Asbestos Management Plan

1.0 Policy

1.1 It is the policy of Sonoma State University that SSU personnel and off campus contractors be made aware of asbestos containing materials in their work area. Every effort shall be made to minimize the unintentional disturbance of asbestos containing material on the SSU campus by following the procedures outlined in this document.

1.2 All persons planning on hanging pictures or plants, removing ceiling tiles, or otherwise disturbing construction materials within SSU buildings must first contact Environmental Health & Safety to ensure that no asbestos containing material is present.

1.3 Environmental Health & Safety will provide all oversight and supervision necessary for protection of individual health and safety. All current practices in asbestos management will meet or exceed applicable federal, state and local safety laws.

2.0 Purpose

2.1 To minimize exposure of campus personnel to asbestos fibers from campus building materials and comply with applicable asbestos control regulations.

3.0 Definitions

3.1 Asbestos
Any of a member of six fibrous silicate materials that occur naturally in the earth's crust, including Amphiboles and Serpentines (chrysotile, amosite, crocidolite, and fibrous tremolite, anthophylite, and actinolite).
3.2 Asbestos NESHAP
The National Emissions Standard for Hazardous Air Pollutants for asbestos is a set of federal regulations designed to control the emission of asbestos fibers from construction and demolition activities.
3.3 Suspect regulated asbestos containing material
A material that is likely to be asbestos but has not been positively identified through analysis by a NIST or EPA accredited laboratory.
3.4 Friable & Non-friable asbestos
Friable asbestos is typically loose degraded material that will crumble, flake, or otherwise release dust when disturbed. Examples are spray on acoustic material, flaking plaster, and water damaged pipe insulation. According to NESHAP, friable asbestos is a material that contains more than 1% asbestos, and when dry, can be crumbled, pulverized, or reduced to a powder by hand pressure.
Non-friable asbestos includes solid asbestos containing construction materials that are in good condition. Examples are intact floor tiles, transite boards, cement products, and encased pipe insulation.
National Emission Standard for Hazardous Air Pollutants. Regulations set forth by the U.S. Environmental Protection Agency to control asbestos emissions from renovation and demolition activities.
Asbestos Hazard Emergency Response Act. Federal regulations covering identification and abatement procedures, training, and other elements of asbestos hazard control.
3.7 Regulated Asbestos Containing Materials (RACM)
Neshap: All friable materials containing greater than 1% asbestos by weight; Category 1 non-friable material that has become friable; Category 1 non-friable material that will be subject to grinding, cutting, sanding, or abrading; and Category 2 non-friable material that will have a high probability of being crumbled, pulverized or reduced to a powder by the demolition/renovation activity.
3.7 Category 1 Non-Friable
Asbestos containing packings, gaskets, resilient floor covering and asphalt roofing products.
3.8 Category 2 Non-Friable
Non-friable asbestos containing products that are not category 1 (e.g. transite).

4.0 Responsibilities

4.1 Enviromental Health & Safety

  1. Develop, implement, and maintain the SSU Asbestos Management Plan, as directed by SSU Vice President of Administration and Finance and the CSU Chancellor's Office.
  2. Perform sampling of suspect regulated asbestos containing materials (RACM) prior to commencement of any activity that may disturb suspect RACM. Sampling shall be conducted in accordance with the procedures outlined in this document.
  3. Maintain building inspection survey information, sampling records, and laboratory analyses.
  4. Notify appropriate regulatory agencies as necessary (see notification procedures, Section 5.7).
  5. Provide personal protective equipment, fit testing, and asbestos awareness training.
  6. Annual notification of asbestos containing materials within SSU buildings.
  7. Arrange for disposal of asbestos containing materials generated on the SSU campus, with the exception of contracted asbestos work.

4.2 Facilities Services

  1. Ensure that all asbestos related work performed by Facilities staff and off campus contractors is done by personnel with current certifications. Off campus contract specifications should include requirements for personnel certification and licensing documentation [HSC 25914.1 (b)].
  2. Ensure that all asbestos related work performed by SSU staff and off campus contractors is done in conformance with the procedures outlined in this document

4.3 Deans, Directors, Department Heads

  1. Ensure that each supervisor adheres to these procedures.

4.4 Supervisors

  1. Ensure that each SSU employee and each off campus employee (under contract) engaged in asbestos related work understands and adheres to adopted procedures.
  2. Assure that necessary education and training will take place prior to the employee being assigned to work with asbestos.
  3. Contact Environmental Health & Safety prior to disturbing RACM or the execution of any renovation projects . Note that the standard turn around time for lab analysis is five working days. Same day results are available at higher cost.
  4. Contact Environmental Health & Safety prior to authorizing any employee to disturb any potentially asbestos containing building materials in their office space.

