Asbestos Operations and Maintenance
Asbestos Operations and Maintenance Trainings & Quick Links
Asbestos Operations and Maintenance Program Summary
The Asbestos Operations and Maintenance Program has been developed to address the management of asbestos containing building materials (asbestos-containing materials or asbestos-containing bulding materials) on campus.
Asbestos is a naturally occurring mineral, which is found throughout the world. Historically, it was used in more than 3,000 products because of its fireproofing and insulating properties. It can be woven into fabric or added into various substrates to improve functionality.
When asbestos-containing material can be easily crumbled or reduced to powder, the fibers can be released and become airborne, posing a potential inhalation hazard. Most of the health risk information regarding asbestos exposure has been derived from studies of workers involved in asbestos-related occupations. Certain cancers, such as mesothelioma, and respiratory diseases are more prevalent in such occupations and may have a latency period of ten to 40 years. More information on the health effects of asbestos exposure is provided at all levels of asbestos training.
This program applies to the management of asbestos-containing building materials on campus. The primary purpose is to minimize the exposure of building occupants, maintenance workers, and outside contractors to asbestos fibers.
Activities involving asbestos-containing building materials must comply with all local, state, and federal regulations, as applicable. Departments involved in asbestos-related activities shall designate a responsible person to coordinate program requirements at the university.
Asbestos Operations and Maintenance Online Program
The purpose of the Asbestos Operations and Maintenance Program is to minimize the exposure of building occupants, maintenance, and custodial personnel to airborne asbestos fibers. Asbestos is a naturally occurring mineral that has been historically used in certain products to improve functionality, such as heat or corrosion resistance. The fibers, which can be microscopic, can become airborne and be inhaled into the lungs. This program has been designed to comply with applicable state and federal regulations pertaining to asbestos. Agencies with regulations applicable to asbestos work at Virginia Tech include:
- Virginia Department of Labor and Industry (VDOLI);
- Virginia Department of General Services (DGS);
- Virginia Department of Professional and Occupational Regulation (DPOR);
- Virginia Department of Transportation (VDOT);
- Occupational Safety and Health Administration (OSHA); and
- Environmental Protection Agency (EPA).
The Operations and Maintenance program applies to all university-owned properties, employees, and the public. The program shall remain in effect until all asbestos-containing materials have been removed from all university properties. Leased properties shall include appropriate disclosures.
Requirements to minimize or eliminate potential exposure of building occupants and employees to asbestos include:
- Surveying and periodically assessing all suspect and known asbestos-containing materials to monitor the condition and ensure that it is maintained in an undamaged non-hazardous condition.
- Providing guidance on asbestos project management to ensure renovation, construction, or emergency maintenance activities are performed safely.
- Ensuring the prompt cleanup of asbestos fibers accidentally released into the atmosphere.
- Training individuals who may encounter asbestos-containing materials during their normal work activities.
Occupants of buildings should presume that most building materials (e.g. ceiling tile, floor tile, wall materials, pipe insulation) contain some degree of asbestos, and should exercise caution to assure suspect asbestos-containing materials is not to be damaged or disturbed except under controlled conditions by trained personnel. Occupants may review asbestos-related building survey records for their building (or work area) by contacting their designated departmental safety representative or Environmemtal Health & Safety as follows:
- Gabe Lineberry for NI&S employees performing work tasks in various buildings on campus.
- Jonathan Spence for Division of Student Affairs buildings on campus.
- Mark Nester for buildings covered by the Division of Campus Planning, Infrastructure, and Facilities on campus.
- Robin Miller for all other buildings on campus that do not fall under one of the above.
Departmental contacts are notified of upcoming asbestos-related abatement projects via VT Repair notices. These notices explain the work that will be performed and the measures that will be taken to reduce the potential for exposure during the project. The person receiving the notice should share with building occupants prior to all abatement projects to determine whether additional precautionary measures may need to be addressed.
Departments involved in work-related activities where asbestos-containing materials may be disturbed during maintenance, custodial, renovation, or demolition activities shall:
- Designate a safety representative specifically to address asbestos activities.
- Manage projects involving asbestos abatement.
- Retain project documentation in such a manner that it is available upon request to Environmental Health & Safety, Virginia Occupational Health and Safety, or others as necessary.
- Update electronic information regarding the location of materials in campus facilities.
- Serve as administrator for university contracts for analytical, inspection, project monitoring, and abatement activities (with input from Environmental Health & Safety).
- Ensure asbestos worker, operations and maintenance, asbestos supervisor, asbestos inspector, and project monitor training is provided (by a third party) to employees involved in asbestos activities.
- Maintain a labeling program to identify known asbestos-containing materials in buildings under their purview.
Renovation, demolition, alteration of building material (i.e. wall, ceiling, floor, insulation, etc.), or maintenance activities that may disturb asbestos-containing materials shall not occur unless it has been reviewed and approved by the DSR. Designated departmental asbestos safety representatives are responsible for the following:
- Serving as asbestos inspector for their department.
- Inspecting worksites and sampling suspect bulk materials for asbestos (if historical information isn't available).
- Maintaining records and communicate results to relative parties for upcoming projects (i.e. supervisors, project managers, contractors, etc.) on the "Asbestos and Lead Inspection Report."
- Providing or coordinating project monitoring services with the project manager during renovation and maintenance activities to protect the interests of the building occupants and the university.
- Monitoring employee exposure during small-scale abatement or maintenance activities.
- Performing periodic reassessments of known asbestos-containing materials in campus buildings and documenting conditions and findings.
- Maintaining current at least one person licensed/certified to conduct project monitoring and asbestos inspector duties.
