Asbestos Management Plan

1.0 Purpose

The University of Delaware is committed to provide its employees, subcontractors, students and visitors with a safe environment, and to ensure that safe work practices are followed. This commitment includes reducing occupational as well as general population exposure to asbestos. The asbestos management plan (AMP) will be reviewed and updated as needed by the University's Environmental Health & Safety Specialst.

2.0 Definitions

2.1 Asbestos- includes chrysotile, amosite, crocodilite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos and any of these minerals that have been chemically treated and/or altered.

2.2 Asbestos Containing Material- means any material containing more than one-percent asbestos.

2.3 Building/Facility Owner- means the University of Delaware.

2.4 Employee Exposure- means exposure to airborne asbestos that would occur if the employee were not using respiratory protection.

2.5 Fiber- means a particulate form of asbestos 5 micrometers or longer, with a length to diameter ratio of at least 3 to 1.

2.6 High-Efficiency Particulate Air (HEPA) Filter- means a filter capable of trapping and retaining at least 99.97 percent of 0.3-micrometer diameter mono-dispersed particulates.

2.7 Permissible Exposure Limit (PEL) -

1. Time Weighted Average (TWA)- The employer shall ensure that no employee is exposed to an airborne concentration of asbestos in excess of 0.1 fibers per cubic centimeter of air as an eight hour TWA.
2. Excursion Limit (EL)- The employer shall ensure that no employee is exposed to an airborne concentration of asbestos in excess of 1.0 fibers per cubic centimeter as averaged over a sampling period of thirty minutes.

2.8 Presumed Asbestos Containing Material (PACM)- means thermal system insulation, sprayed or troweled on surfacing material, and debris in buildings constructed before 1980 that are assumed to contain greater than one percent asbestos but has not been sampled or analyzed to verify or negate the presence of asbestos as defined by the OSHA standard.

2.9 Regulated Area- means areas established by the employer to demarcate areas where airborne concentrations of asbestos exceed or there is a reasonable possibility they may exceed, the permissible exposure limit.

2.10 Small Operations and Maintenance Activities- means any activity conducted by the University's in-house asbestos team that requires the abatement of less than 25 linear feet or 10 square feet of known or assumed ACM.

2.11 Surfacing Material- means material that is sprayed, troweled-on, or otherwise applied to surfaces (such as acoustical plaster on ceilings, fireproofing materials on structural members, or other materials for acoustical or fireproofing purposes).

2.12 Suspect Asbestos Containing Materials- means any material that may contain more than one- percent asbestos but has not been sampled and tested to determine its asbestos content.

2.13 Thermal System Insulation- means material applied to boilers, pipes fittings, tanks, breaching, ducts or other structural components to prevent heat loss or gain.

3.0 Personnel Covered Under the Asbestos Management Plan

3.1 Personnel to be covered under this plan will be identified by the Department of Environmental Health & Safety (DEHS). This information will be provided for their consideration. This will include but not be limited to custodians, skilled craftsmen, project and construction managers, outside contractors, or any other person that may come in contact with ACM on a routine basis.

4.0 Identification of ACM or ACM Hazards Prior To Renovation or Demolition Projects

4.1 Prior to the start of any scheduled or emergency renovation or demolition project, the project manager, construction manager or other person responsible for the project must determine if any suspect ACM may be disturbed during the operation.

4.2 If the University's project manager, construction manager or other responsible person cannot determine if suspect ACM will be disturbed during the operation, then the Environmental Health & Safety Specialist must be contacted to make the final determination.

4.3 If a determination has been made by the University's project manager, construction manager, or other responsible persons that suspect ACM will be disturbed, the University's Environmental Health & Safety Specialist must be notified to determine if bulk sampling of the suspect ACM or any other applicable action will be necessary.

4.4 To initiate an asbestos survey the project manager, construction manager or other responsible person will utilize the "Environmental Health & Safety Checklist" and submit the form to the Environmental Health & Safety Specialist for review.

4.5 Under no circumstances will any suspect ACM be disturbed without following the prescribed procedures as outlined above.

5.0 Identification of ACM or ACM Hazards for Small Scale Operation and Maintenance Activities

5.1 Prior to the start of any small scale operation and maintenance activity or emergency response activity, such as but not limited to, valve or pipe repair, computer cable installation above suspended ceiling, etc., a determination must be made if any suspect ACM will be disturbed.

5.2 This determination must be made by the person responsible for the operation. If the person responsible for the project cannot make the appropriate determination, the Environmental Health & Safety Specialist must be contacted.

5.3 If Asbestos containing materials are determined to exist, then the Environmental Health & Safety Specialist must be contacted.

5.4 Under no circumstances, will any suspect ACM be disturbed without following the prescribed procedures as outlined above.

