CENTRAL MICHIGAN UNIVERSITY ASBESTOS MANAGEMENT PLAN

Transcription

1 CENTRAL MICHIGAN UNIVERSITY ASBESTOS MANAGEMENT PLAN Revised: February 17, 2017

2 Table of Contents (1.0) Plan Information... 1 (1.1) Contact Information... 1 (1.2) Plan Status... 1 (1.3) Understanding this Plan... 1 (1.4) Communication Policy... 1 (1.5) Prequalified Asbestos Contractors and Consultants... 2 (1.5.1) Asbestos Abatement Contractors... 2 (1.5.2) Asbestos Consultants... 2 (2.0) Introduction... 3 (2.1) Scope... 3 (2.2) Purpose and Objectives... 3 (2.3) Disclaimer... 4 (3.0) Applicable Regulations... 4 (4.0) Responsibilities... 4 (4.1) University Employees and Student Workers... 5 (4.2) Facilities Management and Res Life Supervisors... 5 (4.3) University Stores... 5 (4.4) Plant Engineering & Planning (PEP)... 6 (4.5) External Project Managers, General Contractors, and Subcontractors... 6 (4.6) External Asbestos Abatement Contractors... 6 (4.7) External Asbestos Consultants... 6 (4.8) CMU Department of Environmental Health and Safety... 7 (5.0) General Asbestos Compliance... 8 (5.1) Prohibitions... 8 (5.2) Asbestos Surveys... 8 (5.3) Training... 8 (5.4) Negative Exposure Assessments... 9 (5.5) Asbestos Abatement Work Practices... 9 (5.6) Asbestos Abatement Air Monitoring (5.7) Post-Abatement Clearances (5.8) Personal Protective Equipment and Respiratory Protection (5.9) Housekeeping (5.10) Medical Surveillance... 12

3 (5.11) Recordkeeping (5.11.1) External Contractors (5.11.2) External Consultants (5.11.3) Environmental Coordinator / EH&S (6.0) Notifications and Communication (6.1) Building Occupants and Contractors (6.2) Notifications to the State of Michigan (6.3) Notification to the Environmental Coordinator (7.0) Project Design (8.0) External Contractor and Consultant Prequalification (9.0) Emergency Response Procedures (10.0) Best Management Practices (11.0) References (12.0) Appendices... 19

4 (1.0) Plan Information (1.1) Contact Information Asbestos Emergencies Service Center Action Line (after-hours) (989) (989) CMU Environmental Health and Safety (989) Program Administrator Jeff Suty, Environmental Coordinator (1.2) Plan Status This revised plan becomes effective January 1, (1.3) Understanding this Plan To assist with the understanding of the Asbestos Management Plan, select terms are defined in the Glossary, which can be found in Appendix A. The first usage of a term in this plan which is included in the Glossary is italicized. (1.4) Communication Policy All submissions required by this plan, including all applications, documents, forms, etc. must be ed in Portable Document Format (PDF) to: environmental@cmich.edu. All submissions will receive an auto-response confirming receipt. If you do not receive this auto-response confirmation receipt within one (1) hour, call the CMU Environmental Health and Safety (EH&S) Department for assistance. Unless otherwise noted, hard copies (mailed or faxed) will not be accepted. 1

5 (1.5) Prequalified Asbestos Contractors and Consultants This section lists asbestos abatement contractors and consultants who have earned prequalification status for the 2016 calendar year. Only prequalified contractors and consultants are permitted to be retained for asbestos-related work for CMU. (1.5.1) Asbestos Abatement Contractors Asbestos Abatement, Inc. HBC Specialized Contracting 2420 N. Grand River Ave Apollo Drive Lansing, MI Lansing, MI (517) (517) Attn: Eric Kuznicki Attn: Brett Eberhard Certified Abatement Services, Inc. Trust Thermal Abatement, Inc Gorey Ave. 210 S. Water St. Flint, MI Owosso, MI (810) (989) Attn: Richard Jacques Attn: Dave Baldwin, Jr. (1.5.2) Asbestos Consultants Arch Environmental Group, Inc. Nova Environmental, Inc Interchange Drive 5300 Plymouth Road Farmington Hills, MI Ann Arbor, MI (248) (734) Attn: Scott P. Staber Attn: Jeff Benya Fibertec Industrial Hygiene Services ATC Group Services LLC 1914 Holloway Drive Humboldt Drive Holt, MI Novi, MI (517) (248) Attn: Phillip A. Peterson Attn: Robert Smith 2

