Managing Asbestos In Place
A Building Owner’s Guide to
Operations and Maintenance Programs
for Asbestos-Containing Materials
Contents
ACKNOWLEDGEMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
FOREWORD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii
1. WHY IS ASBESTOS A PROBLEM?
Introduction and Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
● Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
● Chapter Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
2. WHAT IS AN O&M PROGRAM?
Purpose and Scope of an Operations and Maintenance program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
● Purpose of O&M Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
● Scope of an O&M Program . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
● Chapter Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3. HOW DOES THE PROGRAM START?
Laying the Foundation for an Effective O&M Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
● The Asbestos Program Manager . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7
● BuildingInspectionandAssessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
● Developing an O&M Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
● IrnplementingandManaging an O&M
Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
● Cost Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9
● Selectingandhnplementing Alternative Abatement Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
● Chapter Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
4. WHAT DOES AN O&M PROGRAM INCLUDE?
O&M Program Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12
● Informing Building Workers, Tenants, and Other Occupants . . . . . . . . . . . . . . . . . . . . . . . . . . .12
● ACMSurveiUance-Reirwectionand Periodic Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . .14
● Supplement to Visual/Physical Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14
● WorkControl/Permit System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
● O&M Work Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16
–Worker protection programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17
–Basic O&M Procedures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
–O&M Cleaning Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
–Procedures for Asbestos Fiber Release Episodes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
● Recordkeeping .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
● Chapter Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22
5. WHAT O&M TRAINING IS NECESSARY?
Types of Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3
● Chapter Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25
ii i
6. WHAT REGULATIONS AFFECT ASBESTOS MANAGEMENT PROGRAMS IN
BUILDINGS, ESPECIALLY O&M PROGRAMS?
Federal, State, and Local Regulations Affecting O&M Programs. . . . . . . . . . . . . . . . . . . . . . . . . . 26
● OSHA Regulations &EPA Worker Protection Rule .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
–Small-scale, Short-duration Projects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
● EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) Regulations. . . .27
–Notification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
–Emissions Control and Waste Disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
● Resource Conservation and Recovery Act (RCRA); Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA, or "Superfund") . . . . . . . . . . . . . . . . . . . . . . . . . . 28
● Asbestos Hazard Emergency Response Act (AHERA) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
● Asbestos Ban and Phaseout Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
● Chapter Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
APPENDIX A.
Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
APPENDIX B.
Sample Recordkeeping Forms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
APPENDIX C.
Illustrative Organzation Charts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
APPENDIX D.
Additional Assistance (EPA, NESW, OSHA; Training ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
APPENDIX E.
Respiratory Protection Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
APPENDIX F.
Existing EPA Guidance For ACM Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
APPENDIX G.
Sample List: Suspect Asbestos-Containing Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
APPENDIX H.
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .40
DISCLAIMER
This document was prepared under contract to an agency of the United States Government. Neither the United States Government
nor any of their employees makes any warranty, expressed or implied, or assume any legal liability for any third party’s use of or the
results of such use of any information, product, or process discussed in this document. Mention or illustration of company or trade
names, or of commercial products does not constitute endorsement by the U.S. Environmental Protection Agency.
i v
Acknowledgements
The time and effort that many individual contributed to the development of this document is
gratefully acknowledged by the U.S. Environmental Protection Agency (EPA). The material in this
publication represents EPA’s approximately 11 years of experience in considering public input and
fine tuning policies on managing asbestos-containing materials in buildings. This document
incorporates views expressed by safety and health professionals, property owners and managers,
public officials, general industry representatives, workers, and the general public.
The primary EPA developer and coordinator of the final
document was Dr. Robert Jordan of the Technical
Assistance Section, Environmental Assistance Divi-
sion, Office of Toxic Substances. Without Bob’s con-
stant oversight, combined with his technical knowledge
and concern that the document be representative of
state-of-the-art asbestos management, this document
would not have reached the public.
Joe Schechter, Chief of the Technical Assistance Sec-
tion, managed the project and helped clarify and edit the
Guide. Bob McNally Chief of the Assistance Programs
Development Branch, was instrumental in the forma-
tive period of the Guide’s development and also devoted
long hours to its review Other important contributions
within the Environmental Assistance Division came
from Tom Tom and Dave Kling. Sylvia Thomas
provided necessary assistance in revisions of the early
drafts. Esther Tepper and Jane Gurin helped review the
Guide in its final revisions, to make sure the document
was written in easy-to-understand language.
The original work which provided the foundation for the
project was performed under a contract with Battelle
Memorial Institute (No. 68-02-4294) by Dr. Dale Keyes
and Dr. Jean Chesson, under the direction of Edie
Sterrett and Cindy Stroup of the EPA Exposure
Evaluation Division. They prepared the first drafts of
the document and were instrumental in establishing its
final format.
EPA staff also gratefully acknowledge the work of staff
from the Georgia Tech Research Institute (GTRI).
Through a cooperative agreement with EPA they
served as the overall project coordinator and provided
thoughtful technical guidance throughout this entire
process. The GTRI team also developed several key
sections of the Guide.
This publication was refined through a peer review
meeting held in October 1988 in Washington, DC, and
by a series of comment periods provided through May
1990. The following individuals gave their time and
provided comments:
John Biechman, Safe Buildings Alliance
Wolfgang Brandner, U.S. EPA Region VII
Frank Bull, Bull, Brown & Kilgo Architects
Eva Clay The Environmental Institute
William Cobbs, U.S. General Services
Administration
Mark Demyanek, Georgia Tech Research
Institute
Michael Duffy, Service Employees International
Union
Paul Fidducia, Winston and Strawn
Eugene Fisher, Association of Wall and Ceiling
Industries
Douglas Greenaway Consultant (formerly,
Building Owners and Managers Association
International)
David Harris, National Institute of Building
Sciences
Steve Hays, Gobbell Hays Partners
Joseph Hopkins, U.S. Department of Energy
David Mayer, Georgia Tech Research Institute
Richard Mendes, New York City Department of
Environmental Protection
Michael Miles, Tishman Spyer Properties
Roger Morse, ENTEK Environmental and
Technical Services, Inc.
Robert Navratil, RREEF Funds, Construction
and Engineering
Anthony Restaino, U.S. EPA Region V
Richard Roth, Social Security Administration
Sims ROy, U.S. EPA, Office of Air Quality
Planning and Standards
v
Scott Schneider, Workers’ Institute for
Asbestos in Public and Commercial Buildings, which
Occupational Safety and Health
met several times during 1989–1990. The purpose of
Henry Singer, U.S. General Services
this multidisciplinary group was to identify the prob-
Administration
lems associated with asbestos in public and commercial
Thomas Warren, Rose Associates, Inc.
buildings and to develop policy recommendations for
solving these problems. Many comments raised by the
In addition to these individuals, the EPA acknowledges
Dialogue Group in the area of asbestos management
the contribution of the Policy Dialogue Group on
were incorporated into this document.
v i
Foreword
In February 1988, the Administrator of the Environmental Protection Agency (EPA) recommended
to Congress that the Agency work during the next three years to enhance the nation’s technical
capability in asbestos by helping building owners better select and apply appropriate asbestos control
and abatement actions in their buildings. The publication of this guidance document is EPA’s most
extensive effort to date to carry out that recommendation. In fact, Managing Asbestos In Place is
the most comprehensive asbestos guide published by EPA since the Agency expanded and updated
Guidance for Controlling Asbetos-Containing Materials in Buildings (also known as the Purple
Book) in June 1985. Based on the insights and recommendations of nationally recognized asbestos
experts, this new guide, along with a new operations and maintenance work practices manual
expected to be available in 1991, provides “state-of-the-art” instruction to building owners to help
them successfully manage asbestos-containing materials in place.
Managing Asbestos in Place does not supplant the
1985 Purple Book as EPA’s principal asbestos guidance
document. Rather, based on our experience since 1985,
it expands and refines the Purple Book’s guidance for a
special operations and maintenance (O&M) program.
In particular, the guide more strongly emphasizes the
importance of in-place management. The guide’s pur-
pose is two-fold. First, it offers building owners the
more detailed and up-to-date instruction they need to
carry out a successful O&M program. Second, it
informs building owners, lenders, and insurers that a
properly conducted O&M program can in many cases
be as appropriate an asbestos control strategy as
removal. Furthermore, in some cases, an O&M pro-
gram is more appropriate than other asbestos control
strategies, including removal.
Emphasizing the importance and effectiveness of a
good O&M program is a critical element of EPA’s
broader effort to put the potential hazard and risk of
asbestos exposure in proper perspective. That effort
centers around communicating the following jive facts,
which EPA hopes will help calm the unwarranted fears
that a number of people seem to have about the mere
presence of asbestos in their buildings and discourage
the spontaneous decisions by some building owners to
remove all asbestos-containing material regardless of its
condition.
FACT ONE: Although asbestos is
hazardous, the risk of asbestos-related
disease depends upon exposure to
airborne asbestos fibers.
In other words, an individual must breathe asbestos
fibers in order to incur any chance of developing an
asbestos-related disease. How many fibers a person
must breathe to develop disease is uncertain. However,
at very low exposure levels, the risk maybe negligible or
zero.
FACT TWO: Based upon available data,
the average airborne asbestos levels in
buildings seem to be very low. Accordingly,
the health risk to most building occupants
also appears to be very low.
A 1987 EPA study found asbestos air levels in a small
segment of Federal buildings to be essentially the same
as levels outside these buildings. Based on that limited
data, most building occupants (i.e., those unlikely to
disturb asbestos-containing building materials) appear
to face only a very slight risk, if any, of developing an
asbestos-related disease.
vii
FACT THREE: Removal is often not a
building owner's best course of action to
reduce asbestos exposure. In fact, an
improper removal can create a dangerous
situation where none previously existed.
FACT FIVE: EPA does recommend a pro-
active, in-place management program
whenever asbestos-containing material is
discovered.
By their nature, asbestos removals tend to elevate the
airborne level of asbestos fibers. Unless all safeguards
are properly applied, a removal operation can actually
increase rather than decrease the risk of asbestos-
related disease.
