Asbestos Management Policy and Program

Table of Contents

ASBESTOS MANAGEMENT POLICY

ASBESTOS MANAGEMENT PROGRAM

I. INTRODUCTION

II. FEDERAL AND STATE REGULATIONS

III. ASBESTOS PROJECTS

A. ASBESTOS WORK PERFORMED BY OUTSIDE EMPLOYERS

B. IDENTIFICATION OF ASBESTOS

1. Building Assessments and Surveys

2. Sampling

3. Monitoring

C. NOTICE

1. Employee Notice

2. Discovery Notice

3. Regulatory Notice

D. LABELING AND SIGNAGE

1. Regulated Areas

2. Warning Labels

3. Installed ACM Labeling

4. Label and Sign Specifications

E. TRANSPORTATION AND DISPOSAL OF WASTE

IV. CUSTODIAL ACTIVITIES

V. ASBESTOS EMERGENCIES

VI. HEALTH AND SAFETY

A. TRAINING

B. PERSONAL PROTECTIVE EQUIPMENT

VII. GENERAL INFORMATION

GLOSSARY

ASBESTOS MANAGEMENT POLICY

It is the policy of Syracuse University to comply with the regulations of New York State, the federal Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) that pertain to asbestos in the work place and environment. All contracted and in-house asbestos work (removal, disposal or laboratory) will be approved and supervised by the University's Physical Plant Environmental Shop. All work activities involving the management of asbestos at the University must adhere to the guidelines set forth in the University's Asbestos Management Program and all applicable rules and regulations.

ASBESTOS MANAGEMENT PROGRAM

I. INTRODUCTION

This program is for the specific purpose of controlling and managing asbestos containing material (ACM) at Syracuse University. Employees of the University and designated supervisors of outside employees whose work may involve existing ACM on the Syracuse University Campus must be informed of the Asbestos Management Policy and the associated guidelines in the Asbestos Management Program prior to commencement of work. Outside Employers are required to follow the guidelines contained herein. Copies of the Policy and Program can be obtained from the Physical Plant Environmental Shop, Environmental Health Office (EHO) and the Office of Design and Construction.

II. FEDERAL AND STATE REGULATIONS

Federal, state, and local government regulations govern removal of ACM within New York State. OSHA Standard 29 CFR 1910.1001 addresses asbestos from the occupational health standpoint, by specifying limitations of workers' exposure through engineering controls, protective equipment, monitoring and training. The OSHA standard also provides requirements for the specifications and posting of caution signs and labels and respiratory protection guidelines. The EPA regulates the emission standard for asbestos (40 CFR Part 61, Subpart M) and addresses the requirements for the manufacturing, application, removal, and disposal of asbestos. The sections of the EPA regulations that pertain to the University are those which govern removal from renovation or demolition areas and the disposal of asbestos.

New York State Department of Labor (DOL) promulgated 12 NYCRR Part 56 (Industrial Code Rule) to address the hazards to public safety and health during the removal, encapsulation, enclosure or disturbance of friable asbestos or any handling of asbestos material that may result in the release of asbestos fiber. The New York State Department of Environmental Conservation (DEC) regulates the transportation of asbestos waste (6 NYCRR Part 364) and also the disposal in New York State landfills (6 NYCRR Part 360). By reference above, all the cited regulations are incorporated herein and become a part hereof.

III. ASBESTOS PROJECTS

An asbestos project, for the purpose of this program, is defined as any activity that may result in the disturbance of ACM, albeit unintentionally. This could involve projects whose main focus are not ACM, but which are undertaken in an area where ACM is present and may be disturbed. University Project Managers, Maintenance Supervisors, Custodial Supervisors and any other employee(s) involved in work which may disturb ACM, are required to contact the Physical Plant Environmental Shop for a determination of "asbestos project" status. This must occur prior to work commencing.

Outside asbestos contractors must notify the University's Asbestos Abatement Coordinator or delegate with the name of the designated "competent person" for each University asbestos project. This person will serve as the responsible, on-site party and assume regulatory responsibility for all asbestos work performed. The Physical Plant Environmental Shop Supervisor will designate the "competent person" for all in-house asbestos projects. The University Project Monitor will access project sites as deemed necessary for the purpose of determining DOL compliance.