6 (2.0) Introduction Asbestos is a fibrous material which was installed in many University buildings because of its characteristics of strength, heat resistance and chemical resistance. Exposure to asbestos can result in serious health problems. Proper control measures must be in place to prevent the disturbance of asbestos-containing materials (ACM) and to prevent potential exposure to airborne asbestos. However, the mere presence of asbestos in a building does not mean the health of the building occupants is endangered. In general, exposure may occur only when the ACM is disturbed or damaged in some way to release particles and fibers into the air (United States Environmental Protection Agency, 2014). Unauthorized removal or disturbance of ACM is not only dangerous, it is also illegal. Studies have shown that individuals exposed to asbestos fibers over a long period of time may develop lung cancer, Asbestosis, and Mesothelioma. The typical latency periods for these diseases range from years. Rather than removing all ACM upon discovery, the Environmental Protection Agency (EPA) recommends a pro-active, in-place management program (United States Environmental Protection Agency, 1990). The EPA only requires asbestos removal in order to prevent public exposure to asbestos, such as during building renovation or demolition. Central Michigan University has maintained an effective in-place management program for several years. This program ensures that the day-to-day management of University owned buildings minimizes the release of asbestos fibers into the air, and ensures that when asbestos fibers are released, either accidentally or intentionally, proper control and clean-up procedures are implemented. In order to follow this guideline, the University's asbestos management program involves identifying existing asbestos and maintaining it in place in good condition. (2.1) Scope This Asbestos Management Plan (AMP) applies to all University owned buildings, structures, machinery and equipment at the main campus, Beaver Island, Neithercut Woodlands, College of Medicine and all global campus locations. It applies to all employees and students of the University, occupants of University buildings and to external organizations who may come into contact with or disturb asbestos-containing materials in University buildings. (2.2) Purpose and Objectives The purpose of this AMP is to establish a program to manage and control all asbestoscontaining materials within Central Michigan University owned buildings of the main and global campuses as well as Beaver Island, Nethercutt Woodlands and the College of Medicine, and all activities which may disturb such materials, including maintenance, alteration, and repair operations. 3

7 The objectives of this program are to: Exercise due diligence in protecting the University community from the potential health risks associated with exposure to airborne asbestos fibers, which includes faculty, staff, students, visitors and external contractors and consultants; Comply with all applicable regulations; Ensure compliance with this program by all employees and external contractors and consultants. (2.3) Disclaimer This program is not a substitute for proper asbestos training and is not a complete reference for asbestos information. Please consult Section (3.0) Applicable Regulations below or contact the Program Administrator/Environmental Coordinator for more information. Where conflict exists between any of the following: 1) this Asbestos Management Plan, 2) project specific specifications, 3) any other form of communication between CMU representatives and the University community, and 4) applicable regulations, the most stringent shall apply. (3.0) Applicable Regulations The CMU Asbestos Management Plan has been established to comply with the following regulations: Asbestos Standards for General Industry, Part 305 Asbestos Standards for Construction, Part 602 Asbestos National Emissions Standards for Hazardous Air Pollutants (NESHAP) Asbestos Model Accreditation Plan (MAP) Title 49 Transportation, Volume II Asbestos Workers Accreditation Act, Michigan Act 440 P.A. of 1988 Asbestos Abatement Contractors Licensing Act, Michigan Act 125, P.A. of 1986 (4.0) Responsibilities All campus members, including faculty, staff, students, visitors, and external contractors and consultants are expected to follow the requirements outlined in the Section 5.0, General Asbestos Compliance. In addition, in order to increase the effectiveness of this asbestos management plan, this section designates specific responsibilities for the University Community. 4

8 (4.1) University Employees and Student Workers All University Employees and Student Workers have a responsibility to: 1. Not clean, damage, disturb, or remove asbestos-containing materials. 2. Abide by all access control restrictions posted on areas containing asbestos material. 3. Contact your supervisor to: a. Have a suspect asbestos-containing material identified. b. Report suspected asbestos debris or damaged asbestos-containing materials. 4. Attend appropriate initial and refresher trainings as directed by your supervisor and/or the Environmental Coordinator (EC). (4.2) Facilities Management and Res Life Supervisors Facilities Management and Res Life Supervisors have the responsibility to: 1. Assure that information and procedures contained within this Asbestos Management Plan are strictly followed by all personnel. 2. Notify the EC when new employees are hired so they may be properly trained, if necessary. If a new employee will perform housekeeping activities or otherwise work around ACM or presumed asbestos-containing materials (PACM), ensure they receive initial asbestos awareness training. 3. Contact the EC or CMU EH&S for testing of suspect materials encountered during routine operations. 4. Immediately contact the EC or EH&S for cleanup/repair if an employee reports that ACM has been discovered in a damaged state or was accidentally disturbed. 5. Coordinate annual air sampling with the EC to keep Negative Exposure Assessments (NEA s) current. 6. Ensure that authorized employees are following proper work procedures while handling ACM and, if an NEA is relied upon, that is listed as current by the EC. (4.3) University Stores University Stores has the responsibility to: 1. Collect surplus PACM materials from campus only after inspection and approval from the EC. 2. Maintain training consistent with Class IV asbestos work operations as defined in this management plan. 5