- Participating in quarterly meetings scheduled by Environmental Health & Safety.
- Any other duties and responsibilities as defined by Memorandums of Understanding as agreed upon between departments.
Departmental Safety Representatives who coordinate or perform asbestos-related activities include:
- Gabe Lineberry for NI&S employees performing work tasks in various buildings on campus.
- Jonathan Spence for Division of Student Affairs buildings on campus.
- Mark Nester for buildings covered by the Division of Campus Planning, Infrastructure, and Facilities on campus.
- Robin Miller for all other buildings on campus that do not fall under one of the above.
Departmental personnel performing asbestos-related activities shall be under the supervision of a currently trained Asbestos Supervisor. The Asbestos Supervisor shall meet the definition of a Competent Person per OSHA, and shall ensure:
- Employees performing custodial, maintenance, or small-scale, short-duration repair activities have been adequately trained to the appropriate level.
- Work activities are conducted in a safe and healthy manner consistent with training and applicable regulations.
- Personal protective equipment is appropriate, available, and worn by employees engaged in asbestos activities.
Preventative maintenance and custodial staff should coordinate with their Departmental Safety Representative to assure they are aware of the location of all suspect and known asbestos-containing materials in the buildings for which they work in.
- Employees involved in work activities that may accidentally disturb asbestos-containing materials shall receive awareness level training from Environmental Health & Safety annually.
- Employees involved in asbestos repair or abatement activities shall maintain current the appropriate level of training/certification - Operations and Maintenance or Asbestos Worker/Supervisor.
Additional training or services may include, but is not limited to:
- Respiratory protection;
- Confined space entry;
- Personal Protective Equipment;
- Hazard Communication Right-to-Know; and/or
- Electrical Awareness.
Environmental Health & Safety will provide technical support, employee exposure investigations, and oversight for this program; however, involvement by Environmental Health & Safety does not relieve the departments, supervisors, or contractors of their individual responsibilities. Environmental Health & Safety responsibilities for this program include:
- Developing, implementing, and administering the Asbestos Operations and Maintenance Program, including delineation of responsibilities and standardized work procedures.
- Providing awareness level training to custodial and maintenance personnel annually, and maintaining centralized training records.
- Providing respiratory protection training and fit-testing to employees.
- Serving as a technical resource for program application on campus.
- Robin Miller, 540-231-2341
- Zachary Adams, 540-231-5985
- Conducting periodic audits and inspections of those departments performing asbestos-related activities to program requirements.
- Responding to potential personnel exposure incidents and campus complaints as reported by the responsible departmental safety representative and/or project manager.
- Retaining asbestos historical data/records and providing access to information to departments and building occupants.
- Maintain an active list of abatement priorities based upon information gathered during the periodic reassessments of asbestos-containing materials
- Providing medical surveillance services for all employees involved in asbestos-related work, including chest X-rays. Issue notification letters when exposures occur.
- Assisting Real Estate Management with the preparation of disclosures and other legal documents for leased properties.
- Scheduling quarterly meetings with departmental safety representatives to coordinate requirements of this program.
In accordance with 18VAC15-20-10, an Asbestos Contractor's License is required for firms that contract with another person, for compensation, to carry out an asbestos abatement project that exceeds 10 linear or 10 square feet. Contractors must comply with all local, state, and federal safety requirements, and must assure that all employees performing work on Virginia Tech property have been trained as an Asbestos Worker, and are provided appropriate personal protective equipment.
Multi-employer worksite rules also apply to asbestos projects. In accordance with 29 CFR 1926.1101(d):
- Employers performing work requiring the establishment of a regulated area (Class I, II, or III work), shall inform other employees on the site of:
- The nature of the work with asbestos-containing materials or presumed asbestos-containing materials.
- The existence of and requirements pertaining to regulated areas.
- Measures are taken to ensure that employees of other employers are not exposed to asbestos.
- Asbestos hazards shall be abated by the contractor who created or controls the source of the asbestos contamination.
- For example, if there is a significant breach of an enclosure containing Class I work, the employer responsible for erecting the enclosure shall repair the breach immediately.
- All employers of employees exposed to asbestos hazards shall comply with applicable safety measures to protect their employees.
- For example, if employees working immediately adjacent to a Class I asbestos job are exposed to asbestos due to the inadequate containment of the job, their employer shall remove the employees from the area until the enclosure breach is repaired.
- All employers of employees working adjacent to regulated areas (Class I, II, or III work) established by another employer on a multi-employer worksite shall take steps on a daily basis to ascertain the integrity of the enclosure and/or the effectiveness of the control method relied on by the asbestos contractor to assure that asbestos fibers do not migrate to such adjacent areas.
- All general contractors on a construction project which includes asbestos work covered by 29 CFR 1926.1101 shall be deemed to exercise general supervisory authority over the work even though the general contractor is not qualified to serve as the Asbestos Competent Person. As supervisor of the entire project, the general contractor shall ascertain whether the asbestos contractor is in compliance with OSHA requirements, and shall require the contractor to come into compliance, when necessary.
Contractor responsibilities for conducting asbestos work in Virginia are detailed 18VAC15-20-451.
The Safety Requirements for Contractors and Subcontractors program provides additional information for contractors on campus.
OSHA requires employees who may be exposed to fiber levels at or above the Permissible Exposure Limit (PEL) of 0.1 fibers per cubic centimeter as an 8-hour Time-Weighted Average (TWA) and/or the Excursion Limit of 1.0 f/cc as a 30-minute TWA participate in a worker training program. The extent of the training is determined by the type of work the employee performs. Asbestos-related training includes:
Asbestos Awareness (2 hours)
All maintenance and custodial staff who perform duties that contact but do not intentionally disturb ACM (OSHA Class IV work) shall receive Asbestos Awareness training on an annual basis. Such training shall be consistent with EPA requirements in 40 CFR 763.92(a)(1). This training is provided by Environmental Health & Safety.