4.5 Asbestos Workers

  1. Provide asbestos abatement, containment, and removal as requested. SSU employees are not to provide asbestos related work in association with off campus contractors unless explicitly approved by EH & S.
  2. SSU asbestos workers are responsible for reading and complying with procedures and guidelines provided by their supervisors and Environmental Health & Safety. Compliance with appropriate asbestos regulations and safe work practices is essential, any conflict arising over compliance issues are to be directed to EH & S.
  3. Ensure that his/her asbestos worker training is up to date.

5.0 Specific Procedures

5.1 Inspection

  1. Inspections will be conducted by AHERA certified building inspectors (see Appendix A for current list of qualified SSU personnel).
  2. Existing inspection records and sampling results will be reviewed prior to performing an inspection in order to prevent unnecessary laboratory analysis. Existing information may only be utilized if the minimum number of sampling results are available per AHERA sampling protocols.

5.2 Conducting Inspections

  1. Visually inspect the area to identify the location of all suspect RACM not previously sampled
  2. Touch all suspect RACM not previously identified to determine if it is friable.
  3. Identify all friable suspect RACM and all non-friable suspect RACM that was not previously identified
  4. Collect bulk samples of suspect RACM not assumed to contain asbestos and suspect RACM not previously sampled.

5.3 Bulk Sampling

  1. All inspections are to include a review of original blueprints and specifications of the facility when available and visual inspections of all areas of the facility which a person involved in the demolition or renovation operation may come into contact, or which may contain asbestos and could be affected directly or indirectly by the operation.
  2. Asbestos bulk samples shall be collected only by a person who has completed AHERA certified inspector training.

5.4 Conducting Bulk Sampling

  1. SSU personnel performing sampling will wear personal protective equipment appropriate to the hazard presented. At a minimum, the following guidelines should be followed: When disturbing friable material, in an isolated area that is contaminated with friable asbestos, or in a sampling situation that will generate significant quantities of dust, gloves and HEPA respiratory protection should be worn. Sampling of non-friable materials does not require PPE provided that dust is not generated in the process.
  2. Asbestos bulk samples will be collected in a random manner using the grid system described in the EPA publication "Asbestos in Buildings - Simplified Sampling Scheme for Friable Surfacing Materials.
  3. Core samples will be taken wherever feasible. If suspect RACM is believed to be present within or underneath a surface that is impenetrable by hand held coring device, then a drill or other physical means will be utilized to obtain a representative sample.
  4. If the area of the homogeneous suspect RACM is less than 1,000 linear or 1,000 square feet, at least three bulk samples shall be collected from each area.
  5. If the area of homogeneous suspect RACM is at least 1,000 linear or 1,000 square feet but less than 5,000 square feet, at least five bulk samples shall be collected from each area.
  6. If the area of homogeneous suspect RACM is at least 5,000 linear or 5,000 square feet, at least seven bulk samples must be collected from each area.
  7. Detailed working instructions for asbestos sampling are found in Appendix C, "Bulk Sampling Procedures for Asbestos."

5.5 Laboratopry Analysis

  1. Samples must be analyzed by an EPA-accredited laboratory listed in 54 Fed. Reg. 8468-82 (Tuesday, February 28, 1989).
  2. If the asbestos content is less than 1 percent as determined by polarized light microscopy (PLM) and the material is being treated as non-asbestos, verify the asbestos content by using the PLM point counting method. Cal/OSHA uses a threshold of 0.1% for ACCM, so "none detected above 1%" is not adequate for our purposes anyway. If a group of samples from a homogeneous area all show less than 1.0% asbestos, only one sample from that group need be re-analyzed using the point-count method, per Joyce Kerley (Chancellor's Office).
  3. If one sample from a homogeneous area shows more than 1% asbestos, the other sample need not be analyzed; treat the area as asbestos.
  4. If all samples required to be collected are found not to contain more than 1% asbestos, then the homogeneous area may be treated as non-RACM under the Consent Decree.

5.6 Sample Results

  1. If the asbestos content is less than 1% as determined by PLM and the material is being treated as non-asbestos, verify the asbestos containing by using the PLM point counting method.
  2. An area of homogeneous material may be considered RACM without analyzing any remaining samples if one bulk sample analysis shows more than 1% asbestos.
  3. If all samples required to be collected are found by an EPA/DHS accredited laboratory not to contain more than 1% asbestos, then the area of homogeneous material may be treated as non-RACM.

