Asbestos Management Program

Transcription

1 Asbestos Management Program March 20, 2006 MNarchMarch

2 TABLE OF CONTENTS OVERVIEW.. 4 ASBESTOS CONTROL PROGRAM.. 4 OWNER RESPONSIBILITIES 4 PROGRAM SUPERVISOR S RESPONSIBLITIES... 5 WORKER S RESPONSIBILITIES ASBESTOS INVENTORY RECORD PRODUCTS THAT MAY CONTAIN ASBESTOS ASBESTOS TRAINING 6 ASSESSMENT OF ASBESTOS CONTAINING MATERIALS 6 IMPLEMENTATION OF CORRECTIVE MEASURES LEGISLATION DEFINITIONS.. 7 OPERATION TYPES... 8 TYPE 1 - OPERATIONS TYPE 1 - PRECAUTIONS.. 8 TYPE 2 - OPERATIONS TYPE 2 - PRECAUTIONS.. 9 TYPE 3 - OPERATIONS TYPE 3- PRECAUTIONS. 10 PRE-QUALIFIED CONTRACTORS ASBESTOS INFORMATION 11 MONITORING WORK.. 11 REMOVAL BY CONTRACT HEALTH AND SAFETY OFFICE REPORTING DISTURBED ASBESTOS. 11 HEALTH CONCERNS/HEALTH INFORMATION

3 NOTIFICATION OF WORK CONTEMPLATED WARNING SIGNS 11 REPAIRS 12 CONTROL MEASURES ENCLOSURE ENCAPSULATION REMOVAL AIR MONITORING MINOR REMOVAL OR REPAIR. 13 SPECIFIC PROCEDURES WASTE DISPOSAL NILFISK GS81 (HEPA EQUIPPED VACUUM).. 14 ASBESTOS CONDITION REPORTS ASBESTOS WORK RECORD. 14 ASBESTOS WORK REPORT SUMMARIES.. 14 EMPLOYEE ASBESTOS EXPOSURE SUMMARIES 14 HAZARDS OF ASBESTOS EXPOSURE. 15 OHSA LIMITS MANAGEMENT OF ASBESTOS WASTE.. 16 ASBESTOS INCIDENT PROCEDURE ASBESTOS INCIDENT REPORT ASBESTOS WORK RECORD.. 19 APPENDIX A. 20 3

4 ASBESTOS MANAGEMENT PROGRAM OVERVIEW Asbestos-containing materials (ACM s) are present in many school buildings. The Rainbow District School Board is committed to the Health and Safety of its Employees and Students and will be in compliance with Ontario Regulation 278/05. ASBESTOS CONTROL PROGRAM The purpose of the Control Program is to ensure that maintenance/operations staff and contractors when undertaking activities that could potentially disturb asbestos containing materials take appropriate precautionary measures. OWNER RESPONSIBILITIES Owners of buildings that may contain friable material are responsible for determining whether the material contains asbestos in the following cases: 1. Where the material has fallen and is being disturbed, and 2. Where the material is likely to be handled or disturbed during the demolition, alteration or repair of machinery or equipment or a building. Where it has been established that friable material containing asbestos is present in a building, the following requirements exist for the building owner: 1. Preparation and maintenance of a record of the location of friable asbestos containing material at each site location. 2. Advise workers who work in close proximity to the friable material and who may disturb the material, of its presence. 3. Establish and maintain a training program for all workers who are likely to work in close proximity to and may disturb the friable material. 4. Inspect the friable material at reasonable intervals in order to determine its condition and update the record at least annually and if new information is obtained. 5. Clean up and remove any friable material that has fallen. 6. Repair, seal, remove or permanently enclose fireproofing or insulation where it is readily apparent that the friable material will continue to fall due to deterioration. 7. Remove all material containing asbestos that may be disturbed during the demolition of machinery or equipment or of a building prior to doing the job. 8. Ensure that prescribed work practices and procedures for various operations that may result in exposure of a worker to ACM are followed. 4