Asbestos Operations & Maintenance Worker (16 hours)
Maintenance and custodial staff involved in general maintenance and asbestos-containing materials repair tasks must receive 16 hours of Operations and Maintenance training (comprised of 14 hours of specialized training and 2 hours of awareness training).
Asbestos Abatement Worker (32 hours)
Employees who perform asbestos abatement activities must be trained as an asbestos worker. This work involves direct, intentional contact with asbestos-containing materials. Training for an Asbestos Worker must be conducted by an EPA/AHERA or DPOR board-approved asbestos training program. Initial training is at least 32 hours and refresher training is 8 hours.
All personnel required to wear respiratory protection or that perform minor repair or maintenance work involving asbestos materials shall receive training on respiratory protection. The requirements of the Respiratory Protection and Medical Surveillance Programs may be obtained by contacting Environmental Health & Safety at 540-231-2509.
Asbestos Inspector (24 hours)
Training for an Asbestos Inspector must be conducted by an EPA/AHERA or DPOR board-approved asbestos training program. Initial training is at least 24 hours and refresher training is 4 hours.
Asbestos Supervisor (40 hours)
Training for an Asbestos Supervisor must be conducted by an EPA/AHERA or DPOR board-approved asbestos training program. Initial training is at least 40 hours and refresher training is 8 hours. OSHA defines a "competent person" as one who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure, and who has the authority to take prompt corrective measures to eliminate them. For Class I and II asbestos abatement work, the competent person must also be trained to the Asbestos Supervisor level. For Class III and IV work, the competent person must be trained to the maintenance and custodial staff level.
Asbestos Project Monitor (40 hours)
In accordance with the Department of General Services, "Construction and Professional Services Manual", asbestos abatement project specifications shall be followed by using a Virginia licensed or properly certified asbestos Project Monitor to conduct air monitoring throughout the duration of the abatement project and for final clearance. No asbestos materials are to be removed without the Asbestos Project Monitor being onsite. Training for an Asbestos Project Monitor must be conducted by an EPA/AHERA or DPOR board-approved asbestos training program. Initial training is at least 40 hours and refresher training is 8 hours.
Asbestos Management Planner (16 hours)
In accordance with the Department of General Services, "Construction and Professional Services Manual," a Virginia licensed asbestos Management Planner shall prepare or update the Asbestos Management Plan in accordance with the Code of Virginia. Training for an Asbestos Management Planner must be conducted by an EPA/AHERA or DPOR board-approved asbestos training program. Initial training is at least 16 hours and refresher training is 4 hours.
Asbestos Project Designer (24 hours)
In accordance with the Department of General Services, "Construction and Professional Services Manual," if asbestos-containing material is found, a Virginia licensed or properly certified asbestos project designer, in concert with the architect/engineer, shall prepare asbestos abatement project design specifications. Training for an asbestos project designer must be conducted by an EPA/AHERA or DPOR board-approved asbestos training program. Initial training is at least 24 hours and refresher training is 8 hours.
Written notification of any asbestos project greater than 10 linear or 10 square feet shall be made to VDOLI by the licensed asbestos abatement contractor at least 20 calendar days prior to the commencement of each asbestos project per Virginia Labor Law 40.1-51.20. Notifications are also required for all demolition projects, regardless of whether asbestos-containing material is present in the structure or not.
Under Virginia regulations, 16VAC25-20-30, notification shall be made to VDOLI by the licensed asbestos abatement contractor on the "Asbestos Demolition/Removal Notification Form Permit Application." Notifications should be sent by facsimile for projects that do not require a fee or projects paid by credit card, or they may be sent certified mail or hand-delivered, to the following and shall be postmarked or made 20 days before the beginning of any asbestos project to the address below. The permit fee shall be submitted with the notification.
VDOLI shall issue a permit to the contractor within 7 working days of the receipt of a completed notification form and permit fee. The permit, or a copy of the permit, shall be kept on-site during work on the project.
Amended notifications shall comply with 16VAC25-20-30, Section H. VDOLI must be notified prior to any cancellation and must comply with 16VAC25-20-30, Section I.
A separate notification to the EPA is no longer required as of December 22, 2021 for asbestos projects that are at least 160 square feet, 260 linear feet, or 35 cubic feet, or for demolition projects. Notification to the state/local authority (i.e. VDOLI) is all that is necessary.
A notification is not required for non-friable asbestos-containing roofing, flooring, and siding materials which when installed, encapsulated, or removed, do not become friable. If the material is in good shape and removed using OSHA's compliant work practices, then the notification is not generally required.
Note: If the material is not in good shape, the matrix has deteriorated, or mechanical means are used to remove the material, resulting in more than incidental breakage, then the notification is required. Activities such as grinding, mechanical chipping, sawing, or drilling can make the asbestos-containing material friable and would require notification.
Notification is not required for demolition of residential structures which do not meet the NESHAPS definition of facility.
Notification of fewer than 20 days may be allowed in case of an emergency involving the protection of life, health, or property. Notification and permit fee shall be submitted within 5 working days after the start of the emergency abatement. A description of the emergency situation shall be included when filing an emergency notification. Examples of emergencies include, but is not limited to:
- Leaking or ruptured pipes;
- Accidentally damaged or fallen asbestos that could expose non-asbestos workers or the public; or
- Unplanned mechanical outages or repairs essential to a work process that requires asbestos removal and could only be removed safely during the mechanical outage.
