EHS

Asbestos Management

This program describes the procedures and methods of operation that employees follow so that CSUN is in compliance with federal, state and local asbestos regulations.

I.   Purpose/Scope

The plan establishes a method of doing business, including specified procedures and a specific program of operation, which is designed to meet the requirements of Cal/OSHA, the Federal Clean Air Act, and the asbestos National Emission Standard for Hazardous Air Pollutants (NESHAPS) and other asbestos rules and regulations. 

All employees are required to comply with this Asbestos Management Plan.  Compliance with the Plan will be included as a condition in any and all contracts for demolitions or renovations.

II.  Definitions

  • Asbestos: the asbestiform varieties of serpentine (chrysotile), riebeckite (crocidolite), cummingtonite-gunnerite (amosite), anthophyllite, and actinolite-tremolite.
  • Asbestos Containing Materials (ACM): both friable asbestos-containing material or nonfriable asbestos-containing material.
  • Asbestos Containing construction Material (ACCM): is any manufactured construction material which contains more than 1/10th of 1% asbestos by weight
  • Category I Nonfriable ACM: asbestos-containing packing, gaskets, resilient floor covering, and asphalt roofing products containing more than 1 percent asbestos.
  • Category II Nonfriable ACM: any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos, that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.
  • Class I Asbestos Work: activities involving the removal of Thermal System Insulation (TSI) and surfacing ACM and Presumed Asbestos Containing Material (PACM).
  • Class II Asbestos Work: activities involving the removal of ACM which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.
  • Class III Asbestos Work: repair and maintenance operations, where ACM, including TSI and surfacing ACM and PACM, is likely to be disturbed.
  • Class IV Asbestos Work: maintenance and custodial activities during which employees contact but do not disturb ACM or PACM and activities to clean up dust, waste and debris resulting from Class I, II, and III activities.
  • COMPETENT PERSON: includes the following:
    • One who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure and who has the authority to take prompt corrective measures to eliminate them; in addition,
    • For Class I and Class II work, one who is specially trained in a training course which meets the criteria of EPA's Asbestos Model Accreditation Plan for supervisor (Plan (40 CFR Part 763, Subpart E), or its equivalent, and
    • For Class Ill and Class IV work, one who is trained in a manner consistent with EPA requirements for training of local education agency maintenance and custodial (40 CFR 763.92(a)(2)).
    • PPM Facilities Project Supervisor or Consultant
    • Demolition: the wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations, or the intentional burning of any facility.  Structural member means any load-supporting member of a facility, such as beams and load support walls; or any non-load supporting member, such as ceilings and non-load supporting walls.
    • Friable Asbestos Material: any material containing more than 1 percent asbestos, that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.
    • Homogeneous Area: an area of surfacing material or thermal system insulation that is uniform in color and texture.
    • National Emission Standards for Hazardous Air Pollutants (NESHAP) for Asbestos in 40 CFR Subpart M, Sections 61.140 - 61.156.
    • Presumed Asbestos Containing Material (PACM): thermal system insulation and surfacing material found in buildings constructed no later than 1980.
    • Renovation: the altering a facility or one or more facility components in any way, including the stripping or removal of ACM from a facility component.  Operations in which load-supporting structural members are wrecked or taken out are considered to be demolitions.
    • Suspect Asbestos Containing Material: material that has not yet been analyzed by an EPA-accredited laboratory to determine whether it is ACM.
      • Thermal System Insulation (TSI): ACM applied to pipes, fittings, boilers, breeching, tanks, ducts or other structural components to prevent heat loss or gain.

