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    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

    1. ACMS can be divided into two general categories: friable and nonfriable. Review hazards and controls for asbestos in Work Process A.
    2. 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.
    3. Personnel must be trained according to requirements prior to working with ACM (Work Process C).
    4. 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.
    5. 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.
    6. Maintenance and repair work involving ACM or PACM is Class IV asbestos work (Work Process F).

    7. Dispose of all removed ACM as hazardous waste (Work Process G).
    8. 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.
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    • 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

    EHS Subject Matter Expert for Asbestos
    EHS Division

    J. Revision History

    Date

    Revision

    By Whom

    Revision Description

    Section(s) Affected

    Change Type

    1/2/2012

    0

    R. Connelly

    Rewrite for wiki (brief)

    All

    Minor

    5/15/2013

    1

    R. Connelly

    Rewrite for wiki (policy)

    All

    Minor

    8/18/2020

    1.1

    R. Brown

    Reference update to Cal/OSHA to reflect 10 CFR 851 variance

    Source documents

    Minor

    DOCUMENT INFORMATION

    Title:

    Asbestos Hazards and Controls

    Document number

    07.07.002.000

    Revision number

    1.1

    Publication date:

    8/18/2020

    Effective date:

    8/18/2020

    Next review date:

    8/18/2025

    Policy Area:

    Industrial Hygiene and Safety

    RPM Section (home)

    ESH

    RPM Section (cross-reference)

    None

    Functional Division

    EHS

    Prior reference information (optional)

    ES&H Manual Section 4.8 moved to Chapter 36

    Source Requirements Documents

    • Title 8 CCR 1529, 5208, Asbestos
    • BAAQMD, Regulation 11, Rule 2, Asbestos Demolition, Renovation and Manufacturing
    • 29 CFR 1926.32, Definitions
    • 29 CFR 1910.1001, Asbestos Occupational Safety and Health Standards, Department of Labor, General Industry
    • 29 CFR 1926.1101, Asbestos Safety and Health Standards for the (formerly 1926.58) Construction Industry, Department of Labor
    • 40 CFR 61, National Emission Standards for Hazardous Air Pollutants (NESHAP), Environmental Protection Agency (EPA)
    • 40 CFR Part 763, Subpart E (guidance), Asbestos Hazard Emergency Response Act (AHERA) — EPA regulations for schools

    Other Driving Requirements

    • Title 22, California Code of Regulations, Article 18 Land Disposal Restrictions, California Department of Toxic Substances Control (DTSC). https://dtsc.ca.gov/title22/

    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

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