FACT FOUR: EPA only requires asbestos
removal in order to prevent significant
public exposure to airborne asbestos
fibers during building demolition or
renovation activities.
As this guide will explain in some detail, in-place
management does not mean “do nothing.” It means
having a program to ensure that the day-to-day manage-
ment of the building is carried out in a manner that
minimizes release of asbestos fibers into the air, and
ensures that when asbestos fibers are released, either
accidentally or intentionally proper control and cleanup
procedures are implemented. As such, it may be all that
is necessary to control the release of asbestos fibers,
until the asbestos-containing material in a building is
scheduled to be disturbed by renovation or demolition
activities.
Asbestos removal before the wrecking ball swings into
action is appropriate to protect public health. At other
times, EPA believes that asbestos removal projects,
unless well-designed and properly performed, can
actually increase health risk.
viii
Why Is Asbestos a Problem?
Introduction: Asbestos in Buildings
This U.S. Environmental Protection Agency (EPA) guide is primarily directed to owners and
managers of office buildings, shopping centers, apartment buildings, hospitals, and similar facilities
which may contain asbestos materials. Managers of industrial plants and other types of structures
may need to supplement this information with additional specialized guidance. This document gives
building owners, managers, workers, and other key building staff basic information on how to develop
and carry out high-quality operations and maintenance programs for managing asbestos in place to
safeguard the health of all building occupants. An operations and maintenance (O&M) program can
be defined as a formulated plan of training, cleaning, work practices, and surveillance to maintain
asbestos-containing materials (ACM) in good condition.
In this document you will find the following information:
The objectives of an O&M program, and an
indication of the scope of O&M activities
(Chapter 2);
Basic steps to take before starting an O&M
program, including an initial survey and evalua-
tion of ACM (Chapter 3);
How to implement and manage the program,
including some basic cost considerations
(Chapter 3);
O&M work practices that protect both
workers and the general building environment
(Chapter 4);
Recordkeeping suggestions and requirements
(a section of Chapter 4);
Training recommendations and requirements
for workers performing O&M activities (Chap-
ter 5); and
An overview of federal regulations, including
those affecting O&M programs (Chapter 6).
In addition, the Appendices provide other useful infor-
mation, including a glossary of useful terms, and
contacts for additional assistance.
How O&M
There are steps which a building
Fits In
owner can take to prevent as-
bestos fiber releases or resuspen-
sion of already-released fibers, or control fiber releases
quickly and safely if they occur. O&M programs are
designed to achieve both these goals. This guide’s
purpose, therefore, is to inform building owners about
how to develop, implement and manage effective O&M
programs, and to encourage their use.
EPA recommends a pro-active, in-place management
program whenever asbestos is discovered. In many
buildings, a well-run O&M program may be all that is
necessary to control the release of asbestos fibers until
the ACM in the building is abated through renovation or
demolition activities. Also, an emergency repair to
equipment or building services, or an unexpected
incident such as ACM falling from a surface could
necessitate a different control strategy However, bar-
ring such events, if ACM is properly managed, release of
asbestos fibers into the air is minimized. The exposure
to asbestos fibers, and therefore the risk of asbestos-
related disease, can be reduced to a negligible level for
all building occupants.
An O&M program may also provide an effective, less
costly alternative to wholesale removal operations.
Some additional cost-related considerations are dis-
cussed in Chapter 3.
The EPA National Emission Standards for Hazardous
An O&M program
can be defined
as a formulated
plan of training,
cleaning, work
practices, and
surveillance
to maintain
asbestos-
containing
materials in
good condition.
1
Air Pollutants (NESHAP) regulations on asbestos may
require ACM removal prior to renovation and/or
demolition projects, to prevent significant asbestos
releases into the air (see Chapter 6). Additionally
removal of some ACM in a building will be necessary if
the material has been damaged beyond repair. However,
at other times, removal is often not a building owner’s
best course of action to reduce asbestos exposure.
(Extraneous factors –for example, difficulty in obtain-
ing insurance, or obtaining financing relative to a real
estate transaction-may actually represent the driving
forces in a decision to remove all ACM, rather than a
health-based need for removal.) In fact, unless all
safeguards are properly applied by trained, experienced
individuals, removing ACM can actually increase build-
ing occupants’ risk of asbestos-related disease.
Background
The Asbestos
Asbestos fibers can cause se-
Issue
rious health problems. If in-
haled. they can cause diseases
which disrupt the normal functioning of the lungs.
Three specific diseases–asbestosis (a fibrous scarring
of the lungs), lung cancer, and mesothelioma (a cancer of
the lining of the chest or abdominal Cavity) -have been
linked to asbestos exposure. These diseases do not
develop immediately after inhalation of asbestos fibers;
it may be 20 years or more before symptoms appear.
In general, as with cigarette smoking and the inhalation
of tobacco smoke, the more asbestos fibers a person
inhales, the greater the risk of developing an asbestos-
related disease. Most of the cases of severe health
problems resulting from asbestos exposure have been
experienced by workers who held jobs in industries such
as shipbuilding, mining, milling, and fabricating, where
they were exposed to very high levels of asbestos in the
air, without benefit of the worker protections now
afforded by law Many of these same workers were also
smokers. These employees worked directly with as-
bestos materials on a regular basis and, generally for
long periods of time as part of their jobs. Additionally
there is an increasing concern for the health and safety
of construction, renovation, and building maintenance
personnel, because of possible periodic exposure to
elevated levels of asbestos fibers while performing their
jobs.
Whenever we discuss the risk posed by asbestos, we
must keep in mind that asbestos fibers can be found
nearly everywhere in our environment (usually at very
low levels). There is, at this time, insufficient informa-
tion concerning health effects resulting from low-level
asbestos exposure, either from exposures in buildings
or from our environment. This makes it difficult to
accurately assess the magnitude of cancer risk for
building occupants, tenants, and building maintenance
and custodial workers. Although in general the risk is
likely to be negligible for occupants, health concerns
remain, particularly for the building’s custodial and
maintenance workers. Their jobs are likely to bring
them into close proximity to ACM, and may sometimes
require them to disturb the ACM in the performance of
maintenance activities. For these workers in particular,
a complete and effective O&M program can greatly
reduce asbestos exposure. This kind of O&M program
can also minimize asbestos exposures for other building
occupants as well.
What is
The term “asbestos” describes
Asbestos?
six naturally occurring fibrous
minerals found in certain types of
rock formations. Of that general group, the minerals
chrysotile, amosite, and crocidolite have been most
commonly used in building products. When mined and
processed, asbestos is typically separated into very thin
fibers. When these fibers are present in the air, they are
normally invisible to the naked eye. Asbestos fibers are
commonly mixed during processing with a material
which binds them together so that they can be used in
many different products. Because these fibers are so
small and light, they may remain in the air for many
hours if they are released from ACM in a building. When
fibers are released into the air they may be inhaled by
people in the building.
Asbestos became a popular commercial product be-
cause it is strong, won’t burn, resists corrosion, and
insulates well. In the United States, its commercial use
began in the early 1900’s and peaked in the period from
World War II into the 1970’s. Under the Clean Air Act of
1970 the EPA has been regulating many asbestos-
containing materials which, by EPA definition, are
materials with more than 1 percent asbestos. The
Occupational Safety and Health Administration’s
(OSHA) asbestos construction standard in section K,
“Communication of hazards to employees," specifies
labeling many materials containing 0.1% or more
asbestos. In the mid-1970’s several major kinds of
asbestos materials, such as spray-applied insulation,
fireproofing, and acoustical surfacing material, were
banned by EPA because of growing concern about
health effects, particularly cancer, associated with
exposures to such materials.
In July 1989, EPA promulgated the Asbestos Ban and
Phasedown Rule. The rule applies to new product
manufacture, importation, and processing, and essen-
tially bans almost all asbestos-containing products in
the United States by 1997. This rule does not require
removal of ACM currently in place in buildings.
Where is Asbestos
In February 1988, the
Likely to be Found
EPA released a report
in Buildings?
titled EPA Study of As-
bestos-Containing Ma-
terials in Public Buildings: A Report to Congress. EPA
found that “friable” (easily crumbled) ACM can be
2
found in an estimated 700,000 public and commercial
buildings. About 500,000 of those buildings are believed
to contain at least some damaged asbestos, and some
areas of significantly damaged ACM can be found in over
half of them.
According to the EPA study significantly damaged ACM
is found primarily in building areas not generally
accessible to the public, such as boiler and machinery
rooms, where asbestos exposures generally would be
limited to service and maintenance workers. Friable
ACM, if present in air plenums, can lead to distribution
of the material throughout the building, thereby possi-
bly exposing building occupants. ACM can also be found
in other building locations.
Asbestos in buildings has been commonly used for
thermal insulation, fireproofing, and in various building
materials, such as floor coverings and ceiling tile,
cement pipe and sheeting, granular and corrugated
paper pipe wrap, and acoustical and decorative treat-
ment for ceilings and walls. Typically it is found in pipe
and boiler insulation and in spray-applied uses such as
fireproofing or sound-deadening applications.
The amount of asbestos in these products varies widely
(from approximately 1 percent to nearly 100 percent).
The precise amount of asbestos in a product cannot
always be accurately determined from labels or by
asking the manufacturer. Nor can positive identification
of asbestos be ascertained merely by visual examina-
tion. Instead, a qualified laboratory must analyze
representative samples of the suspect material. Appen-
dix G contains a sample list of some suspect materials.
When is Asbestos
Intact and undisturbed
a Problem?
asbestos materials do
not Dose a health risk.
The mere presence of asbestos in-a building does not
mean that the health of building occupants is endan-
ACM which is in poor
physical condition.
Under a proper oper-
ations and mainte-
nance program, cor-
rective action would
normally prevent
deterioration of the
insulation.
gered. ACM which is in good condition, and is not
somehow damaged or disturbed, is not likely to release
asbestos fibers into the air. When ACM is properly
managed, release of asbestos fibers into the air is
prevented or minimized, and the risk of asbestos-related
disease can be reduced to a negligible level.