5 PROGRAM SUPERVISOR S RESPONSIBILITIES 1. See that the list of locations where asbestos has been removed or controlled has been kept up to date. 2. To inspect these areas for deterioration and/or need for repair. 3. If a new area is discovered and the presence of asbestos is suspected, a sample shall be acquired for testing. This is to be arranged through the Safety Office. 4. Maintain a record of worker exposure to friable ACM while performing repair operation. All Maintenance and Custodial staff must record: - Work involved - Safety measures undertaken - Name of worker - Job duration - Any non-compliance to precautions WORKER S RESPONSIBILITIES (Maintenance, Custodial Workers and Outside Contractors) 1. Consult the Asbestos Inventory Record on site to determine if ACM s are present in the area where work is to be carried out to determine: a) Location of ACM b) The type and condition of ACM s c) Precautionary procedures for duties involved 2. Follow precautionary procedures. All workers involved in the operation as prescribed must wear personal protective equipment including a respirator and personal protective clothing 3. Report to immediate supervisor any suspect material found during a repair operation. Asbestos Inventory Record The Rainbow District School Board has conducted an Asbestos Survey and will maintain and update this survey on an annual basis. Copies of the survey have been distributed to all schools, Maintenance Shop and Board Office. Some Products That May Contain Asbestos - Ceiling tiles - floor tiles -sprayed on insulation - Mechanical insulation - some ceramic products - transite table tops, pipes - Doors (core) - insulating boards - acoustical plaster This list is not complete. 5

6 Asbestos Training Training courses will be provided for all levels of employees in the Asbestos Control Program as applicable. The scope and duration of the training course will depend on the requirements of each group and their roles in the Asbestos Control Program. Topics covered in training include: Potential hazards associated with exposure to asbestos fibres. Location of asbestos-containing materials in the building. Applicable asbestos regulations. Personal protection Proper handling of asbestos-containing materials. Asbestos waste disposal. Maintenance of records. Asbestos training for maintenance staff will include hands-on instruction on the following subjects, where applicable: Personal protection Repair of thermal insulation containing asbestos Response to asbestos-related spills or incidents Maintenance and care of asbestos control equipment Teachers/Other Staff who are unlikely to come in contact with or be exposed to friable asbestos will be given an overview of the following: Asbestos Legislation Typical Asbestos Locations How To Report An Asbestos Concern Board Asbestos Management Program Assessment of Asbestos-Containing Materials Physical inspection and assessment of the ACM s will be conduced annually. The ACM s have been graded and condition reports will be reported as follows: Good - No Remedial Action required. Fair - Slight cracking or chipping of the encapsulant or elbow. Poor - Friable Implementation of Corrective Measures Corrective measures if required may include one or more of the following: Repair of thermal insulation Enclosure of friable material Application of Encapsulation Removal of friable asbestos-containing material Air monitoring, inspection & management 6

7 Legislation All activity related to asbestos will be in accordance with governing legislation including: Occupational Health and Safety Act and Regulations for Industrial Establishments Regulation respecting Asbestos made under the Occupational Health and Safety Act (Reg837/90) Regulation respecting Asbestos on Construction Projects and in Buildings and Repair Operations made under the Occupational Health and Safety Act (Reg 278/05) DEFINITIONS Asbestos means any of the following fibrous silicates: actinolite, amosite (brown asbestos), anthophyllite, chrysotile (white asbestos), crocidolite (blue asbestos), or tremolite; buildings includes a structure and without restricting the generality of the foregoing, includes the electrical, plumbing, heating and air handling equipment, including rigid ductwork, of a building or structure; friable material means material that when dry can be crumbled, pulverized or powered by hand pressure and includes such material that is crumbled, pulverized or powered by hand; HEPA filter means a high efficiency particulate aerosol filter that is at least percent efficient in collecting 0.3-micrometre aerosol. 7

8 OPERATION TYPES Regulation 278/05 is aimed specifically at controlling disturbances of friable asbestos through maintenance, renovation or demolition and in it such work is broken down into three categories. TYPE 1 OPERATIONS: a) Installing or removing manufactured non-friable products containing asbestos such as: - roofing felts - vinyl asbestos tile - perforated acoustical tile - 2 x 4 ceiling tile - 2 x 2 ceiling tile - gaskets - seals - packing - friction products - asbestos cement products - transite - insulating asbestos - clapboard - siding shingles - roofing shingles b) Cutting, drilling or shaping these products with non-powered hand tools c) Removal of less than one square metre of drywall in which joint-filling compounds are ACM.. d) Removal of ACM ceiling tiles if the area is less than 7.5 square metres. TYPE 1 PRECAUTIONS Clean all visible dust that may be distributed using a damp cloth or vacuum equipped with a HEPA filter. Control the spread of dust using polyethylene drop sheets and shut down ventilation system. Do not re-use the drop sheets. Use water containing a wetting agent to control dust unless the water creates a hazard or causes damage. Clean the area during and at the end of the work using a HEPA vacuum or damp mop. Asbestos containing waste will be placed in a prescribed container for disposal. Provide a non-powered half face respirator and protective clothing if requested by the worker. Compressed air shall not be used to remove dust or to clean clothes. Eating, drinking, chewing or smoking is not allowed in the work area. Facilities for washing must be available and used upon completion of the work. 8