9 (4.4) Plant Engineering & Planning (PEP) PEP and EH&S have developed an Environmental Work Procedure that defines the requirements for completion of environmental work by Facilities Management. This work procedure can be found in Appendix F. (4.5) External Project Managers, General Contractors, and Subcontractors External Project Managers, Construction Managers, General Contractors, and Subcontractors have the responsibility to: 1. Ensure compliance of all provisions of the applicable regulations governing asbestos operations, project-specific asbestos abatement specifications, and this management plan. 2. Ensure all employees have received asbestos awareness training including information of the presence, quantity and location of site-specific materials. 3. Not impact ACM or PACM unless specifically trained and authorized to do so. 4. Stop work immediately and contact the assigned PEP Project Manager if a previously unidentified ACM or PACM is discovered. 5. Communicate asbestos work hazards to all other trades on the project site. (4.6) External Asbestos Abatement Contractors External Asbestos Abatement Contractors have the responsibility to: 1. Follow all provisions of the applicable regulations governing asbestos operations, project-specific asbestos abatement specifications, and this management plan. 2. Maintain Type II contactor licensure from Michigan Department of Licensing and Regulatory Affairs (MDLARA) as well as appropriate insurance coverage. 3. Receive approval from the EC before requesting a regulatory variance from any state agency. Approval from the EC must be requested in writing by completing the Variance Request Form, which can be found in Appendix B. 4. Apply for prequalification to be considered to receive or maintain prequalified status. (4.7) External Asbestos Consultants External Asbestos Consultants have the responsibility to: 1. Follow all provisions of applicable regulations governing asbestos operations, project-specific asbestos abatement specifications, and this management plan. 2. Use only individuals with current initial and refresher training and current accreditation as Asbestos Building Inspectors by MDLARA for the collection bulk samples or to perform type I and type II asbestos inspections. 6

10 3. Use only individuals with current initial and refresher training and current accreditation as Asbestos Project Designers by MDLARA to create specifications and/or project documents for asbestos abatement activities. 4. Ensure that all on-site personnel have current asbestos contractor/supervisor initial and refresher training and current accreditation as Asbestos Contractor / Supervisor by MDLARA. 5. Ensure that asbestos abatement work is conducted in accordance with all applicable regulations, the project specific specification, and this management plan. If non-compliant work practices are observed, the air monitoring professional shall take corrective action on-site and notify the EC and the appropriate Project Representative. 6. Respond to reports of accidental disturbances for cleanup or repair. 7. Provide technical review of project design and specifications for asbestos abatement on Purchase Order and Project Request projects. 8. Annually apply for prequalification to be considered to receive or maintain prequalified status. (4.8) CMU Department of Environmental Health and Safety The CMU Department of Environmental Health and Safety has the responsibility to: 1. Maintain the AMP and revise as necessary. 2. Provide and coordinate necessary asbestos training for CMU staff and students. 3. Conduct asbestos identification activities. 4. Maintain records of all building surveys, material sampling, training, abatement activities, air monitoring, and negative exposure assessments. 5. Provide technical review of project design and specifications for asbestos abatement projects. 6. Annually prequalify external asbestos abatement contractors and consultants for asbestos related activities on CMU properties. 7. Investigate asbestos concerns of student, faculty, staff, contractors, building occupants, and visitors. 8. Periodically monitor activities at asbestos abatement job sites for compliance to applicable regulations. 9. Review State of Michigan project notifications. 10. Approve or deny regulatory variance requests from contractors. 11. Meet with all regulatory agencies as needed for inspections and asbestos related inquiries. 12. Ensure only prequalified contractors and/or consultants perform asbestos related activities. 7

11 (5.0) General Asbestos Compliance Section 3.0 (Applicable Regulations) apply to the University community on any Central Michigan University owned property and are incorporated by reference in to this program. The material presented in this portion of the management plan addresses CMU specific requirements for asbestos related work. This section is designed to supplement and not replace any regulatory requirements. Please see the disclaimer in Section 2.3 for additional information. (5.1) Prohibitions The following activities which disturb or may disturb asbestos-containing material or suspect material are strictly prohibited: 1. Wet or dry sweeping (including during pre-cleaning operations); 2. Dry vacuuming; 3. Glovebag removal without negative pressure. (5.2) Asbestos Surveys Type I asbestos surveys have been conducted for most campus buildings in compliance with the regulations set forth in the OSHA General Industry Standard for Asbestos, 29 CFR The purpose of these surveys is to determine the presence, location and quantity of accessible ACM. During the survey, representative samples of each suspect material are taken and analyzed at an accredited independent laboratory. Copies of completed surveys are maintained by EH&S. Records are available through the EH&S website and also by contacting the EC. A Type II survey must be conducted whenever a building is scheduled for renovation or demolition to comply with the requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAP). The purpose of this survey is to review the findings of Type I survey and to conduct destructive testing to find all hidden ACM which may be disturbed as part of the renovation or demolition project. Typical work includes identifying, sampling, and quantifying fire doors, roofing, caulks, glazing compounds and other materials previously assumed to contain asbestos. Formerly inaccessible spaces such as pipe chases, tunnels, and ceiling cavities must also be evaluated. (5.3) Training Training is required for all employees who perform Class I through IV asbestos work. The training must meet the requirements of the EPA Model Accreditation Plan (MAP). CMU employees and student workers are prohibited from performing Class I-III work. All Class I-III work will be conducted by external contractors who meet the prequalification requirements as described in this AMP. External contractors must 8