Bulk sample data
Historical building sampling data is kept in Access databases (by building). Bulk samples collected since 2002 have been kept by the designated safety representative in hard copy or electronic format. Beginning Jan. 1, 2017, all new bulk samples shall be entered into the historical Access databases. Designated safety representatives should have a plan for adding samples taken between 2002 and 2017 into the system in a timely manner. The Access databases shall be maintained by Environmental Health & Safety and made accessible to all necessary parties via Sharepoint (or other appropriate means).
Information regarding asbestos for renovation or demolition projects shall be provided by the designated safety representative to the respective project manager upon request. This information shall be provided in writing, and in accordance with state and federal requirements. Asbestos Inspection Reports shall be provided to the project manager and contractor prior to the start of abatement activities.
For leased properties, third-party sampling to identify asbestos-containing material is typically performed for construction and renovation projects. Environmental Health & Safety should be copied on the analysis and report.
General information regarding ACM in buildings can be obtained by contacting the respective DSR or Environmental Health & Safety.
Bulk sample collection
Unless presumed to contain asbestos, all suspect materials must be sampled prior to renovation, demolition, or maintenance projects where the suspect material has the potential to be disturbed. Suspect materials must be identified as asbestos-containing material or non-asbestos-containing material with the use of historic sampling data, written product certification, or sample collection and analysis. Historic sampling data should be supplemented with confirmatory sampling when in doubt.
Where the project will render previously inaccessible materials (e.g. located within a wall cavity or above a hard ceiling) accessible, it is recommended that every effort be made to access and sample suspect materials in advance of the project. Upon discovery of previously untested, inaccessible suspect materials, work must cease until further sampling is conducted. Locked rooms or spaces above drop ceiling tiles or below raised floors are not considered inaccessible and are required to be sampled.
Bulk samples collected for Virginia Tech shall be collected by a Virginia licensed/accredited asbestos inspector. Asbestos Inspectors shall conduct all asbestos inspections in accordance with 40 CFR 763.86 and are to include both building interior and exterior suspect materials, floor to roof, as applicable to the project scope. Each sample shall be assigned a unique identification number, using one of the following formats - work order number-sequential number (of samples), or building number-room number-sequential number (of samples). Examples: 2-123456-001, 22-123456-002 or 123-456-001, 123-456-002.
Per 18VAC15-20-459.1, Asbestos Inspectors shall conduct all asbestos inspections in accordance with 40 CFR 763.86. The asbestos inspector shall prepare a written report titled "Asbestos and Lead Inspection Report" for the purpose of communicating the presence or absence of asbestos-containing material, and shall contain, but is not limited to, the following:
- Date of inspection
- Asbestos inspector's name and license (or certification) number.
- Note: License (or certification) must be current on the day of the inspection.
- Location of any new samples taken (building, room number, or other references)
- Note: Per the Department of General Services, Construction and Professional Services Manual, locations must be marked on the drawings.
- Note: If information is from historical data, indicate such in the report. Historical data may include information from the asbestos database, CAD drawings, sample reports not included in the database, and abatement records.
- Location and type of all asbestos-containing material and assumed asbestos-containing material.
- Note: Include the type of asbestos and percentage (ex. Chrysotile, 5%).
- Assessment of all asbestos-containing material and presumed asbestos-containing material per 40 CFR 763.88.
- Significantly damaged.
- Copy of the laboratory report (for new samples) and/or historic sampling summary report maintained by Virginia Tech.
Revisions to Inspection Reports
Inspection reports are shared with many stakeholders involved in campus renovation and demolition projects. In order to ensure that all parties are aware of any revisions to an existing report, the following protocol must be used:
- Leave the original report as it is.
- Issue a new report that indicates a "Revision to Inspection Report Dated MM-DD-YYYY for W/O#" in the subject line of the report issued on the original date.
- The new report should reflect the current date in the dateline of the report.
- Attach the revised report to the original report, and
- Resend the package to all original recipients.
This will alleviate confusion on which report supersedes which, and will avoid potential issues with incorrect information being communicated to all parties involved. It also provides an audit trail if questions were to arise.
The project monitor acts as a buffer between the asbestos contractor and the building owner, ensuring that the contractor completes the project in accordance with the asbestos contract specifications and all applicable health and safety laws, as well as answering questions and providing guidance for the owner. It is the project monitor who represents the university's interests during abatement projects.
The human health and environment are primary concerns of the project monitor and the building owner. The project monitor must use his/her knowledge, experience, and expertise to assist the abatement contractor in making decisions unique to a particular project. The duties and functions of a project monitor per 18VAC15-20-455 include, but are not limited to,
- Observing and monitoring the activities of an asbestos abatement contractor on asbestos projects to determine whether proper work practices are used, and compliance with all applicable asbestos laws and regulations are maintained;
- Collecting environmental air samples during the asbestos project;
- Performing visual inspections of the work area; and
- Granting final air clearance upon completion of the asbestos project.
In accordance with 18VAC15-20-455.1, a project monitor is required on asbestos abatement projects where performed in buildings that are occupied, or intended to be occupied upon completion of a project exceeding 260 linear feet or 160 square feet or 35 cubic feet of asbestos-containing material or whenever the building or property owner deems it necessary to monitor asbestos project. Communication is extremely important in all phases of the project, especially in occupied buildings.
Virginia Tech asbestos project monitors shall:
- Perform duties and functions established by 18VAC15-20-455 as listed above.
- Inspect, smoke test, and approve all containments and glove bags prior to the removal of any asbestos materials to ensure the integrity of the containment is maintained.