9 TYPE 2 OPERATIONS: Removal of all or part of a suspended ceiling with the likelihood of ACM to be lying on the surface of the false ceiling. Minor renovations or demolition or routine maintenance on pipes and boilers such as: - removing asbestos insulation to repair valves on pipes and boilers - replacing asbestos insulation with non-asbestos insulation. Minor removal or disturbance of friable material during repair, alterations and maintenance such as to fasten to a sprayed surface. Enclosure of friable material. Installing or removing ceiling tiles that are ACM if more than 7.5 metres in area Application of tape, sealant or other covering to pipes or boiler insulation containing asbestos. Removal of ACM using a glove bag. Cleaning or removing filters used in air handling equipment in a building that has spray fireproofing that is ACM. All non-defined operations that may cause asbestos exposure. TYPE 2 PRECAUTIONS Post signs warning of asbestos dust hazard Provide suitable enclosure or drop sheets (polyethylene) and shut down ventilation systems. Provide protective clothing and full-face non-powered asbestos rated respirators for all persons in work area: no eating, drinking, chewing or smoking in the work area Clean all waste at start, during and end of work by wet methods or HEPA vacuum. No compressed air may be used in clean up. Wet all material to be disturbed (wetting agent in water). If the operation is contaminated ceiling entry a polyethylene enclosure is mandatory Turn off ventilation system Cover off all ducts to and from the work site Place all waste in labeled waste containers. Clean drop sheets and clothing or dispose as asbestos waste. Workers should clean them with HEPA vacuum or damp cloth wiping in the area, then wash hands and face. 9

10 TYPE 3 OPERATIONS Removal (other than minor) or encapsulation (sealant) of friable material if area removed is more than one square metre. Cleaning or removal of air handling equipment with friable-sprayed asbestos. Repair, alterations or demolition of kiln or furnace with asbestos. Use of power tools not equipped with HEPA dust collectors. Repair, alteration or demolition of plant utilizing asbestos in the process. Work on ceiling tiles, drywall or friable ACM is classified according to the total area on which work is done consecutively in a room or enclosed area even if the work is divided into smaller jobs TYPE 3 PRECAUTIONS Notify the Ministry of Labour, Construction Health and Safety Branch of all Type 3 operations. Separate area from rest of workplace. Provide full enclosure, with critical barriers. Construct decontamination facility with full hot and cold shower and towels. Provide protective clothing and appropriate respirators (supplied air, PAPR or non-powered); no eating etc. Disconnect and seal ventilation system. Provide ground fault circuit interrupters. Wet material where possible (wetting agent). Clean area with a HEPA vacuum or wet method; no compressed air in clean up. Dispose of all waste and drop sheets in labeled waste containers along with all sheeting used in the enclosure. Daily inspection (minimum) of work site. Daily inspections to be completed by a certified member of the Joint Health and Safety Committee and/or the asbestos abatement manager. Carry out a thorough cleaning of the work area by wet methods and HEPA vacuum. Random air testing on both sides of critical barrier at discretion of the daily inspector. 10