12 comply with all applicable regulations, including all training requirements when working on any CMU property. CMU does not provide training to non-university personnel. Class IV asbestos work involves maintenance and custodial activities during which employees contact but do not disturb ACM and PACM. Initial two-hour asbestos awareness training (conducted by the EC or the EC s designee) is required for all new custodial, maintenance, housekeeping and service personnel who work in buildings that contain asbestos. Annual refresher training is also required and is available through the EH&S On-line Training website, or during face to face sessions. (5.4) Negative Exposure Assessments A Negative Exposure Assessment, or NEA, is a demonstration by an employer that an employee's exposure is consistently below the Permissible Exposure Limits (PELs). NEAs are job specific and apply only to the work place conditions, type and amount of material, asbestos type and percent by weight, control methods, work practices, and environmental conditions which closely resemble those of the activity to be represented. NEAs only apply to projects in which current workers experience is equal to or greater than the workers used in the development of the NEA. An NEA must rely on data collected within the previous 12 months and is not transferrable between companies. (5.5) Asbestos Abatement Work Practices The following work practices are required during asbestos abatement projects: Only high efficiency particulate air (HEPA) filtered vacuums as described in the definition found in the Glossary are permitted. A Shop Vac equipped with a HEPA filter does not meet this requirement. Brooms and other sweeping equipment or supplies are not allowed for any asbestos-related work, including pre-cleaning activities. All asbestos waste stored on campus must be placed in closed top dumpsters. The dumpsters must be lined with 6-mil polyethylene sheeting and appropriate warning signs must be posted. The dumpster must remain locked at all times when not in attendance by a competent person. Mastic removal operations is considered non-intact, friable removal and must be conducted within a full negative pressure enclosure as defined within the MIOSHA Asbestos for Construction Standard. Chemical removal treatments will not be permitted, unless approved by the EC via the Variance Request Form in Appendix B. For ACM mastic/adhesive abatement, all material must be completely abated. No encapsulant shall be applied until a success visual inspection and fingernail test has passed. 9

13 All glovebag operations must be conducted either by using the negative pressure glovebag method or by installing a negative air machine for local exhaust and venting it out-of-doors. Plexiglas windows shall be installed and kept clean/clear on enclosures or other critical barriers upon request. Where decontamination units are required, they must be contiguous to the regulated area. Remote decontamination units are not permitted, unless approved by the EC via the Variance Request Form in Appendix B. Where negative pressure enclosures are required or specified, 0.02 inches of water column drop must be maintained during all operations until successful clearance has been achieved. This includes during bag-out operations. (5.6) Asbestos Abatement Air Monitoring All projects involving Class I-III asbestos work must include the following air monitoring during operations regardless of current NEA status: Representative (personal) exposure monitoring as follows: o Task specific sampling on at least 25% of the work force. o Task specific 30-minute excursion limit (EL) sampling at least once per day, per task. Perimeter sampling from areas adjacent to the restricted areas. If negative air machines (NAMs) are exhausted inside a building, the exhaust must be monitored. The regulatory limits for asbestos abatement air monitoring are as follows: Type of Air Monitoring 8-Hour Time Weighted Average (TWA) 30-Minute Excursion Limit Perimeter / NAM Exhaust *f/cc = fibers per cubic centimeter Regulatory Limit 0.1 f/cc* 1.0 f/cc 0.01 f/cc The EC must be notified immediately if an air monitoring result(s) exceed the above referenced regulatory limits. External contractors and consultants must use the PCM Analytical Report, or equivalent, found in Appendix C for the collection and analysis of all PCM samples. Equivalent forms must include all information found on the above referenced form. (5.7) Post-Abatement Clearances A thorough visual inspection pursuant to the current version of the ASTM Standard E1368 or equivalent (e.g., EPA Publication 560/ ) is required following the completion of all projects involving the disturbance of ACM. Additionally, for all Class I and Class II projects, all air monitoring data must be below regulatory limits. If any air monitoring data is not within regulatory limits, immediately contact the EC. 10