III.  Exemptions/Exclusions

None

IV.  Responsibilities

  • Employees:  Employees are responsible for being aware of the potential hazards and adverse health effect of asbestos.  This can be accomplished by reading and understanding the Annual Notification of the Presence of Asbestos in Buildings at CSU Northridge or by contacting the Environmental Health and Safety Department at extension 2401.  In addition, employees should not handle, move or otherwise disturb asbestos containing or potential asbestos containing materials.
  • Inspector:  Inspectors are responsible for the inspection of a building or job site prior to any renovation or a demolition work to determine the presence of asbestos. Only an accredited inspector can sample/inspect such materials to prove they are not asbestos.
  • Competent Person:  The Competent Person is responsible for Job Site Inspections to ensure they are in compliance with the applicable requirements.
    • On Class I worksites, on-site inspections shall be made at least once during each work shift, and at an employee request
    • On Class II, III and IV worksites, on-site inspections shall be made at intervals sufficient to assess whether conditions have changed, and at any reasonable time at employee request.
    • On all worksites where employees are engaged in Class I or II asbestos work, the competent person shall perform or supervise the following duties, as applicable:
      • Set up the regulated area, enclosure, or other containment.
      • Ensure (by on-site inspection) the integrity of the enclosure or containment.
      • Set up procedures to control entry to and exit from the enclosure and/or area.
      • Supervise all employee exposure monitoring and ensure that it is conducted in accordance with applicable regulations and requirements.
      • Ensure that employees working within the enclosure and/or using glove bags wear respirators and protective clothing.
      • Ensure (by on-site supervision) that employees set up, use, and remove engineering controls, use work practices and personal protective equipment in compliance with all requirements.
      • Ensure that employees use the hygiene facilities and observe decontamination procedures.
      • Ensure that, (through on-site inspection), engineering controls are functioning properly and employees are using proper work practices.
      • Ensure that notification requirements are met.

V.  Training

  • Employee Training: 
    • Any employee engaged in the removal of ACM during a demolition or renovation operation, or in the inspection of a facility for the presence of ACM or suspect ACM, will be properly trained.  Copies of training certificates for each trained employee will be kept in the employee’s department for the record retention period.
    • The University will maintain at least one employee who has successfully completed an EPA-approved 3-day inspector course or study, and two employees who have successfully completed a 4-day EPA-approved training course for asbestos abatement workers.  An individual employee can be trained as both an inspector and an abatement worker.  Each of these trained employees will attend an EPA-approved refresher training course before the employee's training certificate expires.  The University will also maintain employees who have successfully completed an EPA-approved contractor/supervisor course.
    • No one will be deemed to have "successfully completed" the training required until he or she has passed the test given by the EPA-approved training provider for the relevant course of study or training program.
    • Inspector Training:
      • Any person engaged in the inspection of a facility for ACM or suspect ACM will have successfully completed an EPA-approved 3-day inspector course of study.  The course material will contain, but not be limited to:
      • Federal, State, and local laws and regulations governing asbestos removal, notification, handling, transport and disposal requirements;
      • Practices and procedures for detection and sampling asbestos, control of asbestos fiber releases, worker protection, and equipment decontamination; and
      • Health effects of asbestos exposure.
      • Contractor/Supervisor Training:
        • Any person performing supervision of asbestos abatement workers will have successfully completed an EPA-approved training course for asbestos abatement contractor/supervisor.
        • Competent Person Training:
          • For Class I, and II asbestos work the competent person shall be trained in all aspects of asbestos removal and handling, including: abatement, installation, removal and handling; the contents of the EPA Model Accreditation Plan; the identification of asbestos; removal procedures, where appropriate; and other practices for reducing the hazard. Such training shall be obtained in a comprehensive course for supervisors, that meets the criteria of EPA's Model Accredited Plan (40 CFR Part 763, Subpart E. Appendix C), such as a course conducted by an EPA-approved or state approved training provider, certified by EPA or a state, or a course equivalent in stringency, content and length.
          • For Class III and IV asbestos work, the competent person shall be trained in aspects of asbestos handling appropriate for the nature of the work, to include procedures for setting up glove bags and mini-enclosures, practices for reducing asbestos exposures, use of wet methods, the contents of this standard, and the identification of asbestos. Such training shall include successful completion of a course that is consistent with EPA requirements for training of local education agency maintenance and custodial staff (40 CFR 763.92(a)(2)), or its equivalent in stringency, content, and length. Competent persons for Class III and IV work, may also be trained pursuant to the requirements of subsection (o)(4)(A) of this section.
          • Asbestos Abatement Worker Training:
            • Any person engaged to perform maintenance, renovation, asbestos stripping, removal, handling, clean-up, transportation, or disposal activities, including maintenance personnel who can reasonably be expected to come in contact with ACM or suspect ACM during normal duties, will have successfully completed a 4-day EPA approved training course for asbestos abatement workers.  The course material will include, but not be limited to:
              • Legal liabilities;
              • Work practice procedures;
              • The role of inspectors, Industrial Hygienists, and other technical experts;
              • Federal, State, and local laws and regulations governing asbestos removal, notification, handling, transport, and disposal;
              • Worker and building occupant safety issues;
              • Clean up and disposal of ACM;
              • Personal protective equipment;
              • Safety considerations;
              • Health effects of asbestos exposure.