5.7 Sample Documentation

  1. Each sample collected shall be immediately placed in a sealed leak tight container, numbered both sequentially and with an identification number unique to the sampling area and the facility, dated, and identified by the initials of the asbestos inspector taking the sample.
  2. The location from which each sample is taken shall be concurrently noted by sample number on a graphic depiction of the facility containing the information specified in 5.6 c. below: If more than one person is inspecting the facility, each asbestos inspector shall use a separate graphic depiction, and date and initial the same.
  3. The following sample records shall be made and maintained at the HS/EH & S Office:
    1. An inspection report with the date of the inspection, signed by the person making the inspection
    2. An inventory and graphic depiction of the demolition or renovation operation, showing the locations of the area of homogenous material where sample are collected, the exact location where each bulk sample is collected, the dates when samples are collected, the areas of homogeneous materials where friable suspect RACM is assumed to be RACM and has therefore not been sampled, and the areas where samples taken were determined by an EPA/DHS accredited laboratory to be RACM
    3. A description of the manner used to determine sampling location, the name and signature of each asbestos inspector who collected the samples, and evidence of his/her qualifications
    4. A list of the type of materials that make up each area of homogenous material (e.g. surfacing, thermal system insulation, etc.)
    5. Chain of custody forms identifying each sample taken
    6. Laboratory reports for each asbestos bulk sample of RACM and suspect RACM taken at the demolition or renovation operation.

5.8 Asbestos Waste Disposal

  1. Friable Asbestos Waste. Waste material containing friable asbestos shall be wetted and double bagged in six millimeter (six mil) polyethylene disposal bags. Bagged asbestos waste material must be labeled with OSHA warning labels and EH & S hazardous waste labels (if left at the abatement site over night). Wetted and bagged material will be placed in 55 gallon D.O.T. approved open head drums provided by EH & S.
  2. Non-Friable Asbestos Waste. Non-friable asbestos containing materials must be managed so as to minimize damage to these materials. Non-friable asbestos materials must be collected separately from other solid waste to facilitate proper disposal. Non-friable asbestos waste (non-hazardous waste) must be taken to disposal facilities that are permitted to handle such wastes.

5.9 Regulatory Agency Notification

  1. EH & S staff will make appropriate notification to the Bay Area Air Quality Management District, Cal-OSHA, Fed-OSHA, and the Federal EPA as necessary for SSU renovation and demolition projects.

5.10 Equipment and Materials

Equipment lists for various asbestos abatement jobs are contained in the specific procedures located in the EH & S Asbestos Manual.

6.0 Employee Training

6.1 SSU employees will maintain their asbestos certifications by attending the appropriate AHERA certified refresher courses prior to the expiration date. In addition to this training, the following are also required:

  1. Respirator Certification (annual, Environmental Health & Safety).
    1. Fit Testing
    2. Applications of Respirators to Different Conditions
    3. Appropriate Cartridge Selection
  2. Asbestos Management Plan Review (annual, Environmental Health & Safety).
    1. Duties and limitations of workers, supervisors, inspectors
    2. Waste disposal
  3. Medical Surveillance
    1. Annual physical exams

7.0 Recordkeeping and Labeling

7.1. Training certificates for all employees will be maintained by EH & S.

7.2. Environmental Health & Safety maintains records of all asbestos survey and sampling results. Chain of custody forms, sampling diagrams, and laboratory results are also maintained in the EH & S Office.

8.0 References

  • Code of Federal Regulations, Title 29, Part 1910.1001 (Occupational exposure to asbestos).
  • Code of Federal Regulations, Title 29, Part 1926.58 (Demolition, abatement, & renovation)
  • Code of Federal Regulations, Title 29, Part 1910.134 (Respirators & PPE)
  • California Code of Regulations, Title 8, Division 1, Part 1, Subchapter 7, (General Industry Safety Orders), Group 16, Article 110, Section 5208. (Regulated Carcinogens).
  • California Code of Regulations, Title 8, Division 1, Part 1, Chapter 4, Subchapter 4, Article 4, Section 1529. (Demolition, abatement, & renovation).
  • California Code of Regulations, Title 8, Division 1, Part 1, Chapter 4, Subchapter 4, Article 4, Section 1531. (Respirators).
  • Code of Federal Regulations, Title 40, Subchapter R, Part 763. (AHERA regulations).
  • Code of Federal Regulations, Title 40, Part 61 (NESHAP).
  • Bay Area Air Quality Management District Regulations, Regulation 6, Section 305 (Particulate Visible Emissions).
  • Bay Area Air Quality Management District Regulations, Regulation 11, Rule 2 and Rule 14 (Demolition and renovation).