- If the integrity of the containment is not properly maintained, follow the protocols listed in the Asbestos Disturbances section of this page.
- Ensure training certifications/licenses, medical exams, and fit-testing records are current for all onsite asbestos contractor personnel daily. This documentation shall be available upon request for the duration of the project.
- Final documentation shall be submitted to the project manager (or designee) and retained with the project files.
- Conduct inspections of the contractor's work practices and of the containment at least daily.
- Documentation shall be submitted to the Project Manager and retained with the project files.
- Be present on the job site each day that response actions are being conducted or in accordance with the owner-approved contractual agreement.
- Maintain a daily log of all work performed, including but not limited to, inspection reports, air sampling data, type of work performed by the contractor, problems encountered, and corrective actions are taken.
- Documentation shall be submitted to the project manager and retained with the project files.
- Perform a final inspection with the contractor at the conclusion of the project for visible debris prior to encapsulation and final clearance air monitoring.
- Documentation shall be submitted to the project manager and retained with the project files.
- Perform clearance air sampling on all abatement projects.
- Documentation shall be submitted to the Project Manager and retained with the project files.
- Perform final teardown inspection after clearance air monitoring to ensure no visible debris is left after teardown of containment, and that the abatement contractor has left the area in satisfactory condition.
Deviations from federal, state, or local regulations, or from the contract, should be brought to the contractor's attention for correction. If the contractor continues to deviate from acceptable work practices or procedures, then a decision as to the course of action to be taken must be made by the owner, the project monitor, and other stakeholders collectively. If the project monitor's judgment is overruled under circumstances when the safety, health, property and welfare of the public are endangered, the project monitor shall immediately stop the work and report his concerns to the designated safety representative, Environmental Health & Safety, and other appropriate authorities if the situation is not resolved. The project monitor shall take such action only when his/her authority to correct a problem has been ignored or overruled.
Surveillance of "friable" ACM to note, assess, and document any changes in the ACM's condition shall be performed on a periodic basis. This includes a visual and physical re-inspection of all ACM. Conditions shall be documented. Photos of reassessments can help determine the degree deterioration over time and likelihood of future fiber release so that actions can be taken in a timely manner. Settled dust can also be examined for the accumulation of asbestos fibers. Positive results may indicate the need for special cleaning of the affected area, or other appropriate response actions to mitigate the condition.
Departmental Safety Representatives (DSR) shall maintain a schedule for periodic reassessment of friable ACM, and any change in material condition shall be noted during this inspection. Assessments shall be entered into the Access databases. EHS and the DSRs shall develop a response plan for deteriorating conditions.
The Asbestos Inspector (or DSR as applicable) is responsible for:
- Determining whether ACM is present in a building,
- Investigating records for ACM
- Inspecting the building for suspect materials
- Sampling and analyzing suspect materials for asbestos
- Assessing the physical characteristics of that ACM and the building.
- Damaged or significantly damaged TSI ACM
- Damaged friable surfacing ACM
- Significantly damaged friable surfacing ACM
- Damaged or significantly damaged friable miscellaneous ACM
- ACM with potential for damage
- ACM with potential for significant damage
- Any remaining friable ACM or friable suspect ACM
The Management Planner then uses the information gathered by the Asbestos Inspector to estimate the degree of current or potential hazard posed by the ACM, and develops an Operations and Maintenance (O & M) Plan for managing the ACM. The Management Planner will then:
- Employ a systematic approach to determine the hazard posed by the ACM, and
- Work with the Designated Safety Representative (DSR) to evaluate and select the proper control/reponse action:
- Operations and Maintenance (O & M)
The selection of a response action by the Management Planner should be based upon a number of evaluating factors, but most importantly the health and safety of the building occupants, and includs:
- Hazard assessment (i.e. the degree of hazard posed by the ACM in the building)
- Costs (initial and long-term), and
- Life of the facility.
Note: The responsibility for paying for any response actions will be Division of Student Affairs or Facilities Services.
The Asbestos and Lead Inspection Reports shall be made available to EHS for consideration in the O & M Plan for the building. Sufficient information must be provided on these reports in order to make a determination on control/response actions.
Accidental Disturbance of Suspect ACM
OSHA defines a "disturbance" as an activity involving asbestos-containing material or presumed asbestos-containing material that disrupts the matrix, crumbles or pulverizes, or generates visible debris. Suspect asbestos-containing materials may be unintentionally disturbed by building occupants, custodial staff, or contractor personnel. A change in material condition (i.e. water damage, deterioration, and air erosion) may cause asbestos-containing material to physically break down and separate from its substrate (ceiling, walls, piping, flooring, etc.). Asbestos fibers may also be accidentally released when a breach occurs in a regulated containment area where abatement activities are taking place.
As a result of conditions where there is a potential for airborne asbestos fiber release, the is a risk of inhalation of fibers by building occupants in the immediate area. Fiber release episodes are categorized as "minor" or "major." Whether the disturbance is intentional, unintentional, minor, or major, the debris must be promptly cleaned up by asbestos-trained personnel only to minimize the further distribution of the debris into the environment.
- Minor fiber release episodes occur when a disturbance of asbestos-containing material causes debris less than 3 square feet or 3 linear feet.
- This debris can be cleaned up by departmental personnel who have Operations and Maintenance training.
- Major fiber release episodes occur when a disturbance of asbestos-containing material causes debris greater than 3 square feet or 3 linear feet.
- This debris may require cleanup by personnel certified as asbestos workers.