11 PRE-QUALIFIED CONTRACTORS Generally licensed asbestos contractors will carry out all repairs, enclosures, encapsulations and removals. ASBESTOS INFORMATION The Rainbow District School Board must furnish asbestos information relating to the building including drawings, plans, asbestos type and specifications to any prospective contractor. MONITORING WORK Inspections and monitoring contractor s work will be carried out before, during and after to ensure compliance. Such inspection and monitoring will be carried out by an independent qualified consultant or by a competent owner representative, in the presence of a certified member of the Joint Health and Safety Committee. REMOVAL BY CONTRACT The contractor will in turn be responsible to ensure all necessary health and safety precautions are taken. Any unsafe work practices will be reported to the appropriate supervisor immediately. HEALTH AND SAFETY OFFICE The Health and Safety Office will monitor Asbestos Work Report Summaries monthly and file an Employee Asbestos Exposure Report annually to the Chief Physician, Occupational Health Medical Services, Ministry of Labour. REPORTING DISTURBED ASBESTOS Concerns regarding the condition of asbestos-containing material should be reported to your immediate supervisor. HEALTH CONCERNS/HEALTH INFORMATION Concerns or information requests regarding the health effects of asbestos should be discussed with you immediate supervisor or the Health and Safety Office. NOTIFICATION OF WORK CONTEMPLATED Building occupants will be advised of any work that may disturb ACM s. The school Principal will be the contact person for the academic department, Supervisors will be the contact for custodial personnel. In all cases H & S must be informed. WARNING SIGNS Warning signs will be placed where access needs to be restricted as entry to work activity area could result in asbestos exposure or damage (ie. When asbestos removal or repair starts or the area has to be contained due to damaged or friable material). 11

12 REPAIRS Repair of thermal insulation includes the restoration of ACM s, or the covering material that has been damaged, usually located on pipes, boilers, tanks, ducts or other facility components. CONTROL MEASURES Enclosure Involves construction of airtight walls and ceilings around friable asbestos-containing materials. This option can only be selected if repair or removal of the asbestos containing materials is not practical. Encapsulation Involves the application of an encapsulant to ACM s to control the release of asbestos fibres in the air. The encapsulation will create a membrane over the surface (bridging encapsulant) or penetrates the material and binds its components together (penetrating encapsulant). Encapsulation will not be applicable if the material is deteriorated or has insufficient adhesion. The encapsulation option will only be selected for limited size and where complete removal is not warranted or practical. Removal Asbestos removal activities involve the stripping of deteriorated friable ACM s from surfaces or components of a facility and the replacement of insulation. Removal of friable ACM s will take place only when: - The ACM s are damaged beyond repair. - The disturbance of the ACM cannot be controlled with operating and maintenance procedures. - Removal activities shall be built into major renovation plans or take place just prior to the demolition of a building. The following factors shall be taken into consideration: - How to incorporate abatement activities with other activities, such as renovations or major repair work. - How to stage abatement activities in the most practical and economical manner. - How to minimize disruption of the activities of the building. AIR MONITORING Air monitoring during asbestos removal is required in many cases including: 12

13 - Inside the removal enclosure, to ensure that fibre counts are below the maximum allowable concentration levels, taking into consideration the protection factor of the respiratory equipment used. - Outside the removal enclosure to ensure that the removal process has no adverse impact on the fibre concentrating levels in the occupied sections of the building. - At the completion of the removal and cleaning process as proof of performance (clearance level). Air monitoring will be arranged through the Health and Safety Office and performed by an independent consultant on all removals as proof of clearance. MINOR REMOVAL OR REPAIR High density non-friable ACM, such as asbestos-cement cladding, pipe, roofing tiles, vinyl floor tiles, gaskets and packing and friction materials, regulations require only simple, straight-forward workplace practices and procedures when installing, repairing or removing these materials. Staff involved in minor ACM removal or repair must follow several basic rules: 1. Turn off and cover air vents in work area to restrict potential contamination of other areas. 2. Ensure that others are not in the immediate work area that may come in contact with disturbed ACM. If exposure to others is likely to occur, all work must cease until the supervisor can arrange appropriate protective measures. 3. Eating and wash-up facilities are not to be in the work areas. 4. Ensure adequate supplies of protective equipment and materials are on hand. SPECIFIC PROCEDURES Repair operations being performed in an area containing friable ACM (ie. work above ceiling tiles covered with fibrous asbestos, drilling or cutting ACM s) or minor removal: - Wet surrounding area with wetting agent (liquid detergent and water) or vacuum with HEPA vacuum. Once completed, wet sweep or vacuum with HEPA equipped vacuum the surrounding area. If drop sheets are utilized, they cannot be reused unless they are vacuumed with HEPA equipped vacuum. 13