14 For all projects consisting of the removal of 10 or more linear feet (l.f.) or 15 or more square feet (s.f.) of friable ACM conducted within a negative pressure enclosure, an aggressive post-abatement air clearance is required. An aggressive post-abatement air clearance may only be conducted following a successful visual inspection. This inspection shall be conducted pursuant to the current version of the ASTM Standard E1368. An aggressive post-abatement air clearance may also be required following the completion of other asbestos removal projects, as determined by the EC on a case-bycase basis. A passive post-abatement air clearance may only be conducted if an aggressive post-abatement air clearance is infeasible. All post-abatement air clearances (aggressive and passive) require representative PCM air samples with a minimum of 1200 liters of air. Transmission Electron Microscopy (TEM) clearance sampling may be required in special circumstances (e.g., environments with fiberglass insulation). While the State of Michigan requires a clearance level of 0.05 f/cc for all asbestos removal projects involving 10 or more linear or 15 or more square feet of friable asbestos, all projects on CMU owned properties must use the EPA recommended clearance level of 0.01 f/cc. Where TEM samples are collected, each sample must be below the clearance level of 70 structures per square millimeter (70 s/mm²). If any of the requirements of this section cannot be met, the Variance Request Form must be completed and submitted to the EC. The request must include the specific reason(s) for the variance and the proposed alternative(s). The EC will approve or deny this request in writing. External contractors (and when retained for air monitoring and/or project oversight, external consultants) must complete the Visual Inspection Certification Form found in Appendix D. Completed Visual Inspection Certification forms must be submitted to the EC either by or by hard copy in person no later than the following business day after the visual inspection. An electronic copy must be submitted by with the final report/invoice. The EC must be notified immediately if any clearance results are at or exceed the above referenced limits. (5.8) Personal Protective Equipment and Respiratory Protection All University employees must be provided with proper protective equipment (PPE) and respirators when assigned to Class IV work that takes place in a regulated area. The University maintains a Respiratory Protection Program and a Personal Protective Equipment Plan for its employees. Click on the above links or contact EH&S for information on these programs. 11

15 (5.9) Housekeeping All surfaces shall be maintained free of ACM waste, debris, and accompanying dust. Surfaces contaminated with asbestos may not be cleaned using compressed air. Do not drill holes, hammer nails into, hang objects from, touch with curtains, or move furniture that damages ACM or PACM. Waste, debris, and accompanying surface dust in areas containing accessible and/or visibly deteriorated ACM, shall not be dusted, swept, shoveled dry, or vacuumed without using a High Efficiency Particulate Air (HEPA) filter. The following restrictions exist for the care of ACM flooring: No sanding is permitted; Stripping of finish may be conducted suing low abrasion pads at speeds lower than 300 RPM with wet methods; If asbestos-containing flooring material has sufficient finish, brushing or dry buffing is permissible; and Broken ACM floor tiles should only be removed by properly trained personnel. Ceiling tiles should not be moved or replaced until it is confirmed that they are not ACM. In buildings where spray-applied surfacing materials are known to exist above drop ceilings, tiles must be decontaminated before they are disturbed. Only trained personnel can replace, decontaminate, or otherwise disturb ACM ceiling tiles or tiles that may be contaminated by ACM surfacing material above. (5.10) Medical Surveillance The University maintains a medical surveillance program for all employees who are engaged in Class I-IV work for a combined total of more than 30 days per year or are exposed at or above either or both PELs. This medical surveillance consists of a review of medical and work history, a physical exam directed to the pulmonary and gastrointestinal systems, a chest roentgenogram interpreted by a NIOSH certified B Reader, and pulmonary function tests. This exam is offered annually at no charge to affected employees. For employees otherwise required to wear a respirator, a physician will determine whether or not employees are able to perform the work and use the equipment. For further information on medical surveillance, contact your supervisor or Health Services at (989) (5.11) Recordkeeping Detailed, accurate recordkeeping is essential to a successful asbestos management plan. This section details CMU s recordkeeping requirements for external contractors and consultants, the EC/EH&S, and anyone else authorized to conduct work subject to this plan. 12