However, asbestos materials can become hazardous
when, due to damage, disturbance, or deterioration
over time, they release fibers into building air. Under
these conditions, when ACM is damaged or disturbed–
for example, by maintenance repairs conducted without
proper controls — elevated airborne asbestos concen-
trations can create a potential hazard for workers and
other building occupants.
ACM with sound
structural
integrity
on the exterior of a
domestic hot water
tank. Note that the
insulation jacketing
is intact and there
is no evidence of
disturbance.
3
Chapter Summary
This document, directed to owners and managers of office buildings and similar facilities, should help
lay the ground work for developing and implementing effective operations and maintenance programs.
Major highlights in this section have focused on background information concerning asbestos and
have touched on the current asbestos-in-buildings situation. Important points to remember are the
following:
● Inhalation of asbestos fibers has been shown to
● Asbestos-containing materials (ACM) are reg-
cause asbestosis, lung cancer and meso-
ulated by EPA, OSHA, and the Consumer
thelioma. Much of our knowledge of these
Product Safety Cornmission (CPSC), and indi-
health effects has come primarily from studies
of workers exposed routinely to very high levels
of asbestos in their jobs,
●
● Information health effects of
low-level
asbestos exposure is less certain; custodial/
maintenance workers who sometimes disturb
asbestos as part of their job would benefit from
●
properly executed O&M programs.
● Three of the six naturally occurring asbestos
minerals, chrysotile, amosite, and crocidolite,
have been most commonly used in building
●
products.
● Asbestos became a popular commercial prod-
uct because of its strength, heat resistance,
●
corrosion resistance, and thermal insulation
properties.
vidual state and local agencies.
Friable ACM can be found in about 700,000
public and commercial buildings. Many areas
where asbestos is found are not accessible to
the general public.
Some common uses of asbestos have included
pipe/boiler insulation, spray-applied fireproof-
ing, floor and ceiling tile. cement pipe/sheeting
and paper pipe wrap.
Positive identification of asbestos requires
laboratory analysis; information on labels or
visual examination only is not sufficient.
Intact, undisturbed materials generally do not
pose a health risk; they may become hazardous
when damaged, disturbed, or deteriorated over
time and release fibers into building air.
4
What Is an O&M Program?
Purpose and Scope of an Operations and
Maintenance Program
Purpose of O&M
The principal objective of an O&M program is to minimize exposure of all building occupants to
asbestos fibers. To accomplish this objective, an O&M program includes work practices to (1)
maintain ACM in good condition, (2) ensure proper cleanup of asbestos fibers previously released,
(3) prevent further release of asbestos fibers, and (4) monitor the condition of ACM.
Scope of an O&M Program
An effective O&M program should address all types of
ACM present in a building. ACM that maybe managed
as part of an O&M program in buildings can be
classified in one of the following categories:
1
2
3
Surfacing Material: Examples include
ACM sprayed or troweled onto surfaces, such
as decorative plaster on ceilings or acoustical
ACM on the underside of concrete slabs or
decking, or fireproofing materials on struc-
tural members.
Thermal System Insulation (TSI): Exam-
ples include ACM applied to pipes, boilers,
tanks, and ducts to prevent heat loss or gain,
or condensation.
Miscellaneous ACM: Examples include
asbestos-containing ceiling or floor tiles, tex-
tiles, and other components such as asbestos-
cement panels, asbestos siding and roofing
materials.
The O&M program, when developed and implemented
in a particular facility should include specific direction
on how to deal with each of these general categories of
ACM. Specified O&M work practices and procedures
should be employed by trained personnel during build-
ing cleaning, maintenance, renovation, and general
operational activities that may involve surfacing, ther-
mal, or miscellaneous ACM. Some elaboration of O&M
work practices and procedures is found in Chapter 4.
The O&M program can be divided into three types of
projects
●
●
●
those which are unlikely to involve any direct
contact with ACM;
those which may cause accidental disturbance
of ACM;
those which involve relatively small distur-
bances of ACM.
The first type may involve routine cleaning of shelves
and counter tops or other surfaces in a building
(provided ACM debris is not present). Generally such
An example of spray-
applied surfacing
ACM on a metal deck
above a suspended
ceiling.
An example of as-
bestos-containing
thermal system insu-
lation on pipes in a
building’s mechanical
room.
activities would not be expected to disturb ACM. The
second type of project could include maintenance work
above a suspended ceiling in an area that may have
surfacing ACM overhead. The third type of project—
small-scale, shor-duration maintenance, repair, or
installation projects involving minor disturbances of
ACM – includes activities such as installation of new
light fixtures on or in an ACM ceiling. A single glovebag
operation to remove a small amount of ACM to repair a
pipe in a boiler room is another example of intentional
small-scale, short-duration disturbance.
An example of an
asbestos-containing
cement sheet product
(miscellaneous ACM).
Larger projects involving more complex procedures for
the intentional removal of ACM are considered asbestos
abatement projects. These require asbestos control and
abatement procedures that are outside the scope of an
O&M program. Before taking action, building owners
should consult qualified professionals for advice and
alternative solutions. Guidance for building owners on
the management of abatement projects is included in
EPA’s “Guidance for Controlling Asbestos-Containing
Materials in Buildings” June 1985, also known as the
“Purple Book.”
Chapter-Summary
The purpose of an operations and Maintenance
Program is to minimize exposure of all building
occupants to asbestos fibers. Through super-
vised work practices, ACM can be managed in
place. Important points to remember are:
ACM can be classified into three categories:
● Surfacing Material
● Thermal System Insulation (TSI)
● Miscellaneous Material
O&M Programs can be divided into three types of
project%
● Unlikely to involve direct contact with ACM.
● Accidental disturbance of ACM.
● Small-scale, short-duration maintenance or
repair activity which may involve intentional
disturbance of ACM.
6
How Does the Program Start?
Laying the Foundation for an Effective O&M Program
A comprehensive asbestos control program for a building should include these basic steps:
●
●
●
l
●
Appoint an Asbestos Program Manager and
develop an organizational policy
Conduct a physical and visual inspection of the
building and take bulk samples of suspect
materials to determine if ACM is present,
establish an ACM inventory and assess the
ACM’s condition and potential for disturbance.
If ACM is located, develop an O&M program,
based on the inspection and assessment data.
Implement and manage the O&M program
conscientiously
Select and implement abatement actions other
than O&M when necessary
This chapter provides information about each of these
basic steps. In addition, see Appendix F for a chart of
references outlining existing EPA guidance for each of
these steps.
The Asbestos Program Manager
The position of Asbestos Program Manager (APM) is
frequently held by the building engineer, superinten-
dent, facilities manager, or safety and health director. In
a small organization, the building owner may have this
role. Regardless of who holds this position, EPA stresses
the need for the Asbestos Program Manager to be
properly qualified, through training and experience, and
to be actively involved in all asbestos-control activities.
EPA accreditation under the Asbestos Hazard Emer-
gency Response Act (AHERA) or state certification as a
Building Inspector/Management Planner would be
typical of the requisite training.
If the person selected is not adequately prepared, he or
she should receive the training necessary to develop and
manage an asbestos control program prior to beginning
the job. If for some reason this is not possible, the
building owner should strongly consider hiring a prop-
erly trained, experienced, and credentialed outside
consultant or firm to provide direction to the owner or
the Asbestos Program Manager.
In general, the Asbestos Program Manager should have
the authority to oversee all asbestos-related activities in
the building, including inspections, O&M activities, and
other abatement actions. The Asbestos Program Man-
ager will either train building workers in O&M tech-
niques or ensure that such worker training takes place.
In addition, he or she should oversee the custodial and
maintenance staffs, contractors, and outside service
vendors with regard to all asbestos-related activities.
Building Inspection and
Assessment
To determine whether an asbestos control and manage-
ment program should be implemented, the owner
should have an initial building inspection performed to
locate and assess the condition of all ACM in the
building. A trained, experienced and qualified inspector,
who is able to perform the sampling of suspect ACM for
laboratory analysis, should conduct the inspection. If an
inspection is not performed, then certain suspect
materials should be assumed to contain asbestos, and
treated accordingly (Refer to Appendix G for a sample
list of suspect ACM.)
EPA guidance on how to take “bulk” samples of suspect
ACM is contained in several publications (see Appendix
H) and from EPA Regional Asbestos Coordinators
(listed in Appendix D).
The building inspection by a qualified professional
serves as the basis for establishing an effective overall
plan for dealing with the asbestos in the building. The
inspector should advise the owner and the Asbestos
To determine
whether an
asbestos control
and management
program should
be implemented,
the owner should
have an initial
building
inspection
performed to
locate and assess
the condition of
all ACM in the
building.
7
A properly trained
and protected build-
ing inspector collect-
ing a bulk sample of
suspected asbestos-
containing thermal
system insulation.
program Manager of inspection findings. Of course, the
inspection may show that ACM is not present and that
an asbestos-control program is not required.
If ACM is found, the material’s characteristics, condi-
tion, quantity and location within the building, as well as
building use, will affect how the building owner should
deal with the ACM. For example, operations and
maintenance procedures may be appropriate and suffi-
cient in a particular building for ACM in good condition.
But O&M procedures alone are not sufficient for ACM
that the inspector determines is significantly damaged,
and may not be sufficient for some types of ACM
situated in highly accessible areas; in these instances,
some form of full scale abatement — repair, encapsula-
tion, enclosure, encasement, or removal – will be
necessary Removal of the ACM may also be appropriate
when performed in conjunction with major building
renovations, or as part of long-term building manage-
ment policies (such as staged removal in conjunction
with renovation over the life of the building, as covered
by the EPA NESHAP requirements for removal before
demolition or renovation).