6.0 Permissible Exposure Limit and Excursion Limit

6.1 The University's asbestos management plan is committed in trying to maintain asbestos exposures below the permissible exposure limit (PEL) of 0.1 fibers per cubic centimeter of air as averaged over an eight hour time weighted average and the excursion limit (EL) of 1.0 fibers per cubic centimeter of air as averaged over a 30 minute sampling period. Work practices, engineering controls, and personal protective equipment will be utilized to maintain asbestos airborne concentrations below the PEL and EL.

7.0 Exposure Monitoring

7.1 Exposure monitoring shall be performed on target groups of personnel who are potentially exposed to airborne asbestos fibers at or above the PEL or EL. This includes but is not limited to custodians, in-house asbestos abatement team, and any other target groups the Department of Environmental Health & Safety deemed appropriate. Air monitoring will be performed periodically to ensure airborne concentrations do not exceed the PEL or EL. If the air monitoring indicates statistically that the affected target group of personnel are below the PEL or EL, the Department of Environmental Health & Safety may advise to discontinue air monitoring for those groups. The Department of Environmental Health & Safety will reinstate air monitoring activities whenever there has been a change in work processes, engineering control equipment, personnel, or work practices, that may result in new or additional exposures to asbestos at or above the PEL or EL. If the PEL or EL is exceeded, then work practices, engineering controls will be re-evaluated by the Environmental Health & Safety Specialist. All exposure monitoring will be conducted by the Environmental Health & Safety Specialist, the University’s asbestos consultant or any other party the Environmental Health & Safety Specialist deems qualified.

7.2 Affected groups or their representatives may observe at any time the air monitoring activities. Affected personnel will receive the results of the test within 15 days. Any results above the PEL or EL will also include a written statement on corrective action incorporated to reduce airborne asbestos fibers below the PEL or EL.

7.3 Exposure monitoring will help identify personnel who need to be covered by the medical surveillance program as outlined in Section 8. of the AMP.

8.0 Medical Surveillance

8.1 The University will supply a medical surveillance program for the University's in-house abatement team. All medical exams will be provided free of charge to the employee and be performed by or under a licensed physician. The medical surveillance program will comply with the OSHA standards 29 CFR 1910.1001 and 1926.1101.

8.2 At a minimum, the exam will include medical and work history, a complete physical exam, with the emphasis on the respiratory system, the cardiovascular system, and the digestive tract; pulmonary function test; and respiratory disease standardized questionnaire as set forth in the OSHA standards 29 CFR 1910.1001 and 1926.1101.

8.3 Physical exams will be made available on a yearly basis, and chest roentgenogram will be performed as outlined in 29 CFR 1910.1001 and 1926.1101.

8.4 Upon termination of employment the employee will be required to complete a medical exam within thirty days before or after termination. This exam will be provided free of charge to the employee.

8.5 The University will provide a copy of the physician's written statement to the employee within 30 days of receipt.

8.6 All personal information received by the University will be held in strict confidence.

9.0 Recordkeeping of Employee Information

9.1 The University will keep accurate records of all exposure measurements taken to monitor employee exposure to asbestos. Records will be kept for 30 years.

9.2 The University will also maintain an accurate record for each employee subject to medical surveillance. These records will be maintained for the duration of employment plus 30 years.

9.3 The University will maintain all employee training records for one year beyond the last date of employment by the University.

9.4 The University will comply with the OSHA standards 29 CFR 1910.1001 and 1926.1101 concerning recordkeeping for employee information.

10.0 Recordkeeping of Asbestos Containing Materials Location

10.1 The Department of Environmental Health & Safety will maintain records about the presence, location, and quantity of ACM identified to date in each building.

10.2 The University community may access all records concerning ACM at any time. Coordination of such activities will be made through the Environmental Health & Safety Specialist.

11.0 Regulated Areas

11.1 The University will establish and set apart regulated areas wherever airborne concentrations of asbestos potentially exceed the PEL or EL. Only authorized personnel will be permitted to enter regulated areas. All personnel entering regulated areas will be required to wear appropriate respiratory protection. These types of areas include but are not limited to asbestos abatement projects, above suspended ceilings where asbestos fireproofing or plaster exists, crawlspaces where damaged ACM exists, or other areas that the Department of Environmental Health & Safety has deemed a regulated area.

11.2 No smoking, eating, drinking, chewing tobacco or gum, or applying cosmetics is permitted in regulated areas.

11.3 Warning signs must be posted at all areas where asbestos removal, encapsulation, or enclosure activities are in progress. The signage will conform to 29 CFR 1910.1001 and 1926.1101.