16 (5.11.1) External Contractors Prior to an external asbestos abatement contractor starting any Class I-IV asbestos work on CMU property, the contractor shall submit the following to the EC in Portable Document Format (PDF), unless a current copy is already on file with the EC: 1. The following records for each employee and subcontracted employee scheduled to work: a. A color copy of initial and current refresher asbestos worker or contractor / supervisor training certificates. b. A color copy of current asbestos worker or contractor / supervisor accreditation cards (front and back). c. A copy of a written physician s opinion as to whether or not the employee may wear a respirator. d. A copy of fit testing documentation for each type of respirator the employee is approved for. 2. Proof of compliance with CMU insurance and bond requirements. Details on insurance and bond requirements can be found here. 3. A copy of the company s current MDLARA Asbestos Abatement Contractor license (must be Type II). 4. A copy of the completed notification form, if applicable (see Section 6.0 below). 5. A Safety Data Sheet (SDS) for each hazardous chemical product brought on CMU property. Upon completion of each project involving any class of asbestos work, the abatement contractor shall submit the following to the EC in PDF. This documentation is required before the associated invoice will be approved for payment: 1. A completed and signed summary report for each work area in which any class of asbestos work was performed. The Asbestos Work Area Summary Report in Appendix E must be used to fulfill this obligation. 2. A copy of all air monitoring data as described in Section 5.4.* 3. A detailed written incident report for any and all issues of non-compliance and/or incidents when non-authorized individual(s) entered the work area. 4. All signed waste manifests returned from asbestos disposal facilities** *External contractors are not required to submit air monitoring data to the EC if an external consultant is retained by CMU to conduct project oversight/air monitoring. **Invoices may not be paid prior to the receipt of signed waste manifests at the sole discretion of the EC. 13

17 (5.11.2) External Consultants Prior to an external consultant starting any asbestos related work on CMU property, the consultant shall electronically submit the following to the EC in PDF, unless a current copy is already on file with the EC: 1. The following records for each employee and subcontracted employee scheduled to conduct any type of asbestos consulting work: a. A color copy of initial and current refresher contractor / supervisor training certificates. b. A color copy of current asbestos worker or contractor / supervisor accreditation cards (front and back). c. A color copy of initial and current refresher asbestos building inspector training certificates. d. A color copy of current asbestos worker or asbestos building inspector accreditation cards (front and back). e. A copy of a written physician s opinion as to whether or not the employee may wear a respirator. f. A copy of fit testing documentation for each type of respirator the employee is approved for. 2. In addition to #1 above, the following records for each employee and subcontracted employee scheduled to conduct project oversight and/or asbestos air monitoring work: a. A color copy of NIOSH 582 equivalency training certificates. 3. For asbestos projects involving the analysis of bulk samples by Polarized Light Microscopy (PLM), the following is required from the laboratory conducting the analysis: a. A current color copy of the laboratory s NVLAP certificate, or equivalent. 4. Proof of compliance with CMU insurance and bond requirements. Details on insurance and bond requirements can be found here. 5. A SDS for each hazardous chemical product brought on CMU property. (5.11.3) Environmental Coordinator / EH&S Specific records must be kept regarding asbestos related activities, including but not limited to: 1. All required documentation in Sections to Training records for affected CMU staff, faculty and student workers. 3. A color copy of all State of Michigan accreditation cards required to be held by CMU personnel. 4. Exposure monitoring records for all workers performing Class I-IV asbestos work. 5. Respirator fit test records each type of respirator worn. 6. Medical records are kept on file by the Worker s Compensation office. 7. Other records or information as required by this management plan or existing regulations shall be maintained by the EC/EH&S as necessary. 14

18 (6.0) Notifications and Communication (6.1) Building Occupants and Contractors The following shall be notified of the presence, location, and quantity of ACM and/or PACM: 1. Prospective employers who are applying or bidding for work whose employees may be expected to work in or adjacent to areas containing ACM or PACM. 2. Contractors hired to work in or adjacent to areas containing ACM or PACM. 3. University employees and building occupants who may work in or adjacent to areas containing ACM or PACM. 4. Tenants who occupy University spaces containing ACM or PACM. (6.2) Notifications to the State of Michigan All contractors are required to notify the Michigan Department of Environmental Quality, Air Quality Division (DEQ-AQD) if conducting demolition, regardless of the date of construction of the building. Additionally, asbestos abatement contractors are required to submit a notification to the MDLARA and DEQ-AQD if the quantity of friable and/or regulated ACM being removed meets the following criteria: 1. DEQ-AQD (NESHAP) [260 l.f., 160 s.f., 35 cubic feet or more is threshold] a. Planned Renovation - 10 working day notice b. Emergency Renovation c. Scheduled Demolition - 10 working day notice d. Intentional Burn - 10 working day notice e. Ordered Demolition f. Non-Asbestos Demolition - 10 working day notice 2. DLARA (MIOSHA) [>10 l.f. or >15 s.f. is threshold] a. Demolition, Renovation, or Encapsulation - 10 calendar day notice b. Emergency Renovation/Encapsulation The contractor submitting a notification form to DEQ-AQD or MDLARA must send a copy to the EC. Notifications must be ed to environmental@cmich.edu. In situations where a variance of work methods must be requested of either agency, the contractor or consultant must first complete the Variance Request Form, which can be found in Appendix B and submit it by to the EC. 15