Developing an O&M Program
If ACM is found, the building owner should have an
O&M program developed as soon as possible. Either
the Asbestos Program Manager or a qualified consult-
ant should develop the O&M program. The written
O&M program should state clearly the O&M policies
and procedures for that building, identify and describe
the administrative line of authority for that building, and
should clearly define the responsibilities of key partici-
pants, such as the Asbestos Program Manager and
custodial and maintenance supervisors and staff. The
written O&M program should be available and under-
stood by all participants involved in the management
and operations of the building.
In general, the O&M program developed for a particu-
lar building should include the O&M program elements
discussed in the next chapter. However, the building
owner should make sure that the O&M program
developed is site-specific and tailored for the building.
The O&M program should take into account use,
function, and design characteristics of a particular
building.
Implementing and Managing
an W&M Program
A well-developed O&M program is ineffective unless
the building owner is committed to implementing it
properly The building owner should convey this com-
mitment to key personnel involved in a building’s
management and operations — particularly the As-
bestos program Manager and custodial and mainte-
nance supervisors and staff. The O&M program’s
success is contingent upon key personnel understand-
ing the O&M program and committing themselves to
implementing it effectively
To the greatest extent possible, the building owner
should incorporate the O&M program into the existing
system for managing a building’s operations. Each
building owner, therefore, will determine the appropri-
ate organizational structure on a case-by-case basis.
Two possible arrangements are suggested in Figures 1
and 2 in Appendix C.
When managing an O&M program, the Asbestos
Program Manager should oversee all asbestos-related
activities. In instances where a building owner hires a
contractor to perform custodial and maintenance work,
the Asbestos Program Manager should ensure that the
contractor is qualified to conduct work that may involve
ACM. Before hiring a contractor, the Asbestos Program
Manager should investigate to determine whether the
contractor’s staff is qualified, trained and equipped to
deal with O&M asbestos activities. Thoroughly check-
ing the references of a contractor is a good recom-
mended practice.
The Asbestos Program Manager should also monitor
the work performed in the building by other contrac-
tors, such as electricians and plumbers, who might
inadvertently disturb ACM. Instituting a work permit
system, as discussed in the next chapter, may prevent
accidental disturbances of ACM. Under this system, a
8
contractor must receive a work permit from the
Asbestos Program Manager before commencing work.
At that time, the Asbestos Program Manager will
inform the contractor whether the project could disturb
ACM and provide any special instructions to make sure
the work is done properly Communication between the
Asbestos Program Manager and tenants occupying the
building is essential to prevent activities that might
compromise the O&M program.
In addition, the Asbestos Program Manager should
routinely and frequently check the work being per-
formed in the building by contractors and custodial and
maintenance staff to see if their work is disturbing
ACM. By maintaining close surveillance over these
activities, the Asbestos Program Manager can help
ensure that work which may disturb ACM is being done
safely Tenants should be required (by legal agreement
or understanding) to notify the building owner or the
Asbestos Program Manager before conducting even
small planned renovations. This would help prevent
building tenants from unknowingly disturbing ACM. For
both the work permit system and the renovation
notification requirement, clear and effective communi-
cations to workers and tenants are crucial to the success
of the O&M management program.
The Asbestos Program Manager should periodically
review the written O&M plan to determine whether it
should be updated. For example, if all ACM were
removed from some areas of the building during a recent
renovation, or if some ACM was damaged, the O&M
program should be revised accordingly The O&M
program should remain in effect as long as there is ACM
present in the building.
Cost
The costs associated with
Considerations
implementing and manag-
ing an O&M program may
vary significantly depending on the types-of ACM,
building-specific factors, actual O&M procedures
adopted, types of equipment used, and the useful life of
the building. Owners may find it more cost-effective to
continue a well-supervised and managed O&M pro-
gram than to incur the costs of immediate, large-scale
removal. In addition to the direct costs of removal, other
costs related to ACM removal include moving building
occupants, arranging alternative space for building
occupants during the removal work, and restoring the
building after the removal is completed.
Clearly many factors enter into the decision. Only by
conducting a cost-effectiveness analysis of the long-
term options (e.g., comparing (a) immediate removal
with (b) phased removal plus O&M with (c) removal just
before demolition plus lifetime O&M) will owners be
truly able to determine which option is most cost-
effective for their buildings. The prudent owner may
need to consult one or more qualified consultants or
firms for advice, if such expertise does not exist within
the owner’s organization,
Selecting and Implementing
Alternative Abatement Actions
In some instances, due to the condition of ACM or
upcoming building renovations, a building owner may
decide to take other abatement actions to deal with
ACM in the building. These response actions could
include encapsulation (covering the ACM with a sealant
to prevent fiber release), enclosure (placing an air-tight
barrier around the ACM), encasement (covering the
ACM with a hard-setting sealing material), repair, or
removal of the ACM. Qualified, trained, and experi-
enced contractors should be used for any of these
actions. EPA’s Purple Book discusses most of these
alternatives in some detail. In general, repair, encap-
sulation, enclosure, and encasement, are intended to
help prevent the release of asbestos fibers. As aspects of
O&M, these techniques manage ACM in place. See
Appendix F of this document for additional federal
reference sources on asbestos response actions.
When determining which response alternative to select,
the building owner and Asbestos Program Manager
may consider seeking advice from qualified, independ-
ent consultants with specific training and experience in
asbestos management.
Asbestos consultants should have a background in
engineering, architecture, industrial hygiene, safety, or
a similar field. Experts who are Registered and/or with
Board Certified backgrounds are recommended. To
help ensure that no “conflict of interest” exists,
consultants should not be affiliated with the abatement
contractors who may be used on a recommended ACM
control project, nor with analytical laboratories which
perform sample analyses. As with other similar busi-
ness decisions, building owners should interview sev-
eral consultants and check references.
Renovations (including remodeling or redecorating) of
buildings or replacement of utility system increases the
potential for disturbing ACM. Before conducting any
renovation or remodeling work, the building owner
should have the Asbestos Program Manager review
asbestos inspection and assessment records to deter-
mine where ACM may be located, visually reinspect the
area, and evaluate the likelihood that ACM will be
disturbed. Any suspect or assumed ACM that could be
disturbed during the renovation work should either be
sampled and analyzed to determine whether it contains
asbestos, or the work should be carried out as if the
materials did contain asbestos. The Asbestos Program
Manager should also ensure that no new ACM is
introduced into the building as part of the renovation
work.
Removal of the ACM before renovation begins maybe
necessary in some instances. Removal is required by the
Asbestos NESHAP regulations for projects which
would break up more than a specified minimum amount
of ACM; specifically at least 160 square feet of surfacing
Renovations
(including
remodeling or
redecorating) of
buildings or
replacement of
utility systems
increase the
potential for
disturbing ACM.
9
Asbestos-containing
thermal system insu-
lation which has sus-
tained significant
damage in a mechan-
ical/boiler room of a
building.
or miscellaneous material or at least 260 linear feet of
thermal system insulation (40 CFR 61.145-147). Build-
ing owners and managers are encouraged to contact
their state or local health or environmental department
for further clarification of these requirements (also, see
Chapter 6 of this document). It is important to ensure
that new materials placed in the building do not contain
asbestos in order to comply with the recent EPA
Asbestos Ban and Phase Out rule (see Chapter 6).
In general, building owners should thoroughly consider
any decision to remove ACM. O&M, encapsulation,
encasement, enclosure, or repair may be viable alter-
natives to removal. Building owners should assess
these in-place management techniques carefully before
deciding to remove undamaged ACM.
Under certain circumstances, however, such as when
some ACM must be removed during building renova-
tions, when the ACM has sustained a great deal of
damage, or ACM disturbance will be difficult to manage
properly the building owner may decide to remove ACM
in parts of the building.
When removal must occur, only qualified, trained and
experienced project designers and contractors should
be permitted to design and perform the work. Building
owners might consider contacting local, state, and
federal asbestos regulatory agencies to see if prospec-
tive contractors have received citations for violating
asbestos regulations in the past. In addition, if the
building owner and Asbestos Program Manager are not
properly qualified themselves, they should retain a
qualified and independent project designer and a project
monitor with training and experience in asbestos
abatement to oversee and ensure that the asbestos
abatement work is done safely. When these precautions
are taken, asbestos removal is more likely to proceed
safely and effectively
Proper completion of the ACM removal is best evalu-
ated by means of the analytical procedures using
transmission electron microscopy (TEM). (These are
described in 40 CFR Part 763, Appendix A to Subpart
E.) Clearance protocols for statistically comparing
asbestos fiber levels inside the work area with outside
levels are available. If the measured levels inside are not
statistically higher than the average airborne asbestos
concentration measured outside the abatement area,
the cleanup is considered successful, and the space is
judged ready for reoccupancy (For reference, see
Appendix H, U.S. EPA “Guidelines for Conducting the
AHERA TEM Clearance Test . . . .")
10
Chapter Summary
Laying the foundation for a comprehensive asbestos control program for a building includes some
basic steps. Important points contained in this discussion are the following
An Asbestos Program Manager needs to be
properly qualified through training and experi-
ence, and be actively involved in all asbestos
control and disturbance activities.
An Asbestos program Manager should have
authority to oversee and to direct custodial/
maintenance staff and contractors with regard
to all asbestos-related activities.
An initial building inspection should be per-
formed by a trained, qualified, experienced
inspector to locate and assess the condition of
all ACM in the building.
The inspection results serve as the basis for
establishing an O&M program. O&M pro-
cedures may not be sufficient for certain ACM
that is significantly damaged or in highly
accessible areas.
An Asbestos Program Manager or qualified
consultant should develop the written O&M
program that is site-specific and tailored for
individual buildings. The O&M program
should take into account use, function and
design characteristics of a building.
The success of any O&M program lies in the
commitment by the building owner to imple-
ment it properly
When outside contractors are used for as-
bestos-related activities, their references and
training should be thoroughly checked and
their subsequent work monitored.
Periodically review written O&M programs.
Alternatives or control options that may be
implemented under an O&M program include:
● repair
l encapsulation
● enclosure
● encasement
● removal (minor)
Removal of ACM before renovations may be
necessary in some instances. (See NESHAP
and State/Local regulations discussion in
Chapter 6.)
