIA - Department of Veterans Affairs, Washington, DC Dana K. Smith - Naval Facilities Engineering Command, Alexandria, VA David A. Swankin - Swankin & Turner, Washington, DC William A. Tippin, IV - EnviroControl, Inc., Alexandria, VA Michael E. Wilson - Associated Builders and Contractors, Rosslyn, VA H. Glenn Ziegenfuss, Ph.D. - American Welding Society, Miami, FL

BOARD OF DIRECTORS

Chairman: Gerald H. Jones, P.E., Kansas City, MOVice-Chairman: Thomas I. Young, FCSI, CCS, Smith, Hinchman & Grylls Associates, Inc., Detroit, MISecretary: Edward W. Rogers, A.G. Edwards & Sons, Inc., Midland, MITreasurer: Michael L. McCune, Argus Real Estate, Inc., Denver, CO

Walter Scott Blackburn, FAIA, Principal, Blackburn Associates Architects, Indianapolis, INJack E. Buffington, P.E., Director, National Rural Transportation Study Center, Univ Arkansas, Fayetteville, AR Dale C. DeHarpport, Principal, Four D. Construction Company, Beaverton, OR Mary Ellen Fise, General Counsel, Consumer Federation of America, Washington, D.C. Warren Friedman, Ph.D., CIH, Manager Abatement Tech. Research, Ofc Lead-Based Paint, HUD, Washington, D.C.J. Lee Hauser, P.E., Senior Deputy Commissioner, N.C. Department of Insurance, Raleigh, NC Steve M. Hays, P.E., C.I.H., Chairman of the Board, Gobbell Hays Partners, Inc., Nashville, TN William H. Hoffman, President, QuestCo, Inc., Easton, MD Jack Kelley, P.E., President, Nickerson & O'Day, Inc., Bangor, ME John H. Miller, P.E., President, Close, Jensen and Miller, P.C., Wethersfield, CTMonte L. Phillips, P.E., Professor, Dept. of Civil Engineering, University of North Dakota, Grand Forks, ND Arnold J. Prima, Jr., FAIA, Washington, D.C. H. Terry Rasco, FAIA, Partner, Witsell Evans & Rasco, P.A., Little Rock, ARRussell E. Sanders, Central Regional Manager, National Fire Protection Association, Louisville, KYWalter Smittle, III, Fire Marshal, State of West Virginia, Charleston, WV David T. Still, Vice President & Gen. Mangr, Building Materials Distribution, Weyerhaeuser Company, Tacoma, WA Christine M. Warnke, Ph.D., Governmental Affairs Advisor, Hogan & Hartson, Washington, D.C.

NIBS PROFESSIONAL STAFF

David A. Harris, FAIA, PresidentBruce E. Vogelsinger, P.E., Vice-President of Planning and CouncilsJohn G. Lloyd, Vice-President of Finance and AdministrationEarle W. Kennett, Vice President for CCB ProgramsWilliam A. Brenner, AIA, Vice President & Executive Director, Construction Metrication CouncilJames R. Smith, Executive Director, Building Seismic Safety CouncilThomas R. Hollenbach, Assistant Executive Director, Building Seismic Safety CouncilPhilip Schneider, AIA, Director, Earthquake Loss Estimation Methodology StudyNeil Sandler, Director of CommunicationsLayne Evans, Director CCB Information SystemsLillian Funk, Director CCB Computer Systems Alexander T. Shaw, III, Project ManagerMichael D. Cohn, Project ManagerPamela W. Towns, Manager - Publications/Membership RecordsKelly Sue McCullough, Manager Building Product PreApproval Program Edmond H. Gryder, Manager, Technical Resources & Software DevelopmentAlynne C. Skrabalak, CCB Information Services ManagerKathleen A. Keller, SpecText, Subscriber Services ManagerRobert M. Payn, CCB, Production ManagerPatricia Broughton, CCB, Subscriber Services ManagerPatricia A. Blasi, Manager, Office ServicesClaret M. Heider, Technical Writer/Editor

Gene C. Brewer, President Emeritus

National Institute of Building Sciences 1090 Vermont Avenue, NW, Suite 700Washington, D.C. 20005-4950Phone: (202) 289-7800Web: www.nibs.org