14 WASTE DISPOSAL Asbestos-containing wastes must be bagged in a 6mm plastic disposal bag, tied off securely and clearly marked, or 200L capacity metal or fibre drums with tightly fitting lids and 0.15mil. minimum thickness sealable polyethylene liners. Containers will be clearly marked with yellow/black labels: Danger Contains Asbestos Material and French equivalent. Store containers in a safe place until the supervisor can arrange transfer to a disposal site. NILFISK GS81 (HEPA EQUIPPED VACUUM) Operation and maintenance will be in accordance with Instruction For Use Nilfisk Model GS81 (or equivalent), as provided. Appropriate protective equipment will be worn as outlined in Instruction For Use, Nilfisk Model GS81, Nilfisk Ltd. And the Employers instructions. Equipment will be wet clothed after each use. ASBESTOS CONDITION REPORTS Asbestos Condition Reports will be conducted annually in low risk areas and monthly in areas where there is greater risk of accidental damage by the JHSC representative or designate. ASBESTOS WORK RECORD Each worker will complete the Asbestos Work Record, each time work with material containing asbestos is performed. Clean-up operation requires documentation noting the class of removal, equipment used and the disposal method. Contractors are also required to complete an Asbestos Work Record. Revisions to asbestos inventory will be forwarded to the specific site by the Plant Department. ASBESTOS WORK REPORT SUMMARIES The immediate Supervisor will submit asbestos Work Report Summaries to the Health and Safety Office. EMPLOYEE ASBESTOS EXPOSURE SUMMARIES Employee Asbestos Exposure Summaries will be submitted by the Health and Safety Office to the Chief Physician Occupational Health Medical Services, Ministry of Labour by the 15 th day of January, annually. The Asbestos Exposure Record will be maintained by the WSIB Administrator. 14

15 HAZARDS OF ASBESTOS EXPOSURE Asbestos is a general classification of minerals, which are virtually indestructible but can be separated into fibres. These fibres were used in building materials and other products, which are now found in many buildings and homes. Asbestos tends to break into a dust of microscopic fibres that remains suspended in the air for long periods of time. When inhaled these fibres easily penetrate body tissue. Asbestos fibres are responsible primarily for three serious diseases: asbestosis, lung cancer and mesothelioma. Asbestosis is a scarring disease of the lung, and mesothelioma is a malignant tumor of the lining of the chest and abdominal cavities. The long latency period associated with these diseases is any where from ten to thirty years. Workers exposed to asbestos twenty to thirty years ago are five times more likely to develop asbestos related malignancy, eight times more likely to develop lung cancer and four times more likely to develop non-malignant respiratory disease than the general population of Ontario. Asbestos-related diseases develop slowly and are not often recognized until they are at an advanced stage. A medical surveillance program is designed to allow earlier detection of the disease. Provincial Regulations sets specific requirements for medical examination record keeping and reporting. The lung tests are an important screening mechanism because reduced lung capacity is one of the earliest signs of asbestosis. There are a number of signs and symptoms of asbestos related diseases. a) shortness of breath, a tightness in the chest: both with exertion b) a dry cough that produces no phlegm c) clubbing of the fingers and toes (the ends of the toes and fingers become enlarged) d) weight loss e) lack of energy f) increased chest infections The danger to health comes only with the disturbance of ACM s that can cause the asbestos fibres to become airborne. Asbestos is dangerous only if it is in a friable (easily crumbles) state when the loose fibres may be inhaled. It is the long, thin fibres that break down many times along their length without losing their mineral qualities. 15

16 OHSA LIMITS All of the occupational standards are based on the optical microscope using the Phase Contrast Methods (PCM). The time-weighted average exposure of a worker to airborne asbestos shall not exceed, TWA of 0.01 fibres/cubic centimeter of air. The time weighted average (TWA) is the concentration for exposure averaged over an 8-hour day or 40-hour work week. It is generally described as the level to which nearly all workers may be repeatedly exposed, day after day, without adverse affects. MANAGEMENT OF ASBESTOS WASTE The management of asbestos waste will be carried out in accordance with all Ministry of Environment Regulations pertaining to Asbestos. 16