VI.  Guidelines/Rules

  • Employee Notification:
    • The Environmental Health and Safety Office will be responsible for distributing an employee notification which includes the following information:
    • The information specified in Health and Safety Code Section 25915;
    • What a worker must do if that worker discovers ACM or suspect ACM while working at the university, including a description of safety measures that a worker can take in the event of site or personal contamination;
    • That asbestos is a hazardous material which can cause adverse health effects;
    • Not to handle, move, or otherwise disturb any ACM or suspect ACM unless they are specially trained, licensed, and authorized to do so; and
    • The requirements of the Asbestos NESHAP.
    • Employees will be provided with this notification according to the following schedule:
    • Within 30 days of being hired or within 15 days of commencement of work in a building containing asbestos, whichever occurs first;
    • Annually.
    • The Physical Plant Management Department is responsible for distributing a copy of the EPA publication "Asbestos in Buildings, Guidance for Service and Maintenance Personnel (EPA Brown Book)" to all employees who may be involved in demolition or renovation work, including all maintenance personnel and custodial staff.
    • Asbestos Locations: 
      • Asbestos can be found in many common building materials.  Examples include, but are not limited to, pipe insulation, acoustical ceilings, floor tile/mastic, and fireproofing.  The campus performs inspections to locate and inventory asbestos-containing materials in buildings.  A current list of building locations and a brief description of the materials, which are known to contain asbestos, can be found on the EH&S Home Page.
      • Environmental Health and Safety in coordination with Physical Plant Management is responsible for keeping the list of asbestos-containing materials current.  This list will be periodically revised as asbestos is removed or discovered.  Employees are urged to contact Environmental Health and Safety or PPM if there is any question regarding the location of asbestos-containing materials or questions as to whether a material contains asbestos.

VII.  Procedures

  • General Procedures: 
    • Asbestos can be found in many buildings as a component of building construction materials.  Asbestos is a hazardous material which may cause adverse health effects.  However, asbestos does not pose a threat to health unless the asbestos fibers become airborne. 
    • Avoid touching asbestos-containing materials on walls, ceilings, pipes, or boilers.  DO NOT drill holes,  hang plants or other objects from walls or ceilings made of asbestos-containing materials.  When replacing light bulbs, DO NOT DISTURB asbestos-containing materials.  DO NOT DISTURB damaged asbestos-containing materials or asbestos debris.  If you find asbestos-containing materials that have been damaged, immediately do the following:
    • Stop any activities that will generate dust or spread debris.
    • Contact PPM work control center Extension 2222.
    • If you or someone else is contaminated, contact Environmental Health and Safety at X-2401.
    • DO NOT attempt to handle or clean up damaged materials unless trained, licensed, or authorized to do so.
    • Only persons specially trained, licensed, and authorized to do so may handle or otherwise disturb any asbestos-containing materials.
    • This Plan establishes procedures to be followed by all employees, contractors, and subcontractors to minimize the possibility of exposure to airborne asbestos fibers.  This Plan is one component of the University's commitment to protect the health and safety of employees, students, and the public from asbestos hazards.  For more information, you can contact the following:
    • Questions on asbestos locations contact:
      • Environmental Health and Safety: Extension 2401
      • Physical Plant Management: Extension 2222
      • Questions on asbestos regulations or asbestos exposures contact:
      • Tony Pepe, Environmental Health and Safety, Extension 2401
      • Ron Norton, Environmental Health and Safety, Extension 2401
      • Renovations & Demolitions:
        • All renovations and demolitions will comply with South Coast AQMD Rule 1403, the asbestos NESHAP, and the California Code of Regulations Title 8 Section 5208.  These standards require the following:
          • A thorough inspection for asbestos prior to any demolition or renovation activities;
          • Notification to South Coast AQMD prior to commencing demolition activities - regardless of whether asbestos is present or not;
          • Notification to South Coast AQMD of renovation operations if asbestos is present in quantities greater than 100 square feet;
          • Notification to CAL/OSHA of renovation and demolition operations if asbestos is present in quantities greater than 100 square feet;
          • Training of employees that perform inspections, and/or conduct abatement or supervise abatement;
          • Presence of a person with Contractor/Supervisor training during renovation and demolition activities;
          • Removal of asbestos prior to renovation or demolition activities that disturb asbestos or preclude access to asbestos;
          • Specific work practices must be used during demolition and renovation operations involving asbestos materials; and
          • Specific procedures must be followed for asbestos waste disposal, including (but not limited to) labeling, transportation, and record keeping requirements.
          • Prior to the commencement of any demolition or renovation work, a diligent and complete inspection will be performed of the facility for the presence of ACM and suspect ACM.  No activity will begin that might disturb or preclude access to any ACM or suspect ACM, including any activity that might disturb or preclude access to any ACM or suspect ACM in adjoining structures or buildings not directly involved in the demolition or renovation until:
          • The results of laboratory analyses conducted by a National Institute of Standards and Technology (NIST) or an Environmental Protection Agency (EPA) accredited laboratory are available establishing that the suspect ACM is, in fact, non-ACM; or
          • All ACM or suspect ACM has been completely removed from the facility in accordance with all applicable laws and regulations.
          • If any suspect ACM is discovered during a demolition or renovation activity, this material may be treated as ACM without sampling and analysis.  However, before suspect ACM is treated as non-ACM, samples of all suspect ACM will be collected and analyzed.
          • If any ACM or suspect ACM is discovered at a demolition or renovation operation that is already underway, all work that could disturb or preclude access to the ACM or suspect ACM will immediately cease.  Activities will not resume that might disturb or preclude access to the ACM or suspect ACM until the material has been sampled, analyzed, and, if found to be ACM, removed by a trained asbestos abatement worker.
          • Inspection, Bulk Sampling & Analysis:
            • Inspections: 
              • Inspections will only be conducted by a person who has successfully completed the asbestos inspection training specified in the Training Section.  If a trained CSU inspector is not available, the campus will arrange for an inspector trained in accordance with the inspection training requirements.
              • All inspections will be documented in a report detailing procedures used to identify ACM and suspect ACM.  All inspections will include a review of original blueprints and specifications of the facility when available.  The inspection will identify and quantify all friable, and Class I and Class II non-friable ACM. A visual inspection will be performed on all areas of the facility that any 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.  In conducting the inspections, each inspector will:

