Asbestos Hazards and Controls

Title:	Asbestos Hazards and Controls
Publication date:	8/18/2020
Effective date:	8/18/2020

BRIEF

Policy Summary

Berkeley Lab's Asbestos Hazards and Controls program manages the presence of asbestos-containing material (ACM) at the Laboratory site by:

Mandating building survey and employee monitoring requirements for asbestos.
Communicating the presence of asbestos and potential exposures via signage and other written communication.
Listing engineering controls, training, and personal protective equipment (PPE) requirements for people and activities that will involve ACM.
Providing removal and repair procedures for ACM.

Who Should Read This Policy

All Berkeley Lab employees, affiliates, visitors, and subcontractors

To Read the Full Policy, Go To:

The POLICY tab on this wiki page

To Read ES&H Program Details, Go To:

ES&H Manual Chapter 36

Contact Information

EHS Subject Matter Expert for Asbestos
EHS Division

Title:	Asbestos Hazards and Controls
Publication date:	8/18/2020
Effective date:	8/18/2020

POLICY

A. Purpose

Lawrence Berkeley National Laboratory's (Berkeley Lab's) Asbestos Hazards and Controls program manages the presence of asbestos-containing material (ACM) at the Laboratory site by:

Mandating building survey and employee monitoring requirements for asbestos.
Communicating the presence of asbestos and potential exposures via signage and other written communication.
Listing engineering controls, training, and personal protective equipment (PPE) requirements for people and activities that will involve ACM.
Providing removal and repair procedures for ACM.

B. Persons Affected

All Berkeley Lab employees, affiliates, visitors, and subcontractors

C. Exceptions

None

D. Policy Statement

ACMS can be divided into two general categories: friable and nonfriable. Review hazards and controls for asbestos in Work Process A.
For guidance on the identification of ACMS, review Work Process B. Examples of materials that have been manufactured with asbestos include:
1. Cement/asbestos panels and pipes (transite).
2. High-temperature gaskets.
3. Pipe insulation (block, corrugated, air cell, etc.).
4. Mastic for vinyl flooring.
5. Vinyl floor tiles and sheet vinyl flooring.
6. Wallboard (Sheetrock).
7. Electric wiring insulation.
8. Taping or joint compounds.
9. Spray-applied fireproofing and insulation.
10. Roofing felt/shingles/flashing.
11. Automotive brake linings and pads.
12. Ceiling tiles.
13. Fire-resistant gloves, clothing.
14. HVAC duct insulation and tape.
15. Linoleum and other resilient flooring.
16. Paint.
17. Fire doors.
18. Window putty.
19. Plaster/stucco.
20. Elevator/crane brake shoes.
Personnel must be trained according to requirements prior to working with ACM (Work Process C).
Removal of thermal system insulation (TSI) or surfacing material greater than one glove bag is Class I asbestos work. Removal of ACM other than TSI or surfacing materials is Class II asbestos work. Examples of this type of work include the removal of roofing, flooring, mastics, gaskets, transite, wallboard, etc. See Work Process D for Class I and Class II requirements.
Repair and maintenance activities that disturb ACM (or presumed asbestos-containing material [PACM]) are Class III asbestos work (Work Process E). Class III includes TSI and surfacing material and the cleanup of ACM dust or debris. The amount disturbed must fit in one glove bag or waste bag less than 60 inches in width.
Maintenance and repair work involving ACM or PACM is Class IV asbestos work (Work Process F).
Dispose of all removed ACM as hazardous waste (Work Process G).
File all reports and testing paperwork according to Work Process H.