17 ASBESTOS INCIDENT PROCEDURE The following is the procedure to be followed in the event of the discovery of suspected friable asbestos containing material within a school building. Friable material is defined as material containing more than 1% of asbestos by weight that can be crumbled, pulverized, or reduced to powder by hand pressure. 1. All work that will potentially disturb the suspect material is to stop immediately. 2. The area in which the suspect material has been discovered is to be isolated with yellow caution tape. Doors are closed, mechanical air handling systems, and fans will be shut off to minimize air movement through the affected areas. 3. Traffic is to be routed around the area where suspect material has been discovered to reduce the potential of disturbance of the suspect material. 4. The following people are to be notified of the possible presence of friable asbestos material. If your supervisor is not available proceed to the next name on the list. 1) Your immediate Supervisor 2) Maintenance Supervisor ) H & S Office , ext ) H& S Representative Certified Member 5) School Principal 5. Until the arrival of the above personnel, no traffic is to be allowed through the affected areas, and the area is to be visually monitored to ensure the affected areas remain vacant. 6. The above personnel will assess the situation and make arrangements to perform any required bulk sample analysis, air tests, and design the appropriate abatement response actions. 7. Abatement work is to be scheduled so as to minimize disturbance to normal building activity. 8. Upon notification the Health and Safety Office advise the school Health and Safety Representative of Asbestos work. 9. Certified members shall inspect the affected areas: - Upon notification of disturbed Asbestos containing material - Prior to removal or encapsulation - Upon completion of air testing at completion of abatement procedures, but prior to removal of protective barriers - Upon final removal of all protective barriers 17

18 ASBESTOS INCIDENT REPORT DATE: TIME: REPORTED BY: SCHOOL: ROOM: REPORTED TO: The following is the checklist to be filled out and submitted in the event of the discovery of suspected friable asbestos containing material within a school building. Friable material is defined as material containing more that 1% of asbestos by weight that can be crumbled, pulverized, or reduced to powder by hand pressure. 1. All work that will potentially disturb the suspect material has been stopped immediately. 2. The area in which the suspect material has been discovered has been isolated with yellow caution tape. Doors are closed, mechanical air handling systems, and fans were shut off to minimize air movement through the affected areas. 3. Traffic was routed around the area where suspect material has been discovered to reduce the potential of disturbance of the suspect material. 4. The following people have been notified of the possible presence of friable asbestos material: 6) School Supervisor 7) Maintenance Supervisor ) H& S Office , ext ) H& S Representative 10) School Principal 5. The area has been inspected and the job type identified. SIGNED: Copies To: Health & Safety Office Joint Health & Safety Committee Maintenance Department School Principal 18

19 ASBESTOS WORK RECORD SCHOOL/LOCATION: AREA/ROOM #: START DATE: COMPLETION DATE: TYPE OF REMOVAL: TYPE 1 TYPE 2 TYPE 3 DESCRIPTION OF WORK PERFORMED: PERSON (S) INVOLVED: Abatement Contractor Abatement Manager CUPE Representative Employer Representative OPERATIONS SUPERVISOR (in charge) CUPE SIGNATURE: EMPLOYER SIGNATURE: DATE: DATE: Copies To: Health & Safety Office Joint Health & Safety Committee Maintenance Department School Principal Manager of Plant 19

20 APPENDIX A Ceiling Entry Protocol Prior to accessing a work area above or through a fixed or false ceiling, the worker must review the on-site asbestos inventory booklet to ascertain whether or not the individual drop-in ceiling tiles are of asbestos containing material (ACM) or if there is ACM present. If there is no ACM present lying on or in the drop-in ceiling tiles the worker can proceed without the use of Type 2 precautions. If there is no ACM above or on the drop-in ceiling tiles, but the ceiling tile is ACM, the worker accessing the work area must first lay a drop sheet on the floor directly below the tile to be removed; carefully remove the ACM ceiling tile ensuring that it is removed intact; vacuum using a HEPA vacuum or damp wipe the track area where the tile was removed from; and dispose of the ceiling tile and drop sheet as ACM waste. Removing all or part of a false ceiling to obtain access to a work area, if ACM is likely to be lying on the surface of the ceiling is deemed to be a contaminated ceiling and therefore a Type 2 operation. If the operation is a contaminated ceiling entry, the use of an enclosure is mandatory. For contaminated ceiling entry the spread of dust from the work area must be prevented by using an enclosure constructed of polyethylene or other material that is impervious to asbestos. The polyethylene sheets shall not be re-used. For contaminated ceiling entry, the friable ACM that is likely to be disturbed shall be cleaned up and removed by using a HEPA vacuum immediately once access to the work area is obtained. Contaminated ceiling entry and the use of HEPA equipped power tools (except for areas with fallen friable ACM) require the use of either a non-powered or full-face powered respirator equipped with P100 or HEPA filters. Inspection only of the area above a false ceiling is not deemed to be work. Violations of this protocol are to be reported to your Zone Operations Supervisor immediately. 20