In accordance with 29 CFR 1926.1101(d)(2), asbestos hazards on a multi-employer worksite shall be abated by the contractor who created or controls the source of the asbestos contamination. For example, if there is a significant breach of an enclosure containing Class I work, the employer responsible for erecting the enclosure shall repair the breach immediately. All employers of employees exposed to asbestos hazards shall comply with applicable protective measures to protect their employees. This may include either removing their employees from the area until the enclosure breach is repaired, or perform an Initial Exposure Assessment in accordance with 29 CFR 1926.1101(f)(2).
If you believe that a minor or major fiber release episode has occurred in your work area, the following procedures should be taken to minimize the spread of asbestos fibers:
- Direct all occupants in adjacent areas to leave the affected area. Notify your immediate supervisor. Secure the area by locking all access points to space. It would be prudent to post a sign indicating "Access to space has been temporarily restricted." If the debris is in a public space and the area cannot be secured, use alternate means to isolate the immediate area, such as rope, caution tape, wet-floor A-frame signs, etc. to prevent pedestrian traffic in the area. Provide a building contact on the warning sign, if possible.
- For cleanup and response actions, notify the departmental safety representative at one of the customer service lines listed below:
- Division of Campus Planning, Infrastructure, and Facilities at 540-231-4300 for academic and administration buildings, or renovation projects.
- Division of Student Affairs at 540-231-1111 for residential and dining buildings, or renovation projects.
- After-hours incidents should be reported to Virginia Tech Police at 540-231-6411.
- Notify Environmental Health & Safety at 540-231-3600 for all other locations, or when there is a potential employee or general public exposure.
- Any personnel expressing concerns about potential exposure to friable asbestos-containing material should complete an Employer’s Accident Report.
- Environmental Health & Safety will determine what area air monitoring will need to be performed.
- Environmental Health & Safetywill assist in determining what response actions need to be taken, if necessary.
If the debris is considered non-friable, such as floor tile in good condition, there is little chance of fibers being released; however, the coordination of prompt cleanup should still be conducted immediately by the appropriate departmental safety coordinator
The responsible departmental safety coordinator responding to the disturbance shall maintain documentation regarding the event, and shall notify Environmental Health & Safety immediately (if not already notified). Depending on the severity of the fiber release, asbestos abatement contractors may be needed to develop a strategy for conducting cleanup operations. The following information must be included:
- Date of the event.
- Location of the event (building and room number).
- Type of asbestos-containing material that was disturbed (friable, non-friable, floor tile, pipe insulation, etc.).
- Potential cause of the disturbance (water damage, accidental contact, deterioration, etc.).
- Actions taken to prevent the spread of fibers (cover/seal air ducts, shut off HVAC in area, etc.).
- Names and contact information of persons concerned about possible exposure to asbestos fibers
- Note: OSHA defines employee exposure as the exposure to airborne asbestos that would occur if the employee were not using respiratory protection.
- Names of departmental workers or contractor personnel who will be performing cleanup activities.
- Date the cleanup was completed.
- Quantity of properly labeled bags used to collect the debris
- Means of disposal of accumulated waste and appropriate waste manifest, if applicable.
The departmental safety coordinator is also responsible for notifying appropriate departmental management to ensure properly asbestos-trained personnel conduct the cleanup of asbestos-containing material debris. Any area having a fiber release episode involving the disturbance of friable asbestos-containing material shall be cleared by an accredited Project Monitor using either Phase Contrast Microscopy (PCM) or Transmission Electron Microscopy (TEM) air sampling.
Abatement Project Documentation
Notifications to regulatory agencies shall be in compliance with the requirements listed in the notification requirements section of this page.
In accordance with the Construction and Professional Services Manual (CPSM), if asbestos-containing materials (ACM) are found, the Owner shall have a Virginia licensed or properly certified asbestos project designer in concert with the A/E prepare asbestos abatement project design specifications. This provides assurance that the work will be performed in accordance with state and federal requirements.
The written plan includes all work procedures that will be used in the repair, removal, and/or demolition of asbestos-containing material shall be submitted to the Owner for review and approval at least 10 working days in advance of the first project performed under the "Hazardous Material Abatement Services" contract. Plans may be pre-submitted to the contract review committee during the pre-bid process. Environmental Health & Safety shall review the plans and provide comments, as necessary, prior to the contract being awarded.
Within 45 days of completion of each asbestos abatement project, the contractor shall submit to the university (per the contract) a final report consisting of the following:
- Start and finish date of work performed.
- Location of work - building and room number.
- Copies of current licenses for contractor personnel on site:
- Asbestos abatement contractor
- Asbestos supervisor
- Asbestos workers
- Asbestos project monitor (if other than Division of Campus Planning, Infrastructure, and Facilities)
- Verification/copy of each asbestos worker's medical examination and respirator fit-test record. (No social security numbers).
- Type and quantities of asbestos-containing material removed.
- Copies of all state and federal notifications (if applicable) and permits pertaining to the particular project.
- Results of all employee exposure monitoring performed.
- Written log of filter change-out.
- Landfill documentation and waste manifests.
- Copies of Supervisor's Daily Log, including worker and visitor sign-in sheets (written legibly).
- Any other documentation pertinent to the project.
- Safety Data Sheets
- Respiratory Protection Program
- Manufacturer's certifications on vacuums, ventilation equipment, and other equipment required to contain airborne fibers conform to ANSI Z.2-1979.
This documentation shall be retained with the project files (preferably electronically) and shall be made available to Environmental Health & Safety or regulatory authorities upon request.
Note: Documentation submitted shall identify the project number related to where the abatement occurred.
Abatement: Work that involves the physical removal of asbestos. Work must be performed by trained personnel under the supervision of a competent person as defined by the Environmental Protection Agency (EPA).