E. Roles and Responsibilities

Roles	Responsibilities
Building Managers	Notify the EHS Division of suspected or known ACM that may pose a health hazard.
Environmental Protection Group	Submits written notification to the Bay Area Air Quality Management District (BAAQMD) at least 10 working days in advance of all demolitions (notification must be given at all times, even when ACM is not present) and renovations involving removal of regulated asbestos-containing material (RACM) greater than or equal to 100 linear feet, 100 ft² or 35 ft³, unless the notification is completed by a subcontractor performing the work. <ac:structured-macro ac:name="unmigrated-wiki-markup" ac:schema-version="1" ac:macro-id="063121bd-9a14-41d7-a81c-3e29fa138b01"><ac:plain-text-body><![CDATAThis is a shared responsibility with Facilities, the Environmental Protection Group [EPG], and the Health and Safety Department.) \]></ac:plain-text-body></ac:structured-macro> Prepares written requests to the BAAQMD for approval of alternate removal methods, such as dry removals.
Facilities Division	Maintains ACM to prevent employee exposures and releases to the environment Responsibilities related to asbestos bulk sampling are as follows: Ensures that buildings and equipment are surveyed for ACM prior to demolitions and renovations. (Note: This is a dual responsibility shared with the Health and Safety Department.) Ensures industrial hygiene services are budgeted for large-scale asbestos abatement projects. This is to provide day-to-day on-site industrial hygiene oversight for the project. Includes site-specific contract specifications for large-scale asbestos abatement projects. Notifies the Industrial Hygienist and/or Environmental Protection of every demolition, whether or not it involves asbestos, and every removal of RACM prior to starting. Ensures that contract specifications are followed by abatement contractors. (Note: This is a shared responsibility with the Health and Safety Department.) Submits copies of all contractor air-monitoring results to an EHS Industrial Hygienist. Notifies an EHS Industrial Hygienist of all asbestos abatement projects involving Class I & II work verbally as far in advance as feasible. Performs asbestos abatement or encapsulating work in accordance with Work Process D and Work Process E, as applicable, of this program. Ensures Facilities employees performing work with ACM or potentially exposed to asbestos at a concentration above the PEL or excursion limit have current training appropriate for the type of asbestos work they are performing. Obtains written approval from an EHS Industrial Hygienist prior to purchasing new ACM.
EHS Industrial Hygienist	Reviews specifications for large-scale abatement projects and associated compliance plans involving the large-scale disturbance of ACM. Ensures buildings and equipment are surveyed for ACM by Facilities or contract consultants prior to demolitions and renovations. (Note: This is a dual responsibility shared with Facilities.) Performs representative personal air monitoring and area air monitoring (e.g., clearance sampling) as appropriate for asbestos abatement work involving Berkeley Lab employees. Notifies the employee and the employee's supervisor of the results in writing within five working days of their receipt. Performs quantitative respirator fit tests annually for employees routinely involved with asbestos abatement work. (Note: Given the limited amount of asbestos work performed by asbestos-trained employees in Facilities, employee fit tests may not be current. In these cases, asbestos work may not be performed until the fit test is made current again.) Provides consultation and inspection for the Environmental Protection Agency (EPA)-approved Building Inspector/Management Planner, Contractor/Supervisor, and Project Designer, with the EHS Industrial Hygienist’s current certification. Note: Certified Industrial Hygienists do not have to attend the Building Inspector course (29 CFR 1926.1101[k][ii][B]).
Health Services Group	Provides, as necessary, complete asbestos physical examinations as described in 29 CFR 1926.1101 or 29 CFR 1910.1001 for Berkeley Lab employees who may be enrolled in the asbestos medical surveillance program.
Supervisors of employees who routinely work with or may disturb ACM	Ensure employees are provided the appropriate protective clothing and respiratory protection. Ensure employees who conduct asbestos work comply with Berkeley Lab's Asbestos Hazards and Controls program and 29 CFR 1926.1101. Also ensure employees handling asbestos, or who may be exposed to asbestos at or above the PEL or excursion limit, have received required training. Ensure appropriate employees receive medical surveillance if necessary.
Waste Management Group	Provides assistance with labeling, storage, and disposal requirements for ACM. Selects a Department of Toxic Substances Control (DTSC)-approved disposal site for all RACM and asbestos-contaminated waste material. (Note: DTSC approvals are not required for non-RACM materials, including undamaged floor tiles and Sheetrock containing less than 1% asbestos by point counting analysis.) Ensures proper packing and loading of ACM onto transport vehicles. Ensures vehicles transporting RACM and asbestos-contaminated waste materials (e.g., clothing and equipment) are placarded in compliance with BAAQMD Rule 11-2-304.5, and that waste shipment records comply with BAAQMD Rule 11-2-502. Manifests RACM and asbestos-contaminated waste materials from Berkeley Lab to the disposal site. Maintains disposal records. Ensures Hazardous Waste Handling Facility employees who handle asbestos-containing waste are adequately trained. Provides the Facilities Division with necessary waste-disposal information prior to abatement projects.