A. Asbestos Work Performed by Outside Employers

The University's Asbestos Coordinator will ensure that all outside employers hired for asbestos work possess appropriate credentials. Completion of the Asbestos Qualifications Review form will be performed by the University's Asbestos Coordinator prior to asbestos work commencing. All outside employers performing asbestos work must notify the University's Asbestos Coordinator or delegate with the name of the designated "competent person" for each University asbestos project.

B. Identification of Asbestos

An accredited inspector identified installed asbestos on campus. All related records and reports resulting from the identification are maintained by the Physical Plant Environmental Shop. Records and information on ACM will be kept for as long as the University owns the building.
1. Building Assessments and Surveys
The University conducted building assessments that determined the presence, location and quantity of ACM. In the event of a project involving demolition of all or a portion of a structure in which ACM is present, a building survey will be conducted by a DOL certified worker, prior to commencement of work. Risk assessments were completed and recorded as part of the building survey.
2. Sampling
The University demonstrated that presumed asbestos-containing material (PACM) did not contain asbestos by taking samples and performing laboratory tests. Such tests included analysis of bulk samples collected in the manner described in 40 CFR 763.86. The tests, evaluation and sample collection were conducted by an accredited inspector or by a CIH. Analysis of samples was performed by a laboratory with proficiency demonstrated by current successful participation in the National Voluntary Laboratory Accreditation Program (NVLAP).
3. Monitoring
An initial exposure assessment in areas containing ACM will be conducted before the start of a planned asbestos project. This will evaluate exceedances of the permissible exposure limit (PEL) and will be conducted by DOL certified workers in accordance with the Industrial Code Rule and OSHA regulations. Initial monitoring is not required if objective data, (as determined by the University's Asbestos Abatement Coordinator), exists to demonstrate that asbestos will not be released in excess of the PEL. Monitoring services will be procured and supervised by the University's Asbestos Abatement Coordinator.

C. Notice

Three forms of notice regarding asbestos work are required. They are employee, discovery, and regulatory.
1. Employee Notice
University housekeeping employees working in buildings with installed ACM who may be potentially exposed, will receive Asbestos Awareness training, conducted by an Environmental Health Office representative. This training will be provided whenever the employee receives a new building assignment and minimally contains the following elements:
  • health effects of asbestos
  • locations of ACM or PACM in the building
  • recognition of ACM/PACM damage or deterioration
  • OSHA Standard requirements related to housekeeping
  • proper response to fiber release episodes
In accordance with the University's Multi-Employer Program and 29 CFR 1910.1200(e)(2), asbestos related information will be provided to outside employers whose employees may be potentially exposed to ACM. Outside employers are defined as employers, who are not employees of Syracuse University, yet perform a job or a service on University-operated property (on-site). This will be accomplished using forms included in the Multi-Employer Program Packet provided with all bid packages or are available from EHO.
2. Discovery Notice
Employees of the University and employees of contractors must notify their supervisor immediately upon discovery of material suspected of containing asbestos which would be disturbed by work activity. Such work activity includes, but is not limited to: cutting or sawing, drilling, sanding, grinding, or stripping.

University supervisors must immediately notify the Physical Plant Environmental Shop upon discovery. Outside contractor supervisors must immediately notify the Office of Design and Construction (or other Departmental) Project Manager, who will then contact the Physical Plant Environmental Shop. Any work already begun which could disturb the PACM and cause aerosolization must be immediately terminated. All such work will be postponed until authorization to proceed has been issued by the University's Asbestos Abatement Coordinator.

3. Regulatory Notice
Notice to regulatory authorities is required if the University or its contractor proposes to conduct an asbestos project involving quantities of ACM in excess of specified thresholds. The University's Asbestos Abatement Coordinator will notify DOL when required. One copy of the notification will be sent to EHO.