The success
of any O&M
program
depends on the
building owner’s
commitment to
implement it
properly.
11
What Does an O&M Program
Include?
O&M Program Elements
To achieve its objectives, an O&M program should include seven elements. Although these should
appear in any O&M program, the extent of each will vary from program to program depending on
the building type, the type of ACM present, and the ACM’s location and physical condition. For
example, if only nonfriable ACM is present, minimal notification might be needed, and custodial or
maintenance staff would most likely have fewer work practices to be followed. If friable ACM is
present, a more detailed O&M program should be prepared and followed. Each of the first six
elements listed below is described in this chapter to provide an illustration of a basic O&M program.
The seventh program element, training of the Asbestos Program Manager and custodial and
maintenance staff, is very important. If staff are not adequately trained, the O&M program will not
be effective. Chapter 5 is devoted exclusively to O&M training topics.
●
●
●
●
●
●
●
Informing Building Workers,
Tenants, and Other Occupants
Building owners should inform building workers, occu-
pants, and tenants about the location and physical
condition of the ACM that they might disturb, and stress
the need to avoid disturbing the material. Occupants
should be notified for two reasons: (1) building occu-
pants should be informed of any potential hazard in their
vicinity; and (2) informed persons are less likely to
unknowingly disturb the material and cause fibers to be
released into the air.
Building owners can inform occupants about the
presence of ACM by distributing written notices,
posting signs or labels in a central location where
affected occupants can see them, and holding aware-
ness or information sessions. The methods used may
depend on the type and location of the ACM, and on the
number of people affected. Some states and localities
have “right-to-know” laws which may require that all
occupants, workers, and visitors in buildings with ACM
be informed that asbestos is present.
In service and maintenance areas (such as boiler
rooms), signs such as “Caution — Asbestos — Do Not
Disturb” placed directly adjacent to thermal system
insulation ACM will alert and remind maintenance
A successful O&M program should include the follow-
ing elements:
Notification: A program to tell workers,
tenants, and building occupants where ACM is
located, and how and why to avoid disturbing
the ACM. All persons affected should be
properly informed.
Surveillance: Regular ACM surveillance to
note, assess, and document any changes in the
ACM’s condition.
Controls: Work control/permit system to
control activities which might disturb ACM.
Work Practices: O&M work practices to
avoid or minimize fiber release during activities
affecting ACM.
Recordkeeping: To document O&M activ-
ities.
Worker Protection: Medical and respiratory
If staff are
not adequately
trained, the O&M
program will not
be effective.
protection programs, as applicable.
Training: Asbestos Program Manager,
custodial and maintenance staff training.
and
1 2
workers not to inadvertently disturb the ACM. In most
cases, all boilers, pipes, and other equipment with ACM
in service areas where damage may occur should have
prominent warning signs placed next to the ACM. As an
alternative, color coding can be used to identify the
ACM in certain situations provided that all potentially
involved parties understand the coding system.
Information sessions reinforce and clarify written
notices and signs, and provide an opportunity to answer
questions. All employees and tenants or tenant repre-
sentatives likely to disturb ACM should be included in
the notification program on a continuing basis. Building
owners should inform new employees about the pres-
ence of ACM before they begin work. Owners should
provide additional signs and information sessions in
languages other than English where a significant
number of workers, occupants, or visitors do not speak
English. It maybe necessary to make special provisions
for illiterate workers, such as providing clear verbal
information or signs, about potential hazards of disturb-
ing ACM. and showing them where ACM is located.
The specific information given to types of building
occupants will vary For example, since service workers
carry out certain tasks that office workers or tenants do
not perform, they should receive additional informa-
tion. Most important, O&M workers should receive the
training necessary for them to perform their tasks
safely
Whatever its form, the information given to building
occupants and workers should contain the following
points to the extent they reflect building conditions:
●
●
●
●
●
●
ACM has been found in the building and is
located in areas where the material could be
disturbed.
The condition of the ACM, and the response
which is appropriate for that condition.
Asbestos only presents a health hazard when
fibers become airborne and are inhaled. The
mere presence of ACM does not represent a
health hazard.
The ACM is found in the following locations
(e.g., ceilings in Rooms 101 and G-323, walls in
the lobby, above suspended ceilings in the first
floor corridor, on columns in the main entry on
pipes in the boiler room).
Do not disturb the ACM (e.g., do not push
furniture against the ACM, do not damage
T S I ) .
Report any evidence of disturbance or damage
of ACM to (name, location, and phone number
of Asbestos Program Manager).
●
●
●
tional measures will be taken if needed to
protect the health of building occupants.
Routine maintenance
activities can cause
disturbance of ACM if
workers are not prop-
erly trained in opera-
tions and mainte-
nance procedures.
Here, a worker care-
lessly contacts ACM,
possibly damaging it.
Report any dust or debris that might come
from the ACM or suspect ACM, any change in
the condition of the ACM, or any improper
action (relative to ACM) of building personnel
to (name, location, and phone number of
Asbestos Program Manager).
Cleaning and maintenance personnel are tak-
ing special precautions during their work to
properly clean up any asbestos debris and to
guard against disturbing ACM.
All ACM is inspected periodically and addi-
It is important to undertake an honest and open
approach to the ACM notification procedure. Owners
should strive to establish clear lines of communication
with all building occupants regarding asbestos issues.
People who are informed of the presence, location and
condition of ACM in a building where they work or live,
who understand that the mere presence of ACM is not
necessarily hazardous to them, and who accept that
ACM can often be managed effectively in place, can be
An example of an
asbestos caution sign
placed directly on a
section of asbestos-
containing duct insu-
lation. Signs such as
this help to ensure
that workers will not
inadvertently disturb
ACM.
13
Visual reinspections
of asbestos materials
at regular intervals
can detect changes in
material condition.
Here, surfacing ACM
has delaminated from
a ceiling in a building
O&M routines can
keep small problems
from becoming big
problems.
very helpful to the owner in eliminating or reducing
hysteria on the part of other less informed building
occupants. On the other hand, if occupants suspect the
building owner is not being honest about asbestos
activities in the building, that owner’s credibility maybe
questioned and the situation can become far more
difficult to manage. If and when asbestos incidents
occur, it is especially important for the building owner
to deal with occupants and contractors openly and
honestly, for that is the best way to maintain occupant/
tenant confidence in both the owner and the building's
asbestos program.
ACM Surveillance
Reinspection and
A visual reinspection
Periodic Surveillance
of all ACM should be
conducted at regular
intervals as part of the O&M program. Combined with
ongoing reports of changes in the condition of the ACM
made by service workers, the reinspection should help
ensure that any ACM damage or deterioration will be
detected and corrective action taken.
According to recent EPA regulations covering schools
(the Asbestos Hazard Emergency Response Act,
“AHERA”), an accredited inspector must reinspect
school buildings at least once every three years to
reassess the condition of ACM. The AHERA regula-
tions for schools also require a routine surveillance
check of ACM every six months to monitor the ACM’s
condition. The AHERA Rule permits this surveillance
to be conducted by a trained school custodian or
maintenance worker. While these intervals are men-
tioned here as a guide, they may also be appropriate for
other buildings. The Asbestos Program Manager
should establish appropriate intervals, based on consul-
tation with the building owner and any other qualified
professionals involved in the O&M program.
EPA recommends a visual and physical evaluation of
ACM during the reinspection to note the ACM’s
current condition and physical characteristics. Through
this reinspection, it is possible to determine both the
relative degree of damage and assess the likelihood of
future fiber release. Maintenance of a set of visual
records (photos or videotape) of the ACM overtime can
be of great value during reinspection.
Some asbestos consultants recommend examining set-
tled dust for accumulations of asbestos fibers as another
surveillance tool in an O&M program. While no
universally accepted standardized protocols currently
exist for sampling and analysis of settled dust, positive
results (i.e., ACM is present in the dust) may indicate
the need for special cleaning of the affected area, or
other action. Because the results of this testing are
difficult to interpret and evaluate at this time, building
owners should carefully consider the appropriateness of
this testing to their situation.
Supplement to
As part of an O&M pro-
Visual/Physical
gram, a carefully designed
Evacuation
air monitoring program to
detect airborne asbestos fi-
bers in the building may provide useful supplemental
information when conducted along with a comprehen-
sive visual and physical ACM inspection and reinspec-
tion program. If the ACM is currently in good condition,
increases in airborne asbestos fiber levels at some later
time may provide an early warning of deterioration or
disturbance of the material. In that way, supplemental
air monitoring can be a useful management tool. If an
owner chooses to use air monitoring in an “early
warning” context, a knowledgeable and experienced
individual should be consulted to design a proper
sampling strategy Appendix H contains a reference to a
useful guide to monitoring airborne asbestos, which can
be consulted for further discussion of this subject.
If supplemental air monitoring is done, a baseline
airborne asbestos fiber level should be established soon
after the O&M program is initiated Representative,
multiple air samples should be collected throughout the
building during periods of normal building operation.
This should be done over along enough period of time to
be representative of existing conditions, in order to
adequately characterize prevailing fiber levels in the
building. This air monitoring should supplement, not
replace, physical and visual inspection. Visual inspec-
tion can recognize situations and anticipate future
exposure (e.g., worsening water damage), whereas air
monitoring can only detect a problem after it has
occurred, and fibers have been released.
Note that the collection of air samples for supplemen-
tary evaluation should not use aggressive air sampling
methods. Aggressive sampling methods, in which air is
deliberately disturbed or agitated by use of a leaf blower
or fans, should be used at the completion of an asbestos
removal project when the building or area is unoc-
14
cupied, not for routine monitoring.