Accredited: Individuals have successfully completed a training program approved by the Virginia Board for Asbestos, Lead, and Home Inspectors to engage in asbestos abatement.
ACM (Asbestos-containing material): Any material containing more than 1.0% asbestos by area as determined using Polarized Light Microscopy. Examples include: TSI and surfacing materials in buildings constructed no later than 1980, asphalt and vinyl flooring material installed no later than 1980, any other materials the building owner has knowledge of, or should have known it to be, asbestos-containing.
Activity: Per 16VAC25-20, from the setup of negative air containment through the breakdown of that containment. Work within a single structure or building shall be considered as one "activity" so long as such work is not interrupted except for weekends, holidays, or delays due to inclement weather. Where containment is not required, all work within a single structure or building shall be considered as one "activity."
Aggressive final clearance air sampling: The act of aggressively agitating the air in an asbestos removal area using fans and/or a leaf blower while final clearance air samples are being taken.
Air plenum: Any space used to convey air in a building or structure. The space above a suspended ceiling is often used as a plenum.
Amended water: Water that has been mixed (amended) with a chemical wetting agent, or surfactant, to improve penetration and wetting ability.
Asbestos: A generic name given to a number of naturally occurring minerals that possess a unique crystalline structure and are separable into fibers. Asbestos includes the asbestiform varieties of chrysotile, crocidolite, and amosite.
Asbestos project: An activity involving job set-up for containment, removal, enclosure, encasement, renovation, repair, demolition, construction, or alteration of asbestos-containing material.
Asbestos project supervisor: A person with the training and experience required by the Department of Professional and Occupational Regulations (DPOR) for licensing as an asbestos supervisor, and who meets the qualifications of "competent person" as established by 40 CFR 761. An asbestos project supervisor must be present on all asbestos projects which involve the removal of friable asbestos-containing materials.
CFR: Code of Federal Regulations.
Class I Asbestos Work: Activities involving the removal of TSI and surfacing asbestos-containing materials and presumed asbestos-containing materials.
Class II Asbestos Work: Activities involving the removal of asbestos-containing material which is not TSI or surfacing material, including but not limited to, the removal of asbestos-containing material wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.
Class III Asbestos Work: Repair and maintenance operations where asbestos-containing material is likely to be disturbed.
Class IV Asbestos Work: Maintenance and custodial activities during which employees contact asbestos-containing material and presumed asbestos-containing material, and activities to clean up waste and debris containing asbestos-containing material and presumed asbestos-containing material.
Control measure: A measure used to control the generation of airborne asbestos fibers until a permanent solution can be implemented. These measures include encapsulation, repair, encasement and enclosure.
Damaged ACM: flaking, blistering, crumbling, water damage, scrapes, gouges, mars or other signs of physical injury of the asbestos-containing building material.
Delamination: Physical separation of one layer from another.
Demolition: Wrecking or taking out of any load supporting structural member and any related removing or stripping of friable asbestos material.
Disturbance: Activities that disrupt the matrix of asbestos-containing material or presumed asbestos-containing material, crumble or pulverize asbestos-containing material or presumed asbestos-containing material, or generate visible debris from asbestos-containing material or presumed asbestos-containing material. Disturbance includes cutting away small amounts of asbestos-containing material and presumed asbestos-containing material, no greater than the amount which can be contained in one standard sized glove bag or waste bag in order to access a building component. In the event the amount of asbestos-containing material or presumed asbestos-containing material disturbed exceeds that which can be contained in one glove/waste bag, it shall not exceed 60 inches in lenght and width.
DOLI: Department of Labor and Industry.
DOPR: Department of Professional and Occupational Regulation.
Employee exposure: That exposure to airborne asbestos that would occur if the employee were not using respiratory protective equipment.
Encapsulation: The application of a sealant over the surface of the asbestos-containing material to prevent the release of asbestos fibers.
Enclosure: The construction or installation over or around the asbestos-containing material of any solid or flexible covering, which will not deteriorate or decompose for a period of time, so as to conceal the asbestos-containing material, contain asbestos-containing material fibers, and render the asbestos-containing material inaccessible.
EPA: Environmental Protection Agency.
Excursion limit: The employer shall ensure that no employee is exposed to an airborne asbestos fiber concentration in excess of 1.0 f/cc of air as averaged over a sampling period of thirty (30) minutes.
Facility: NESHAPS defines it as "any institutional, commercial, public, industrial, or residential structure, installation, or building (including any structure, installation, or building containing condominiums or individual dwelling units operated as a residential cooperative, but excluding residential buildings having four or fewer dwelling units); any ship; and any active or inactive waste disposal site. For purposes of this definition, any building, structure, or installation that contains a loft used as a dwelling is not considered a residential structure, installation, or building."
Fiber release episode: The unintentional disturbance of asbestos-containing material resulting either from accidental contact or that is a result of other factors, such as pipe leaks or roof leaks, where the asbestos-containing material has been physically dislodged and the potential for asbestos fibers to have become airborne as a result of this disturbance is high.
Friable: Material which is capable of being crumbled, pulverized or reduced to powder by hand pressure when dry, or which under normal use or maintenance emits or can be expected to emit fibers into the air.
Functional space: a room, group of rooms, or homogeneous area (including crawl spaces or the space between a dropped ceiling and the floor or roof deck above), such as classroom(s), a cafeteria, gymnasium, hallway(s), sesignated by a person accredited to prepare management plans, design abatement projects, or conduct response actions.
Glovebag: A polyethylene or polyvinyl chloride bag-like enclosure affixed around an asbestos-containing source (most often thermal system insulation) so that the material may be removed while minimizing release of airborne fibers to the surrounding atmosphere.