D. Labeling and Signage

The University's Asbestos Abatement Coordinator will ensure that required demarcation is employed at the University.
1. Regulated Areas
Warning signs must demarcate all regulated areas, which are defined as having airborne concentrations of asbestos which exceed or there is a reasonable possibility that exposures may exceed the PEL. Regulated areas may also include areas in and adjacent to which certain classes of work (29 CFR 1926.1101(b)) involving the actual or likely disturbance of ACM is conducted. Only certified asbestos workers who have appropriate PPE may enter regulated areas.
2. Warning Labels
Warning labels must be affixed to all raw materials, mixtures, scrap, waste, debris and other products containing Warning labels must be affixed to all raw materials, mixtures, scrap, waste, debris and other products containing asbestos fibers or to their containers. These labeling requirements to do not apply where the asbestos fibers have been modified by a binding agent, coating, binder or other material, provided that during their reasonably foreseeable use handling, storage, disposal, processing or transportation, no airborne concentrations of fibers of asbestos in excess of the PEL and/or excursion limit will be released. The requirements also do not apply to products with an asbestos concentration of less than one percent (1%).
3. Installed ACM/PACM Labeling
The following labeling requirements are required on campus. Installed asbestos products must bear a visible label where feasible. A color-coded system will be used on linear asbestos materials (i.e. pipe runs). Blue color-coding will indicate asbestos-free insulation and yellow color-coding will indicate asbestos containing material. The entrance to mechanical rooms or areas that contain thermal system insulation and surfacing ACM are posted with a sign identifying this. Placing labels on ACM floor, ceiling and wall tiles and unexposed ACM may not be feasible. These areas will have a small sticker placed on the doorjamb of the space indicating installed ACM. Information about ACM surfacing materials can be found in the building's asbestos binder or by contacting the University's Asbestos Abatement Coordinator.
4. Label and Sign Specifications
Labels must conform with current EPA specifications and shall be printed in letters of sufficient size and contrast as to be readily visible and legible. Warning signs must bear the following information:
DANGER ASBESTOS
CANCER AND LUNG DISEASE HAZARD
AUTHORIZED PERSONNEL ONLY
RESPIRATORS AND PROTECTION CLOTHING ARE REQUIRED IN THIS AREA

Labels on ACM must bear the following:
DANGER
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
CANCER AND LUNG DISEASE HAZARD

E. Transportation and Disposal of Waste

Contractors who remove ACM from the premises of the University must comply with all federal, state and local regulations regarding the proper handling and disposal of the waste containing asbestos. AMC waste generated at the University by Physical Plant Environmental Shop activities, will be collected at Physical Plant for transportation by waste haulers with valid DEC Part 364 permits. Copies of all related permits must be provided to the Physical Plant Environmental Shop at the time of contract. ACM waste at greater than 20% solids will be disposed of in a permitted DEC Part 360 sanitary landfill. The University's Asbestos Abatement Coordinator will ensure that all contractors and disposal sites are regularly reviewed and are appropriately permitted.

IV. CUSTODIAL ACTIVITIES

The following guidelines must be incorporated into ACM flooring material care Standard Operating Procedures (SOPs) for custodial staff. They must also be followed by outside employers hired by the University to perform ACM flooring material care. Custodial supervisors are responsible for supplying proper equipment and supplies; providing and documenting SOP training; and ensuring SOPs are adhered to.

All ACM floors must be stripped and scrubbed by wet methods (water with detergent or stripper). Floor machines must use low abrasion pads and operate at 300 rpm or less. Buffing and burnishing activities must include the use of low abrasion pads. Only floors with at least three coats of wax finish may be burnished.

V. ASBESTOS EMERGENCIES

In the event an emergency situation mandates that work be performed that involves ACM, the following special procedures will apply:

    1. All worked must be halted and potentially exposed individuals removed from the area until permission to return is given by the University's Asbestos Coordinator or designee.

    2. During regular working hours, the employee or outside employer will notify the Project Manager from Design & Construction and the University's Asbestos Coordinator or designee. After regular working hours, the employee or contractor must notify the Public Safety Office. In either case to the University's Asbestos Coordinator shall be immediately contacted for regarding the situation.

    3. Any unexpected or uncontrolled release of friable asbestos above the reportable quantity of one (1) pound must be immediately reported to EHO who will notify the National Response Center (800-424-8802). Any release which goes off-site must also be reported to DEC (800-457-7362) by EHO.

    4. Based on the nature of the emergency, the Physical Plant Environmental Shop representative will then go to the emergency scene and will grant or deny permission to conduct the requested work.

    5. If permission to conduct the work is denied, the procedures outlined in Section III, Asbestos Projects will apply.

    6. If permission to proceed is granted, job parameters will be set and monitored by the University's Asbestos Coordinator. Emergency notification to the DOL will be made, when appropriate, by the University's Asbestos Coordinator as soon as practical after identification of the project.

VI. HEALTH AND SAFETY

Training and appropriate personal protective equipment (PPE) are essential to limiting exposure to asbestos fibers. All applicable rules and regulations related to both items must be strictly followed by all employees at the University.