Visually inspect the area to identify the location of all suspect ACM not previously sampled;

Touch all suspect ACM not previously identified to determine if it is friable;

Identify all friable suspect ACM and all non-friable suspect ACM that was not previously identified; and Collect bulk samples of suspect ACM not assumed to contain asbestos and suspect ACM not previously sampled.  Bulk sampling will be conducted in accordance with bulk sampling procedures.

  • An area of homogeneous material may be considered to be ACM without analyzing any remaining samples if one bulk sample analysis shows more than 1% asbestos.  If all samples required to be collected are found by an EPA-accredited laboratory not to contain more than 1% asbestos, then the area of homogeneous material may be treated as non-ACM.
  • Bulk Sampling: 
    • Asbestos bulk samples will be collected only by a person who has completed the asbestos inspection training specified in the Training Section.
    • All asbestos bulk samples will be collected in a random manner, using the grid system described in the EPA publication no. 560/5-85/030a - "Asbestos in Buildings - Simplified Sampling Scheme for Friable Surfacing Materials" (EPA Pink Book)".  The number of asbestos bulk samples collected will be based on the extent of homogeneous area.
    • All asbestos bulk samples will be made up of a core that has fully penetrated the suspect ACM.  Each sample collected will be immediately placed in a sealed, leak tight container and labeled with a unique identifier.
    • Inspection Records: 
      • Inspection records will be maintained in the Environmental Health and Safety Office. 
      • The location from which each sample is taken will be concurrently noted by sample number on a graphic depiction of the facility.  If more than one person is inspecting the facility, each asbestos inspector will use a separate graphic depiction, and date and initial the same.  The following sample records will be generated and maintained:
      • An inspection report with the dates of the inspection and the name, address, telephone number and signature of each person making the inspection;
      • Written statement that the inspectors have successfully completed the required asbestos inspector training course;
      • An inventory and graphic depiction of the demolition or renovation operation, showing the locations of the area of homogeneous material where samples were collected, the exact location where each bulk sample was collected, the dates that samples were collected, the areas of homogeneous material where friable samples were collected, the areas of homogeneous materials where nonfriable suspect ACM was assumed to be ACM and was therefore not sampled, and the areas where samples were determined by an EPA accredited laboratory to be ACM;
      • A description of the manner used to determine sampling location and a description of sampling protocols;
      • A list of the type of materials that make up each area of homogeneous material (e.g., surfacing, thermal system insulation);
      • Chain of custody forms identifying each sample taken;
      • The name, address, and telephone number of the laboratory or laboratories that conducted analyses;
      • A statement of qualification of the laboratory demonstrating NIST accreditation; and
      • Laboratory reports for each asbestos bulk sample of ACM and suspect ACM taken at the demolition or renovation operation, including a list of test methods used, test data, and any other information used to identify or quantify any materials containing asbestos.
      • Laboratory Analysis: 
        • Samples will be analyzed only by an EPA accredited laboratory.  An EPA accredited laboratory means a laboratory with current accreditation to conduct bulk sample analysis pursuant to EPA's Interim Asbestos Bulk Sample Analysis Quality Assurance Program. 