The most accurate and preferred method of analysis of
air samples collected under an O&M program would
require the use of transmission electron microscopy
(TEM). Phase contrast microscopy (PCM), which is
commonly used for personal air sample analysis and as a
screening tool for area air monitoring, cannot distin-
guish between asbestos fibers and other kinds of fibers
which may be present in the air. PCM analysis also
cannot detect thin asbestos fibers, and does not count
short fibers. TEM analysis is approximately ten times
more expensive than PCM analysis. However, the more
accurate information on actual levels of airborne
asbestos fibers should be more beneficial to the building
owner who elects to use supplemental air monitoring in
the asbestos management program. TEM analysis is
most reliably performed by laboratories accredited by
the National Institute for Standards and Technology
(NIST; see Appendix D for telephone number), and who
follow EPA's quality assurance guidelines. (Appendix H,
U.S. EPA, Dec. 1989, “Transmission Electron Micro-
scopy Asbestos Laboratories: Quality Assurance
Guidelines.”)
Selection of a reliable and experienced air monitoring
firm and analytical laboratory is important, if the
building owner elects to conduct supplemental air
monitoring under the O&M program. A consultant
knowledgeable in air sampling and analysis protocols
can be contacted for recommendations if the building
owner or Asbestos Program Manager has limited
knowledge in this area.
Periodic air monitoring, conducted simultaneously with
the visual reinspection or surveillance, would then be
used to see if asbestos levels have changed relative to the
baseline. Some building owners may wish to present
current air monitoring results to building occupants in
addition to information regarding the physical reinspec-
tions. Although this supplemental use of air monitoring
as part of an O&M program may provide useful
information, it is likely to be very expensive, particularly
if the more accurate and recommended TEM analysis is
used. Use of only a small number of measurements or
measurements taken only at one time maybe mislead-
ing (i.e., overestimate or underestimate of fiber levels),
and can lead to inappropriate decisions.
It should be noted that some of the exposures of persons
to airborne asbestos fibers in buildings may result from
episodic events, such as repair work or the accidental
disturbance of the ACM or of ACM debris by mainte-
nance activities inside the building. Air monitoring may
not be done frequently enough to include such episodic
events; this can lead to a misleading interpretation of air
sampling results. In particular, air sampling may under-
estimate the exposure of O&M workers and building
occupants. A good reference sourcebook for additional
information on air sampling and analysis for asbestos
fibers is “A Guide to Monitoring Airborne Asbestos in
Buildings” (see Appendix H).
Work Control/Permit System
The O&M program should include a system to control
all work that could disturb ACM. Some building owners
have had success using a “work permit” program, which
requires the person requesting the work to submit a Job
Request Form to the Asbestos program Manager
(Appendix B, Form 2) before any maintenance work is
begun. The form gives the time and location of the
requested work, the type of maintenance needed, and
available information about any ACM in the vicinity of
the requested work. The contractor or other person
authorized to perform the work should be identified on
the work request.
Upon receiving a pre-work Job Request Form, the
Asbestos Program Manager should take the following
steps:
1
2
3
4
Refer to written records, building plans and
specifications, and any building ACM inspec-
tion reports to determine whether ACM is
present in the area where work will occur. If
ACM is present, but it is not anticipated that
the material will be disturbed, the Asbestos
Program Manager should note the presence
of the ACM on the permit form and provide
additional instruction on the importance of
not disturbing the ACM.
If ACM is both present and likely to be
disturbed, the Asbestos Program Manager or
a designated supervisor qualified by training
or experience, should visit the site and
determine what work practices should be
instituted to minimize the release of asbestos
fibers during the maintenance activity
This determination should be recorded on the
Maintenance Work Authorization Form (see
example in Appendix B, Form 3), which is
then sent to the in-house maintenance super-
visor or to the maintenance contractor to
authorize the work.
The Asbestos Program Manager should
make sure that a copy of both the request and
the authorization forms (if granted) are placed
in the permanent file.
An example of a
maintenance worker
conducting activities
near a friable
asbestos-containing
ceiling. Under a
proper permitting
system, the building
Asbestos Program
Manager would
evaluate and
authorize projects
such as this prior to
beginning work.
1 5
5
6
7
8
It is important
to undertake an
honest and open
approach in ACM
notification.
Where the task is not covered by previously
approved standard work practices, the As-
bestos Program Manager should make sure
that the appropriate work practices and
protective measures are used for the job.
For all jobs where contact with ACM is likely
the Asbestos Program Manager or a desig-
nated supervisor qualified by training or
experience should visit the work site when
the work begins to see that the job is being
performed properly For lengthy jobs where
disturbance of ACM is intended or likely,
periodic inspections should be made for the
duration of the project.
The Asbestos Program Manager’s observa-
tions should be provided on an Evaluation of
Work Form (see Appendix B, Form 4). Any
deviation from standard and approved work
practices should be recorded immediately on
this form and the practices should be imme-
diately corrected and reported to the Asbestos
Program Manager.
Upon completion of the work, a copy of the
evaluation form should be placed in the
permanent asbestos file for the building.
Building owners should consider using asbestos O&M
work control forms similar to those which already may
be in use for non-ACM work in their facilities, or
expanding the existing forms to include the content of
the request, approval, and evaluation forms illustrated in
Appendix B.
The O&M management system should also address
work conducted by outside contractors. Many building
owners contract for at least some custodial and mainte-
nance services. A building’s asbestos work control/
permit system, as described above, should also cover
contract work.
At a minimum, contracts with service trades or
abatement companies should include the following
provisions to ensure that the service or abatement
workers can and will follow appropriate work practices:
●
●
●
Proof that the contractor’s workers have been
properly notified about ACM in the owner’s
building and that they are properly trained and
accredited (if necessary) to work with ACM.
Copies of respiratory protection, medical sur-
veillance, and worker training documentation
as required by OSHA, EPA and/or state regula-
tory agencies.
Notification to building tenants and visitors
that abatement activity is underway (per-
formed by owner).
●
●
●
●
●
●
●
Written work practices must be submitted by
the vendor or contractor for approval or
modification by the Asbestos Program Man-
ager. The vendor or contractor should then
agree to abide by the work practices as finally
accepted by the Asbestos Program Manager.
Assurance that the contractor will use proper
work area isolation techniques, proper equip-
ment, and sound waste disposal practices.
Historical air monitoring data for representa-
tive examples of the contractor’s previous
projects, with emphasis on projects similar to
those likely to be encountered in the building.
Provisions for inspections of the area by the
owner’s representative to ensure that the area
is acceptable for re-entry of occupants/ten-
ants.
A resume for each abatement contractor/
supervisor or maintenance crew chief, known
as the “competent person” in the OSHA
standard and EPA Worker Protection Rule.
Criteria to be used for determining successful
completion of the work (i.e., visual inspections
and air monitoring).
Any other information deemed necessary by
the owner’s legal counsel.
Notification to EPA (and other appropriate
agencies) if the abatement project is large
enough (see Chapter 6).
O&M Work Practices
●
1
2
3
The O&M program focuses on a special set of
work practices for the custodial, maintenance,
and construction staff. The nature and extent
of any special work practices should be tailored
to the likelihood that the ACM will be disturbed
and that fibers will be released. In general, four
broad categories of O&M work practices are
recognized
Worker Protection Programs – These
work practices help ensure custodial and
maintenance staff are adequately protected
from asbestos exposure.
Basic O&M Procedures – Basic pro-
cedures are used to perform routine custodial
and maintenance tasks that may involve ACM.
Special O&M Cleaning Techniques –
Special techniques to cleanup asbestos fibers
on a routine basis.
1 6
4 Procedures for Asbestos Fiber Release
Episodes – If moderate to relatively large
amounts of ACM are disturbed, the building
owner should use these procedures to address
the hazard.
A brief synopsis of worker protection and O&M work
practices follows. (Note: A more detailed, technically
oriented O&M “work practices” manual specifically
addressing topics such as work practices, worker
protection, and specific information on how to carry
out O&M plans, is being developed, with publication
expected in 1991.)
Worker Protection
A worker protection
Programs
program includes engi-
neering controls, per-
sonal exposure monitoring, medical surveillance, and
personal protection. While engineering controls are the
preferred method of worker protection, there are few
engineering control options available for O&M work.
This section discusses two key aspects of personal
protection: use of respiratory protection and protective
clothing for workers in an asbestos O&M program.
According to OSHA regulations (see Chapter 6), a
written respiratory protection program is necessary
whenever an O&M program specifies that service
workers wear respirators, or where respirators are
made available to employees. OSHA regulations also
require a respirator program whenever workers are
exposed, or are likely to be exposed, to fiber levels above
OSHA’S “permissible exposure limits” such as the
8-hour time weighted average (TWA) limit or the 30-
minute “excursion limit” (EL). The 8-hour TWA limit
and the EL are described in more detail in Chapter 6. In
addition, OSHA requires workers to wear special
protective clothing under the same circumstances.
Respiratory Protection/Worker Protection Pro-
grams The selection of approved respirators, suitable
for the hazards to which the worker is exposed, is only
one aspect of a complete respiratory protection pro-
gram. Other elements include written operating pro-
cedures for respirator use; outlining personnel respon-
sibilities for respirator cleaning, storage, and repair;
medical examination of workers for respirator use;
training in proper respirator use and limitations;
respirator fit testing respirator cleaning and care; and
work-site supervision. All of these are described in
detail in the OSHA respirator standard, 29 CFR
1910.134. The O&M respirator program can be admin-
istered by the facility safety and health manager or the
Asbestos Program Manager, if properly qualified.
Proper respiratory protection is an integral part of all
custodial and maintenance activities involving potential
exposure to asbestos. When in doubt about exposure
during a certain work operation, building owners should
provide respiratory protection to custodial and mainte-
nance workers. OSHA specifies general types of
respirators for protection against airborne asbestos
during “construction” activities, which include abate-
ment, renovation, maintenance, repair, and remodeling.
Personal air sampling is not the same as area air
monitoring. Personal air sampling (required by OSHA)
is designed to measure an individual worker’s exposure
to fibers while the worker is conducting tasks that may
disturb ACM. The sampling device is worn by the
worker and positioned so that it samples air in the
worker’s breathing zone. In contrast, area (or ambient)
air sampling is conducted to get an estimate of the
numbers of airborne asbestos fibers present in a
building. It is used as an assessment tool in evaluating
the potential hazard posed by asbestos to all building
occupants. (See the previous discussion of area air
monitoring on page 14.)