HEPA: High Efficiency Particulate Air filtered equipment must be capable of trapping and retaining 99.97% of all particles larger than 0.3 microns.
Homogeneous material: Building materials of the same age, physical appearance, texture and color, used for a similar application. A separate homogenous sampling area shall be defined for each type of homogenous material on each floor of a building.
Homogeneous area: an area of surfacing material, thermal system insulation material, or miscellaneous material that is uniform in color and texture. At VT, homogeneous areas are defined by building and floor in most cases.
Industrial hygienist: A professional qualified by education, training and experience to recognize, evaluate, and develop control measures for occupational health hazards.
Intact: The asbestos-containing material has not crumbled, been pulverized, or otherwise deteriorated so that asbestos is no longer likely to be bound to its matrix.
Licensed: An authorization issued by the Virginia Department of Professional and Occupational Regulation (DPOR) permitting a person to enter into contracts to perform an asbestos abatement project.
Medical surveillance: A periodic comprehensive review of a worker's health status.
Miscellaneous asbestos-containing material: Interior asbestos-containing material that is not surfacing or thermal system insulation, such as some floor tile, ceiling tile, wire insulation, asbestos cement products and so forth.
NESHAP: National Emission Standard for Hazardous Air Pollutants - EPA Rules under the Clean Air Act, 40 CFR Subpart M, Part 61.
NIOSH: National Institute for Occupational Safety and Health. Primary functions are to conduct research, issue technical information, and test and certify respirators.
Non-friable: Cannot be crumbled, pulverized, or reduced to powder by hand pressure when dry.
Operations and Maintenance Program: Specific procedures and practices developed for the interim control of asbestos-containing materials in buildings until it is removed.
OSHA: Occupational Safety and Health Administration, administered in Virginia by the Department of Labor and Industry (DLI).
PACM (presumed asbestos containing material): TSI and surfacing material found in buildings constructed no later than 1980. The designation of a presumed asbestos-containing material may be rebutted in accordance with 1926.1001(k)(5).
PEL (Permissible Exposure Limit): The highest allowable level of exposure to airborne asbestos fibers that an employee may have, without using respiratory protection, as stated by the Occupational Safety and Health Administration (OSHA). The employer shall ensure that no employee is exposed to an airborne asbestos fiber concentration in excess of 0.1 f/cc of air as averaged over an eight-hour period (i.e. time-weighted average). The concentration of 0.1 f/cc is defined as the PEL/TWA for asbestos.
Personal air samples: An air sample taken with a sampling pump directly attached to the worker with the collecting filter and cassette placed in the worker's breathing zone. These samples are required by the OSHA asbestos standards and the EPA Worker Protection Rule.
Personal Protective Equipment: Any material or device worn to protect a worker from exposure to, or contact with, any harmful material or force. PPE should be used only if engineering or administrative controls are insufficient to protect against a hazard.
RACM (regulated asbestos containing material): A term specific to NESHAPS where asbestos-containing material is friable, had become friable, will be (or has been) subjected to sanding, grinding, cutting, or abrading, or has a high probability of becoming friable.
Regulated area: An area established by the employer to demarcate areas where Class I, II, and III asbestos work is conducted, and any adjoining area where debris and waste from such asbestos work accumulate; and a work area within which airborne concentrations of asbestos exceed, or there is a reasonable possibility they may exceed, the permissible exposure limit (PEL). The regulated area shall be demarcated in any manner that minimizes the number of persons within the area and protects persons outside the area from exposure to airborne asbestos. Critical barriers or negative pressure enclosures may demarcate the regulated area per 29 CFR 1926.1101(e)(2).
Renovation: Altering, in any way, one or more facility components.
Repair: Returning damaged asbestos-containing material to an undamaged condition or to an intact state so as to prevent fiber release.
Respiratory protection: A device worn to either purify the air, or that provides clean air from another source to the wearer. All respirator users must be enrolled in Virginia Tech's Respiratory Protection Program, and must have received appropriate training on respirator use, care, and maintenance.
Response action: Repair of damage or deterioration to asbestos materials, or the removal of asbestos or asbestos debris, undertaken to alleviate a hazard to building occupants.
Small-scale, short-duration asbestos projects: Small-scale, short-duration (SS/SD) renovation or maintenance activities include, but are not limited to: removal of asbestos-containing material from pipes; replacement of an asbestos-containing material gasket on a valve; installation or removal of small sections of drywall; installation or electrical conduit proximate to, or through, asbestos-containing material; or the removal of small sections of ceiling tile, friable (e.g. damaged) flooring, or unbonded asbestos-containing material flooring where the work is non-repetitive, and can be completed within an eight (8) hour work shift. The purpose of SS/SD projects is maintenance, repair or renovation where the removal of asbestos-containing material is not the primary goal of the job.
Surfacing asbestos-containing material: Asbestos-containing material sprayed or troweled on surfaces, such as some acoustical plasters, hard wall or ceiling plasters, and fire-proofing.
TSI - Thermal System Insulation: Asbestos-containing material applied to pipes, fittings, boilers, breeching, tanks, ducts, or other structural components to prevent heat loss or gain or water condensation.
TWA - Time-Weighted Average: In air sampling, this refers to the average air concentration of contaminants during a particular sampling period (typically 8 hours).
Frequently Asked Questions
Is training mandatory? If so, when? Yes. Persons who perform maintenance, renovation, or custodial operations, and persons who work around asbestos must attend this training.
Class length: 1 hour.
Available online: Yes.
When is refresher training required? Annually.
Please see the class schedule for more information.
Robin McCall-Miller, Occupational Safety Program Manager