F. Definitions/Acronyms

See the Asbestos Hazards and Controls program for technical terms related to the details of this policy and its implementation.

Term	Definition
ACM (asbestos-containing material)	Building materials that contain asbestos in an amount greater than 1.0% by weight, area, or count
Asbestos	A generic term referring to naturally occurring fibrous mineral silicates. The three most common types are chrysotile (white) asbestos, amosite (brown) asbestos, and crocidolite (blue) asbestos.
BAAQMD	Bay Area Air Quality Management District
Class I Asbestos Work	Activities involving the removal of thermal system insulation (TSI) and surfacing ACM
Class II Asbestos Work	The removal of asbestos-containing wallboard, floor tile, roofing materials, transite, construction mastic, gaskets, etc. This does not involve the removal of TSI or surfacing materials.
Class III Asbestos Work	Activities involving repair and maintenance operations where ACM (including TSI and surfacing materials) are likely to be disturbed. The amount removed must fit into one glove bag or waste bag less than 60 inches in width.
Class IV Asbestos Work	Maintenance or custodial activities in which employees contact ACM or PACM, and activities to clean up waste and debris containing ACM and PACM
Friable ACM	A material containing asbestos that can be crumbled, pulverized, or reduced to a powder when dry, under hand pressure, or that has been crumbled, pulverized, or reduced to a powder
Nonfriable ACM (Category I)	Intact asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing products
Nonfriable ACM (Category II)	Asbestos-containing material (excluding Category I) that when dry and in its present form cannot be crumbled, pulverized, or reduced to powder by hand pressure. This includes asbestos cement products, transite board, pipe, plaster, stucco, paint, and mastics.
PACM (presumed asbestos-containing material)	Material that may contain asbestos and has not been sampled for asbestos content. It should be assumed to contain asbestos and treated accordingly.
PEL	Permissible Exposure Level
RACM (regulated asbestos-containing material)	Friable ACM Nonfriable Category I ACM that has or will become friable, or that has been subjected to sanding, drilling, grinding, cutting, or abrading Nonfriable Category II ACM that may become crumbled, pulverized, or reduced to powder by the forces expected to act upon the material in the course of demolition or renovation
TSI (thermal system insulation)	Insulation applied to pipes, fittings, boilers, ducts, etc., to prevent heat loss or gain

G. Recordkeeping Requirements

The Health and Safety Department maintains the following records:

Bulk sampling.
Employee notification.
Exposure monitoring.
Asbestos training.

H. Implementing Documents

Document number	Title	Type
07.07.002.001	Asbestos Hazards and Controls	Program
07.07.002.002	Work Process A, General Requirements	Process
07.07.002.003	Work Process B, Asbestos Identification Process	Process
07.07.002.004	Work Process C, Training Requirements	Process
07.07.002.005	Work Process D, Class I and II Asbestos Work Procedures	Process
07.07.002.006	Work Process E, Class III Asbestos Work Procedures	Process
07.07.002.007	Work Process F, Class IV Asbestos Maintenance and Custodial Work	Process
07.07.002.008	Work Process G, Waste Disposal Requirements	Process
07.07.002.009	Work Process H, Reports and Tests	Process
07.07.002.010	Asbestos Management Plan	Plan

I. Contact Information