When adequate care is taken to prevent or minimize and
control fiber release, routine, small-scale/short-dura-
tion maintenance or custodial tasks are not likely to
generate high levels of airborne asbestos compared to
large asbestos removal projects; and respirators which
filter breathing air may be used. OSHA, EPA, and
NIOSH are on record as not recommending
single use, disposable paper dust masks for use
against asbestos; in fact, OSHA has disallowed
their use against airborne asbestos fibers.
The options that may be used include:
● A half-face or full facepiece, negative pressure,
air-purifying respirator with replaceable high-
efficiency filters.
Pictured below are
different examples of
air-purifying, negative
pressure respirators
equipped with high-
efficiency cartridges
which can be used to
protect workers
against asbestos
exposure. On the left
are examples of half-
mask facepieces
equipped with high-
efficiency cartridges,
and on the right are
examples of full
facepiece, high-
efficiency masks.
1 7
● A half or full facepiece powered air-purifying
respirator (PAPR) with replaceable high-effi-
ciency filters. This has a battery powered pump
which assists breathing and provides positive
pressure in the facepiece.
Pictured above are
two different types of
powered air-purifying
respirators (PAPR's)
equipped with high-
efficiency filters. On
the left is an example
of a tight fitting, full
facepiece PAPR, and
on the right is an
example of a loose-
fitting helmet style
PAPR.
Under the OSHA standards for asbestos, any employee
required to wear a negative pressure respirator can
request a powered air-purifying respirator, and the
employer is required to provide a fully functional and
approved unit, provided it will afford the worker at least
equal protection.
Currently only respirators approved by NIOSH and the
Mine Safety and Health Adminstration (MSHA) are
permitted for use. If they are air-purifying respirators,
the filtration device(s) must be rated as “high-effi-
ciency”
Selecting the most appropriate respirator for each
O&M task requires knowledge of the levels of airborne
asbestos fibers and other possible air contaminants
generated by the task or likely to be present where the
task is performed. This knowledge is best gained
through personal air monitoring conducted during
worker performance of the actual task. (Obviously the
workers must have respiratory protection while this
initial personal air sampling is carried out.) In fact,
OSHA and EPA require air monitoring under certain
circumstances (see Chapter 6). To learn more about the
different types of respirators available and the degree of
protection they provide, see Appendix E. Owners may
also wish to contact the nearest OSHA office, a local
trained and qualified industrial hygienist (preferably
Certified), or an occupational health professional for
more information on respirators. The expertise of these
specialists should be used to ensure proper selection, fit
testing, and training of workers in respirator use.
Building owners and other facility managers may not be
familiar with some of the terms used in discussions of
respirators, airborne fiber levels, and related topics.
Appendix E contains more information on these topics,
and gives the minimum EPA-recommended levels of
respiratory protection to be provided during typical
O&M tasks.
For additional information on respirator programs,
respirator types, and respirator use, the building owner
or Asbestos Program Manager may want to use the
following references
● “Respiratory Protection An Employer’s Man-
ual,” NIOSH, October 1978;
● “A Guide to Respirator Protection for the
●
●
●
●
●
Asbestos Abatement Industry” EPA/NIOSH,
1986;
OSHA respirator standard (29 CFR
1910.134);
OSHA asbestos regulations (29 CFR
1910.1001 and 1926.58);
“Occupational Exposure Sampling Strategy
Manual; NIOSH #77-173, January 1977.
“Respirator Decision Logic," NIOSH, May
1987; and
“NIOSH Guide to Industrial Respiratory Pro-
tection” September 1, 1987.
Protective Clothing/Worker Protection Pro-
grams In addition to the use of respirators, some O&M
procedures may require workers to wear protective
clothing. Most often, protective clothing is disposable
and consists of coveralls, a head cover, and foot covers
made of a synthetic fabric which does not allow asbestos
fibers to pass through. This type of clothing prevents
workers’ regular clothing from becoming contaminated
with asbestos fibers. Contaminated clothing could be
taken home, creating a possible risk to the worker’s
family members.
OSHA and EPA regulations require workers to wear
protective clothing whenever they are exposed, or likely
to be exposed, to fiber levels above OSHA’s permissible
levels (see Chapter 6). It is important that workers be
properly trained in the use, removal and disposal of
protective clothing after use. All O&M activities may
not require the use of protective clothing. It is important
for the Asbestos Program Manager to assess this need
on a case-by-case basis.
Basic O&M
Basic O&M procedures to mini-
Procedures
mize and/or contain asbestos fi-
bers may include wet methods,
use of mini-enclosures, use of portable power tools
equipped with special local ventilation attachments, and
avoidance of certain activities, such as sawing, sanding,
18
and drilling ACM. Maintenance activities can be divided
into three categories with regard to their potential for
disturbing ACM:
1 Those which are unlikely to involve any direct
disturbance of ACM; for example, cleaning
shelves or counter tops with a damp cloth.
2 Those which may cause accidental distur-
bance of ACM; for example, working on a
fixture near a ceiling with surfacing ACM.
3 Those which involve intentional small-scale
manipulation or disturbance of ACM; for
example, removing a small segment of TSI
ACM to repair a pipe leak.
The O&M program should include work practices for
each type of ACM that is present in the building
(surfacing, TSI, and miscellaneous) as well as for each
type and category of maintenance activity performed
(e.g., general cleaning, electrical work, plumbing).
Special work practices such as wet wiping, area
isolation, and HEPA vacuuming, and the use of personal
protective equipment such as respirators and protective
clothing, may be needed where disturbance of ACM is
likely. The need for these practices varies with the
situation. For example, removing light fixtures located
near surfacing ACM may disturb the material and might
involve the use of special cleaning, possibly area
isolation, and respiratory protection. Periodic emptying
of a trash can near heavily encapsulated asbestos-
containing plaster may not disturb the material at all, so
no special work practices would generally be necessary
These work practices and procedures are intended to
ensure that disturbance of any ACM during O&M
activities should be minimized, or carried out under
controlled conditions when the disturbance is required
by the nature of a specific O&M task.
In addition, ACM may readily release asbestos fibers
into the air when certain mechanical operations are
performed directly on it. For example, fiber releases can
occur when workers are drilling, cutting, sanding,
breaking, or sawing vinyl asbestos floor tile.
The action of drilling, cutting, abrading, sanding,
chipping, breaking, or sawing is the critical factor here,
since it is likely to cause a release of fibers. Maintenance
or repair operations involving those actions should be
eliminated or carefully controlled with basic O&M
procedures in order to prevent or minimize asbestos
fiber release.
Certain activities that occur in the vicinity of ACM can
also cause damage which may result in asbestos fiber
release. For example, maintenance and custodial stroll
may damage ACM accidentally with broom handles,
ladders, and fork lifts while performing other tasks.
Activities performed in the vicinity of ACM should
always be performed cautiously to prevent fiber release.
To summarize, if in doubt about the possibility of
disturbing ACM during maintenance activities, ade-
quate precautions should be taken to minimize fiber
release; these will protect workers as well as the
building environment. Basic O&M procedures, includ-
ing use of wet methods and specially equipped tools,
should be used to protect building occupants.
O&M Cleaning
Special cleaning practices
Practices
are appropriate for a building
with exposed surfacing or
thermal system insulation ACM, especially if the ACM
is friable. If gradual deterioration or damage of ACM has
occurred or is occurring, asbestos-containing dust or
debris could be present. If the building inspection has
determined that asbestos-containing dust or debris is
present in some areas, then the O&M program should
include special cleaning practices to collect residual
asbestos dust. Routinely cleaning floors using wet
methods is an example of one such practice. Custodial
and maintenance workers in the course of normal work
can also identify and report areas which are in need of
special cleaning or repair. Special cleaning techniques
should supplement, not replace, repair or abatement
actions for damaged, friable ACM. The cleaning
program should include an initial cleaning followed, as
needed, by subsequent periodic or episodic cleanings.
Building owners and custodial and maintenance staff
should ensure that special O&M cleaning is done
correctly Proper cleaning is important for two reasons:
●
●
The use of improper techniques to clean up
asbestos debris caused by previous deteriora-
tion or damage may result in widespread
contamination, and potentially increase air-
borne asbestos fiber levels in the building.
Improper cleaning may cause damage to the
ACM, thus releasing more airborne asbestos
fibers.
O&M cleaning will involve the use of wet
cleaning or wet-wiping practices to pick up asbestos
fibers. Dry sweeping or dusting can result in asbestos
fibers being re-suspended into the building’s air and
therefore should not be used. Once wet cloths, rags, or
mops have been used to pickup asbestos fibers, they
should be properly discarded as asbestos waste while
still wet. They should not be allowed to dry out, since
the collected fibers might be released at some later time
when disturbed. The use of special vacuum cleaners,
commonly referred to as HEPA vacuums, may be
preferable to wet cleaning in certain situations. These
vacuums are equipped with filters designed to remove
very small particles or fibers — such as asbestos — by
filtering those particles from the air passing through the
vacuum. Since the exhaust air from an ordinary vacuum
cleaner is not filtered sufficiently it is possible for tiny
asbestos fibers to pass through the filter and back into
the building air.
If in doubt about
the possibility
of disturbing
ACM during
maintenance
activities,
adequate
precautions
should be taken
to minimize
fiber release.
1 9
Special
procedures are
generally needed
to minimize the
spread of fibers in
the building after
asbestos fiber
release occurs.
Here, a worker uses
a HEPA vacuum
(backpack type) to
clean ACM debris
from one of several
carpeted areas in a
room where surfacing
material had fallen.
It is important for O&M workers to use caution when
emptying HEPA vacuums and changing the filters.