19 (6.3) Notification to the Environmental Coordinator Notification shall be made to the EC of the following occurrences: 1. Project meetings with asbestos contractors or environmental consultants. 2. Pre-bid, pre-construction kickoff and project progress meetings for projects with asbestos abatement components. 3. Notifications to State agencies as detailed in Section 6.2. Copies of subsequent revisions to a notification must also be submitted to the EC. 4. Inspections from state or federal agencies regulating asbestos, such as MIOSHA, DEQ-AQD, OSHA, and EPA. (7.0) Project Design Certain asbestos abatement activities warrant development of a comprehensive project design. These documents define the expectations of the University, the requirements of the work, the scope of the project, and can ultimately be used as part of the bid process. Most projects are simple enough that no project design is required and a "scope of work" letter may be all that is needed. The determination to prepare a formal specification or scope of work will be made on a case by case basis by the PEP Project Manager and the EC. If formal specification documents are produced for a project they must be prepared by a Project Designer accredited by the MDLARA. (8.0) External Contractor and Consultant Prequalification As of January 1, 2015, external asbestos contractors and consultants wishing to conduct asbestos related activities for CMU must first be prequalified by the Department of EH&S. Asbestos contractors and consultants selected for prequalification will be approved for one (1) calendar year and will need to reapply every fall. Prequalification applications for the following calendar year will be released on or before September 1 at and will be due by October 1 that same year. Contractors and consultants selected for prequalification will be notified by December 1 that same year. Successful prequalification does not specifically guarantee work with CMU. CMU reserves the right to waive prequalification requirements for asbestos contractors and/or consultants on a case by case basis. A waiver of prequalification must be in writing from CMU EH&S and will be specific to a single project. CMU also reserves the right to remove companies from the prequalified list for noncompliance with applicable asbestos and/or other regulations, project-specific asbestos specifications, and/or this asbestos management plan. 16

20 (9.0) Emergency Response Procedures A fiber release episode is any uncontrolled or unintentional disturbance of asbestoscontaining building materials resulting in visible emission or debris. The likelihood of an emission depends on the friability of the material as well as the physical condition which includes the state of deterioration and/or delamination, physical damage, water saturation. In the event of an asbestos fiber release episode the following procedures should be immediately followed: 1. Do not attempt to clean; 2. Exit the area and restrict access by others by posting appropriate warning signs; 3. Notify your supervisor. If your supervisor is not available contact the Plant Engineering and Planning department at (989) (contractors) or CMU EH&S at (989) (contractors or staff); 4. Shut down the HVAC system serving the area; and 5. EH&S will design an appropriate action and engage asbestos abatement contractor(s) and asbestos consultant(s) as necessary. (10.0) Best Management Practices EH&S maintains the "Best Management Practices" guidelines for operations. Current Best Management Practices at CMU include: 1. Abate ACM impacted during the course of renovation or any other work activities. 2. If a building or portion of a building will be demolished, all ACM must be abated, including NESHAP Category I and Category II non-friable materials. 3. Do not cover any ACM including vinyl floor tile, mastic, rolled vinyl flooring products, pipe insulation, or any other material that has the potential to deteriorate while covered. Leaving these materials results in much higher costs and presents complications for future projects. 4. Fire doors containing an asbestos core shall not be modified in any way if contact with or disturbance of the asbestos within the door is required to make the modifications. 5. Do not use asbestos containing lab gloves, wire mesh screens, test-tube holders or other similar laboratory equipment. Contact the EC for disposal options. 6. No material containing asbestos shall be installed on CMU owned property at any time for any reason. 7. Non-asbestos replacement thermal systems insulation shall be colored blue, embedded with gold color coding (or similar feature), or shall be permanently signed in a manner that future contractors and CMU staff can easily recognize the replacement product as non-asbestos and can easily determine the limits of the replacement product. 17

21 (11.0) References United States Environmental Protection Agency. (1990). Managing Asbestos In Place. United States Environmental Protection Agency. (2014, March 16). Learn About Asbestos. Retrieved from 18

22 (12.0) Appendices Appendix A Glossary

23 Adequately wet: Sufficiently mix or penetrate with liquid to prevent the release of particulates. If visible emissions are observed coming from asbestos-containing material, then that material has not been adequately wetted. However, the absence of visible emissions is not sufficient evidence of being adequately wet. Aggressive post-abatement air clearance: Post-abatement air sampling conducted in accordance with unit III.B.7.d. of 40 CFR Part 763, Subpart E, Appendix A. Aggressive method: Removal or disturbance of building material by sanding, abrading, grinding or other method that breaks, crumbles, or disintegrates intact ACM. Asbestos: Includes chrysotile, amosite, crocidolite, tremolite, anthophyllite, actinolite, and any of these minerals that has been chemically treated and/or altered. For purposes of this management plan, "asbestos" includes PACM, as defined below. Asbestos-containing material (ACM): Any material containing more than one percent asbestos. Asbestosis: The scarring of lung tissue resulting from exposure to asbestos. Authorized person: Any person authorized by the employer and required by work duties to be present in regulated areas. Category I non-friable ACM: Asbestos containing packings, gaskets, resilient floor covering, and asphalt roofing products containing more than 1% asbestos that cannot when dry be crumbled, pulverized, or reduced to powder by hand pressure. Category II non-friable ACM: Any material, excluding Category I non-friable ACM, containing more than 1% asbestos that cannot when dry be crumbled, pulverized, or reduced to powder by hand pressure. Class I asbestos work: Activities involving the removal of TSI and surfacing ACM and 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 may 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.

