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Title:

Asbestos Hazards and Controls

Publication date:

4/4/2013

Effective date:

4/3/2007

BRIEF

Policy Summary

Berkeley Lab's Asbestos Management Plan 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: 

http://www.lbl.gov/ehs/ih/forms/AsbestosMgmtPlan.pdf

Contact Information

Asbestos Subject Matter Expert
Industrial Hygiene Group
EHSS Division
End Brief

Title:

Asbestos Hazards and Controls

Publication date:

4/4/2013

Effective date:

4/3/2007

POLICY

A. Purpose

Lawrence Berkeley National Laboratory's (Berkeley Lab's) Asbestos Management Plan 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. Asbestos-containing materials 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 asbestos-containing materials, review Work Process B. Examples of materials that have been manufactured with asbestos:
    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 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 presumed asbestos-containing material (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 EHSS 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.
  • Submits written notifications to the BAAQMD of cumulative renovations (during a calendar year) that involve reportable amounts of RACM. (Note: This is a shared responsibility with Facilities, the Environmental Protection Group [EPG], and Industrial Hygiene.)
  • 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:
    • Ensures that buildings and equipment are surveyed for ACM prior to demolitions and renovations. (Note: This is a dual responsibility shared with Industrial Hygiene.)
    • 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 Industrial Hygiene.)
    • Submits copies of all contractor air-monitoring results to an EH&S Industrial Hygienist
    • Notifies an EH&S 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 Processes D and 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 EH&S Industrial Hygienist prior to purchasing new ACM

EHSS 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: Environmental Protection Agency (EPA)-approved Building Inspector/Management Planner, Contractor/Supervisor, Project Designer, with 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 Management Plan 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 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 Management Plan 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 Industrial Hygiene Group maintains the following records:

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

H. Implementing Documents

Document number

Title

Type

07.07.002.001

Asbestos Management Program

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 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

Asbestos Subject Matter Expert
Industrial Hygiene Group
EHSS 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

4/4/2013

1

R. Ronnelly

Rewrite for wiki (policy)

All

Minor



Remove this text after wiki tabs are set. End Policy.

DOCUMENT INFORMATION

Title:

Asbestos Hazards and Controls

Document number

07.07.002.000

Revision number

1

Publication date:

4/4/2013

Effective date:

4/3/2007

Next review date:

4/4/2016

Policy Area:

Industrial Hygiene and Safety

RPM Section (home)

ESH

RPM Section (cross-reference)

None

Functional Division

EHSS

Prior reference information (optional)

PUB-3000 Section 4.8

Source Requirements Documents

  • 8 CCR 1529, 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


Implementing Documents

Document number

Title

Type

07.07.002.001

Asbestos Management Program

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 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


Remove this text after wiki tabs are set. End Document Info.

ADDITIONAL INFORMATION

Title:

Asbestos Hazards and Controls

Document number

07.07.002.000

Revision number

1

Publication date:

4/4/2013

Effective date:

4/3/2007

Next review date:

4/4/2016

Policy Area:

Industrial Hygiene and Safety

RPM Section (home)

ESH

RPM Section (cross-reference)

none

Functional Division

EHSS

Author name/contact info

R. Connelly

 

 

Revision 0 publication date

1/2/2012

Retirement date

n/a

Prior reference information (optional)

PUB-3000 Section 4.8

 

 

Inputs from more than one Functional Area?

No

List additional Functional Areas & contacts

 

 

 

Inputs from more than one Policy Area?

No

List additional Policy Areas & contacts

 

 

 

30-day notification needed?

No

30-day start date

n/a

30-day end date

n/a

 

 

LDAP protected?

No

 

 

Need TABL reminders?

No

Frequency

n/a

Brief reminder text:

n/a

 

 

Approval Sheet for this revision received (date)
[Note: author is responsible}

 

Keyword search words, phrases:

  • Text, text, text

New terms that need to be added to Glossary/Acronym list:

  • (list items not found and context (Policy Area name) – full definition would be included in Policy)

Implementing Documents restricted to department/functional use

(optional – these will be used for tracing between requirements and associated documents)

Document number

Title

 

 

 

 



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