12.0 Communication of Hazards

12.1 Personnel engaged in housekeeping activities, operation and maintenance activities, or other activities that could potentially disturb ACM might be exposed to asbestos fibers. The University is committed to minimize personnel asbestos exposure through the following mandates:

1. In buildings constructed before 1980, personnel will treat thermal system insulation, sprayed or troweled on surfacing materials, and floor tile and linoleum as asbestos containing material, unless properly sampled and analyzed for asbestos content.
2. Inform and provide training for employees performing housekeeping activities or other activities that may contaminate the work area.
3. The University shall keep records of the presence, location, and quantity of ACM identified to date in each building.
4. Persons responsible for the oversight of demolition and renovation projects must communicate the location, presence, and quantity of ACM at each work site to all contractors prior to the start of work.
5. All building occupants will be notified concerning abatement activities prior to the start of any asbestos project. This activity can be accomplished through meetings or written correspondence.

13.0 Training

13.1 The Department of Environmental Health & Safety will provide training for all employees who are potentially exposed to asbestos fibers above the PEL or EL. Training will be provided on an annual basis or at the time of being hired. The training program will inform employees about ways in which they can safeguard their health.

13.2 The elements of the training course will include the health affects of asbestos; common types of ACM that are present at the University, locations of known ACM, signs of damage and deterioration of ACM; the proper response to fiber release episodes; and where the housekeeping requirements are located in 29 CFR 1910.1001.

13.3 All training provided at UD will be free of charge to the individuals covered under this plan.

14.0 Control Methods

14.1 To the extent feasible, engineering and work practice controls must be in place to reduce and maintain employee exposure at or below the PEL or EL. The following are a list of requirements established by the Department of Environmental Health & Safety.

1. Design, construct, install, and maintain local exhaust ventilation and dust collection systems according to the American National Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems, ANSI Z9.2-2006.
2. Provide local exhaust ventilation system for all hand operated and power operated tools such as saws, scorers, abrasive wheels, and drills those produce or release asbestos fibers.
3. Handle, mix, apply, remove, cut, score, or work asbestos in a wet state to prevent employee exposure.
4. Sanding of floors containing asbestos is prohibited.
5. Using compressed air to remove asbestos or materials that contain asbestos is prohibited.

15.0 Respiratory Protection

15.1 Respiratory protection is required in all areas that the PEL or EL may be exceeded. This includes but is not limited to; above suspended ceiling where ACM plaster or other damaged ACM exists, removal of ACM, drilling or cutting into ACM plaster walls, accessing crawlspaces with damaged ACM, etc.

15.2 Respirators will be equipped with High Efficiency Particulate Air (HEPA) filters for all asbestos related activities.

15.3 ALL personnel using respiratory protection will comply with the University's policy # 7-32 "Respiratory Protection" as well as OSHA CFR 1910.134 concerning respiratory protection.

16.0 Protective Clothing

16.1 Any employee or contractors exposed to airborne concentrations of asbestos that may exceed the PEL or EL are required to wear protective clothing, such as full body clothing, head coverings, gloves, and foot coverings. Eye protection is also required.

16.2 Asbestos contaminated work clothing will not be permitted to leave the work site. All contaminated work clothing will be disposed of as ACM waste.

17.0 Hygiene Facilities and Practices

17.1 All personnel that work in regulated areas are required to set up or have access to clean change rooms and shower facilities. All personnel will comply with CFR 1910.1001 and 1926.1101.

18.0 Housekeeping

18.1 All surfaces must be maintained as free as possible of accumulations of waste containing asbestos and/or asbestos dust. HEPA filtered vacuums or wet methods are the preferred choices for these activities. Compressed air will not be permitted for any housekeeping activities.

18.2 Only qualified and trained personnel, determined by the Department of Environmental Health & Safety will be permitted to clean asbestos waste or debris.

18.3 All ACM or PACM floor tile shall not be sanded for any reason. Low abrasion pads at speeds lower than 300 rpm and wet methods must be employed. If floors have a sufficient layer of wax, brushing or dry buffing is permitted.

19.0 Asbestos Waste and Storage

19.1 All asbestos waste generated at the University of Delaware will be disposed of at an EPA approved landfill designated by the Department of Environmental Health & Safety. All asbestos waste generated will be bagged and transported in accordance with all applicable State and Federal regulations.

19.2 All waste generated by the University's asbestos abatement team will be stored only at the University's storage facility designated for asbestos waste. There will be no exceptions.

20.0 Asbestos Abatement Activities

20.1 State of Delaware licensed asbestos workers or supervisors as defined by the Department of Natural Resources and Environmental Control shall conduct all removal, patch and repair, enclosure, encapsulation, or disturbance of ACM.

20.2 All asbestos abatement related activity will be completed in strict accordance with OSHA CFR 1926.1101, 1910.1001 and the State of Delaware asbestos regulations.

20.3 Any asbestos abatement contractor performing asbestos related tasks at the University must first be pre-approved by the Department of Environmental Health & Safety.

Questions regarding asbestos issues may be addressed to Ed Jackson or call 831-0690.