Exposures could result from such activities. Workers
should move the HEPA vacuum to a physically isolated
area of the facility and put on proper personal protective
equipment before emptying the dust and debris into
properly labeled, sealed, and leak-tight containers for
disposal as asbestos-containing waste. When custodial
workers do not work with ACM, trained maintenance
workers can be used to empty the HEPA vacuums and
change their filters. Decisions regarding special clean-
ing practices should be based on the building inspection
and ACM assessment data, including the potential for
ACM disturbance. In general, the building would not
need special O&M cleaning when the building contains
only nonfriable (not easily crumbled) ACM; ACM which
has been encapsulated, encased, or enclosed behind air-
tight barriers; or ACM known to be undamaged/
undisturbed since the last special cleaning. Further-
more, where ACM is confined to a single room or area,
special cleaning of just that area rather than other parts
of the building may be sufficient.
If ACM has been released onto a carpeted area of a
building, it may not always be possible to adequately
clean the carpeted area. “Steam" cleaning and HEPA
vacuuming methods are sometimes employed for this
purpose. A preliminary study carried out by EPA in
1989 showed that hot water vacuums were more
effective in carpet cleaning than HEPA vacuums, under
the test conditions. Further field studies are planned to
confirm these findings.
For carpets, successful cleaning will likely depend on
factors such as the amount of ACM released onto the
carpet, how long the situation has existed, traffic over
the area, as well as the structure and composition of the
carpet itself. It is prudent to evaluate individual
situations on a case-by-case basis. The Asbestos
program Manager should consider the need for workers
engaged in cleaning asbestos fiber-contaminated car-
pets to wear proper respiratory protection. It may also
be prudent to arrange for this type of cleaning to be
done after normal working hours or when the facility is
less occupied. Additionally it maybe more cost effective
to properly dispose of contaminated carpets and other
fabrics as asbestos-containing waste if a permanent
asbestos control option is being undertaken in the
building.
Where the ACM is damaged and located in an “air
plenum” – where fibers can be transported by the
heating, ventilation, or air conditioning (HVAC) system
throughout the building – special cleaning practices
may be extended to the entire building, including the
HVAC system itself.
Procedures for
Special procedures are
Asbestos Fiber
generally needed to rnin-
Release Episodes
imize the spread of fibers
throughout the building
after asbestos fiber releases occur, such as the partial
collapse of an ACM ceiling or wall. These procedures
are needed whether the ACM disturbance is intentional
or unintentional To provide building owners with some
guidance, under EPA regulations for schools a “major
fiber release” is defined as one involving more than
three square or linear feet of ACM. The procedures to
be followed will vary according to the site of the major
release episode, the amount of ACM affected, the
extent of fiber release from the ACM, the relationship of
the release area to the air handling systems, and
whether the release site is accessible to building
occupants. Depending on the severity of the episode,
asbestos abatement consultants and contractors may be
needed to develop a strategy for conducting the clean-
up operations.
In general, for major fiber releases, the area should be
isolated by closing doors and/or erecting temporary
barriers to restrict airflow as well as access to the site.
Signs should be posted as necessary immediately
outside the fiber release site to prevent persons not
involved in the cleanup operation from inadvertently
entering the area. If asbestos fibers could enter the
HVAC system, the system should be modified to prevent
fiber entry, or should be shut down and sealed off. The
final step should be to employ thorough cleanup
procedures to properly control the ACM, a careful visual
inspection, and final clearance air monitoring to verify
satisfactory cleanup.
Similar procedures can be used for much smaller fiber
release events: where the amount of ACM is on the
2 0
order of three square or linear feet or less. The HEPA
vacuuming, wet wiping, and worker protection pro-
cedures outlined in this guidance document, as well as
wetting ACM wastes and properly placing them in an
appropriate leak-tight container (such as a properly
labeled, 6-mil-thick plastic bag), are examples of some of
the procedures which could be used for both major and
minor fiber releases.
It is important to recognize that different levels of
training are needed for workers involved with fiber
release episodes. A major release will generally require
“asbestos abatement worker training,” rather than the
degree of training considered adequate for O&M
workers.
EPA suggests that building owners and Asbestos
Program Managers consult with state and local regula-
tory officials before establishing formal training pro-
cedures for each type of situation.
The following table should be useful in determining
when to apply certain O&M work practices in buildings.
The table illustrates the O&M work practices that
should be used by custodial and maintenance staff,
depending on the likelihood of ACM disturbance.
Summary of When to Apply Key O&M Work Practices
Likelihood of ACM Disturbance
Accidental Disturbance
Disturbance
Contact Unlikely
Possible
Intended or Likely
Management Responsibilities
Need Pre-Work Approval from Asbestos
Review by Program
Yes
Yes
Program Manager
Manager
Special Scheduling or Access Control
No
Yes
Yes
Supervision Needed
No
Initial, At Least
YES
HVAC System Modification
None
As Needed1
Shut Downl
Area Containment
None
Drop cloths, Mini-enclosures
Y e s2
Personal Protection
Respiratory Protection
Available For Use Yes
Ye s
Protective Clothing
None
Review by Asbestos Program
Yes
Manager
Work Practices
Use of Wet Methods
No
As Needed
Ye s
Use of HEPA Vacuum
Available For Use
Available For Use
As Needed
1) In the area where work takes place
2) Type of containment may vary. For example, small-scale, short-duration tasks may not require full containment.
2 1
EPA recommends
that building
owners make
available all
written elements
of the O&M
program to the
building’s O&M
staff as well as
to tenants and
other building
occupants.
Recordkeeping
All the building asbestos management documents
discussed in this Guide (inspection and assessment
reports, O&M program plan, work practices and
procedures, respirator use procedures, fiber release
reports, application for maintenance work and work
approval forms, evaluations of work affecting ACM, and
reinspections/surveillance of ACM) should be stored in
permanent files. In addition, for employees engaged in
asbestos-related work, federal regulations (see Chapter
6) require that employers retain:
● personal air sampling records, for at least 30
years. Personal air samples are those collected
in the worker’s breathing zone during perform-
ance of work involving asbestos exposures.
● objective data used to qualify for exemptions
from OSHA’s initial monitoring requirements
for the duration of the exemption.
● medical records for each employee subject to
the medical surveillance program for the
duration of their employment plus 30 years.
● all employee training records for one year
beyond the last date of each worker’s employ-
ment.
In addition, OSHA requires that employers provide to
each employee their record of exposure and medical
surveillance under the Records Access Standard (29
CFR 1910.20) and the Hazard Communication Standard
(29 CFR 1910.1200). Seethe OSHA Construction Rule
(29 CFR 1926.58) or the EPA Worker Protection Rule
(40 CFR 763 Subpart G) for more details of recordkeep-
ing requirements.
EPA recommends that building owners make available
all written elements of the O&M program to the
building’s O&M staff as well as to tenants and other
building occupants, if applicable. Building owners are
also encouraged to consult with their legal counsel
concerning appropriate recordkeeping strategies as a
standard part of their O&M programs. Additionally
state and local regulations may also require additional
recordkeeping procedures.
Chapter Summary
Although the elements discussed in this chapter should appear in any O&M program, the extent to
which each applies will vary depending on the building type, the type of ACM present, and the ACM's
location and physical condition. To achieve its objectives an O&M program should include the
following:
A notification program to inform building
occupants, workers, and tenants about the
location of ACM and how to avoid disturbing
ACM.
Periodic surveillance and reinspection of ACM
at regular intervals by trained workers or
properly trained inspectors. Air monitoring to
detect airborne asbestos fibers in the building
may provide useful supplemental information
when conducted along with a comprehensive
visual and physical ACM inspection/ reinspec-
tion program. Air samples are most accurately
analyzed using transmission electron micros-
copy (TEM).
A “work Control/permit” system, which some
building owners have used successfully to
control work that could disturb ACM. This
system requires the person requesting work to
submit a Job Request Form to the Asbestos
Program Manager before any work is begun.
O&M work practices to avoid or minimize fiber
release during activities affecting ACM.
Recordkeeping. OSHA and EPA have specific
requirements for workers exposed to asbestos.
22
What O&M Training Is
Necessary?
Types of Training
Training of custodial and maintenance workers is one of the keys to a successful O&M program. If
building owners do not emphasize the importance of well-trained custodial and maintenance
personnel, asbestos O&M tasks may not be performed properly This could result in higher levels of
asbestos fibers in the building air and an increased risk faced by both building workers and occupants.
OSHA and EPA require a worker training program for
all employees exposed to fiber levels (either measured
or anticipated) at or above the action level (0.1 f/cc,
8-hour time-weighted average– the TWA) and/or the
excursion limit (1.0 f/cc, 30-minute TWA—see Chapter
6). According to the EPA regulations governing schools,
all school stall custodial and maintenance workers who
conduct any activities that will result in the disturbance
of ACM must receive 16 hours of O&M training. Some
states and municipalities may also have specific training
requirements for workers who may be exposed to
asbestos, or who work in a building with ACM present.
With proper training, custodial and maintenance staff
can successfully deal with ACM in place, and greatly
reduce the release of asbestos fibers. Training sessions
should provide basic information on how to deal with all
types of maintenance activities involving ACM. How-
ever, building owners should also recognize that O&M
workers in the field often encounter unusual, “non-
textbook” situations. As a result, training should
provide key concepts of asbestos hazard control. If these
concepts are clearly understood by workers and their
supervisors, workers can develop techniques to address
a specific problem in the field. Building owners who
need to provide O&M training to their custodial and
maintenance staff should contact an EPA environmental
assistance center (see Appendix D) or equally qualified
training organization for more information.
At least three levels of maintenance worker training can
be identified
LEVEL 1: AWARENESS TRAINING. For custo-
dians involved in cleaning and simple main-
tenance tasks where ACM may be acciden-
tally disturbed.
For example, fixing a light fixture in a ceiling covered
with surfacing ACM. Such training may range from two
to eight hours, and may include such topics as:
● Background information on asbestos.
● Health effects of asbestos.
● Worker protection programs.
● Locations of ACM in the building.
● Recognition of ACM damage and deterioration.
● The O&M program for that building.
● Proper response to fiber release episodes.
Training of
custodial and
maintenance
workers is
one of the
keys to a
successful
O&M
program.
2 3