A. Training

The Occupational Safety and Health Administration (OSHA) has categorized work performed by asbestos workers into four classes (listed below). The University requires that any employee performing Class I-III work to hold NYS Department of Labor (DOL) certification. Certifications must be verified by the University's Asbestos Coordinator and be current and available for inspection during work on the project. Class IV asbestos jobs will be conducted by employees trained in the University's Asbestos Awareness program.
  1. University asbestos policy and program;
  2. Responsibility for reporting asbestos incidents;
  3. Occupational health pertaining to asbestos; and
  4. Occupational safety and environmental health regulations (DOL, OSHA, EPA).
New Physical Plant employees will receive this training within 60 days after hire. An annual "Asbestos Awareness Seminar" will be conducted by the Environmental Health Office for the University community. All related University training records will be maintained by the Hazard Communication Coordinator or delegate.

B. Personal Protective Equipment

The Physical Plant Environmental Shop Supervisor will ensure the issuance of appropriate PPE to all potentially exposed University personnel prior to commencement of asbestos work. PPE must be used and maintained as directed during in-service training. PPE must be worn throughout the asbestos project until the ACM waste has been double bagged and sealed. While performing work, if an employee needs to remove PPE, they must first leave the asbestos work area to the decontamination area. Reentry to the work site is permitted only after the worker has donned the required PPE. The University's Asbestos Coordinator will ensure that all Physical Plant Department personnel who are required to perform asbestos abatement work will:

    1. receive periodic in-service training by the Physical Plant Environmental Shop pertaining to safe asbestos handling and procedures such as glove bagging and the proper use of personal protective equipment, including fit-test for respirators.

    2. have baseline and annual medical examinations conducted and work/medical histories performed.

The University's Asbestos Coordinator will maintain all related documentation. Physical Plant Department personnel must wear PPE whenever the Physical Plant Environmental Shop Supervisor deems it necessary. All personnel refusing or neglecting to wear the required equipment will be subject to appropriate disciplinary action. PPE may include (but, not limited to) any or all of the following: protective clothing (Tyvek suit) and boots, appropriate gloves, respirator, and safety goggles/glasses.

VII. GENERAL INFORMATION

The information provided below will be updated as necessary and is current as of September 1999.
Department
Title
Name
Phone
Risk Management
Skytop Office Building		 Director David Pajak 443-5334
Physical Plant
285 Ainsley Drive		 Director Allan Breese 443-2793
Physical Plant
285 Ainsley Drive		 Asbestos Abatement Coordinator Dan Welker 443-1120
Environmental Health Office
029 Lyman Hall		 Director James McCumber 443-4132
Public Safety
005 Sims Hall		 Dispatcher 443-2224

The following DOL certifications are held by University employees:
Name
Handler
Supervisor
Inspector
Project Monitor
Mike Culligan
x
x
x
x
Andy Kenyon
x
x
x
x
Maurice Maggiolino
x
x
x
x
David McKenney
x
x
x
x
Roger Stevens
-
-
-
x
Patricia Stock
-
-
-
x
Dan Welker
x
x
x
x
Allen Williams
x
x
x
x

Glossary

A

ACM: (asbestos containing material), any material containing more than 1% asbestos (by weight)

AIHA: American Industrial Hygiene Association

asbestos: any naturally occurring hydrated mineral silicate separable into commercially usable fibers, including chrysotile (serpentine), amosite (cummingtontonite-grunerite), crocidolite (riebeckite), tremolite, anthrophyllite and actinolite

asbestos project: work undertaken which involves the removal, encapsulation, enclosure or disturbance of friable asbestos or any handling of asbestos material that may result in the release of asbestos fiber

C

CIH: certified industrial hygienist

competent person: the responsible, on-site person who assumes regulatory responsibility for work performed

D

DEC: New York State Department of Environmental Conservation

DOL: New York State Department of Labor

E

EPA: United States Environmental Protection Agency

F

friable: the condition of crumbled, pulverized, powdered, crushed or exposed asbestos which is capable of being released into the air by hand pressure

O

OSHA: Occupational Safety and Health Administration

outside employer: employers, who are not employees of Syracuse University, yet perform a job or a service on University-operated property

P

PACM: presumed ACM; thermal insulation, sprayed on or troweled on surfacing material and debris in work areas where such material is present

PEL: permissible exposure limit; 0.1 fibers/cubic centimeter for asbestos

S

surfactant: a chemical wetting agent added to water to improve its penetration