        • A National Institute of Science and Technology (NIST) accredited laboratory with current EPA accreditation to conduct asbestos bulk sample analyses from the NIST, pursuant to the National Voluntary Laboratory Accreditation Program. 
        • If the asbestos content is less than 1.0 percent as determined by Polarized Light Microscopy (PLM), the asbestos content may be verified by using the PLM point counting method.
      • Notification Responsibilities: 
        • The Environmental Health and Safety Office in coordination with PPM (who must notify EH&S when project is planned) is responsible for ensuring that the appropriate regulatory agencies are notified when work will disturb asbestos. This includes the annual notification of nonscheduled renovation operations.  When work is performed by a contractor, the contractor shall be responsible for notifying the appropriate regulatory agencies. The Environmental Health and Safety Office will maintain records of notifications.
        • Physical Plant Management is responsible for ensuring that the appropriate agencies are notified if no asbestos is determined to be present in a demolition project.  Physical Plant Management will maintain records of these notifications.

VIII.  South Coast Air Quality Management District (SCAQMD) Notification SCAQMD Rule 1403:

    • Annual notification is required if nonscheduled renovation operations are expected to exceed 100 square feet.  The notification is due by December 17 of the year proceeding the year in which the demolition will occur.
    • Renovation notification is required if more than 100 square feet of asbestos will be removed.  The notification must be postmarked at least 10 working days prior to the start of renovation activities.
    • Demolition notification is always required, even if there is less than 100 square feet of asbestos that will be disturbed.  The notification must be postmarked at least 10 working days prior to the start of demolition activities.
    • Notification must be typewritten on forms provided by South Coast AQMD and a filing fee must accompany the notification.
    • Notifications must be revised if the quantities of asbestos changes by more than 20%, the start date changes, or the completion date changes.
  • Federal Notification:
    • The Federal EPA does not require notification if the South Coast AQMD has been notified.
  • CAL/OSHA Notification: 
    • California Code of Regulations Title 8 Section 5208(r) specifies two (2) types of notifications that apply to the campus, as follows:
    • Carcinogen Report of Use:
      • Applies to exposures of campus employees to listed CAL/OSHA carcinogens.  Employee exposure to asbestos must be included in the report.
      • The Carcinogen Report of Use Form is a general notification to CAL/OSHA and applies to campus employees.  This form does not apply to temporary worksite abatement operations.  This form is filed one time, but must be updated within 15 days if any information changes.  CAL/OSHA can also periodically request the campus to verify the information on the current form.
    • Temporary Worksite (Abatement) Notification:
      • Applies to asbestos abatements.
      • A temporary Worksite Notification must be made for abatement jobs if more than 100 square feet of asbestos will be disturbed.  The notification applies to the employees of the contractor performing the work.  Notification must be made at least 24 hours in advance of the job.  There is no notification fee.  The notification can be made by using the SCAQMD notification form, or any other means that includes the time and date of commencement of work, approximate duration of work, location, type of business, and kind of work to be performed.  Notification can be made by mail, phone, or fax to the CAL/OSHA District Office:

IX.  Forms

X.  References

XI. Revision Record

Revision

Changes

Date

1.0

Original Program

October 15,2008

2.0

Format changes and review

May 30, 2009

2.1

Added definitions and review

June 9, 2009

2.2

Format changes and review

January 2014