24 Closely resemble: The major workplace conditions which have contributed to the levels of historic asbestos exposure are no more protective than conditions of the current workplace. Competent person: In addition to the definition in 29 CFR (f), one who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure, who has the authority to take prompt corrective measures to eliminate them, as specified in 29 CFR (f): in addition, for Class I and Class II work who is specially trained in a training course which meets the criteria of EPA's Model Accreditation Plan (40 CFR part 763) for supervisor, or its equivalent and, for Class III and Class IV work, who is trained in a manner consistent with EPA requirements for training of local education agency maintenance and custodial staff as set forth at 40 CFR (a)(2). 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. DEQ-AQD: The Michigan Department of Environmental Quality Air Quality Division, which is responsible for enforcing the Asbestos NESHAP Standards. Disturbance: Activities that disrupt the matrix of ACM or PACM, crumble or pulverize ACM or PACM, or generate visible debris from ACM or PACM. This term includes activities that disrupt the matrix of ACM or PACM, render ACM or PACM friable, or generate visible debris. Disturbance includes cutting away small amounts of ACM or PACM, no greater than the amount which can be contained in one standard sized glove bag or waste bag in order to access a building component. In no event shall the amount of ACM or PACM so disturbed exceed that which can be contained in one glove bag or waste bag which shall not exceed 60 inches in length and width. Emergency renovation operation: A renovation operation that was not planned but results from a sudden, unexpected event that, if not immediately attended to, presents a safety or public hazard, is necessary to protect equipment from damage, or is necessary to avoid imposing an unreasonable financial burden. This term includes operations necessitated by non-routine failures of equipment. Employee exposure: Exposure to airborne asbestos that would occur if the employee were not using respiratory protective equipment. Enclosure: An airtight, impermeable barrier designed to prevent the release of asbestos fibers into the air. Fiber: A particulate form of asbestos, 5 micrometers or longer, with a length-to-diameter ratio of at least 3 to 1.

25 Friable: Material that when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. High-efficiency particulate air (HEPA) filtered vacuum: A vacuum which has been designed with a HEPA filter as the last filtration stage. A HEPA filter is a filter that is capable of capturing particles of 0.3 microns with 99.97% efficiency. The vacuum cleaner must be designed so that all the air drawn into the machine is expelled through the filter with none of the air leaking past it. Industrial hygienist: A professional qualified by education, training, and experience to anticipate, recognize, evaluate and develop controls for occupational health hazards. Inspection: An activity undertaken in a school building, or a public and commercial building, to determine the presence or location, or to assess the condition of, friable or non-friable asbestos-containing building material (ACBM) or suspected ACBM, whether by visual or physical examination, or by collecting samples of such material. Intact: ACM that has not crumbled, been pulverized, or otherwise deteriorated so that the asbestos is no longer likely to be bound with its matrix. Intentional burn: The intentional burning of a structure as a means of demolition. All ACM must be removed from a structure prior to its demolition by intentional burning. Latency period: The time between initial asbestos exposure and when a doctor definitively diagnoses the cancer. Mesothelioma: A rare form of cancer related to asbestos exposure. Miscellaneous material: Building material on structural components, structural members or fixtures, such as floor and ceiling tiles, and does not include surfacing material or thermal system insulation. Negative exposure assessment: A demonstration by the employer that employee exposure during an operation is expected to be consistently below the PELs. Ordered demolition: An order issued by a local or state government agency to demolish a structure in danger of imminent collapse. Passive post-abatement air clearance: Post-abatement air sampling which is not conducted in accordance with unit III.B.7.d. of 40 CFR Part 763, Subpart E, Appendix A. A passive final clearance is only allowed if it is not feasible to conduct an aggressive final clearance. PEP: The Plant Engineering and Planning department of Central Michigan University.

26 Permissible exposure limit (PEL): The maximum allowable exposure to asbestos at 0.1 fibers per cubic centimeter of air as an eight (8) hour time-weighted average Presumed asbestos containing material (PACM): Thermal system insulation and surfacing material found in buildings constructed no later than Project designer: A person who has successfully completed the training requirements for an abatement project designer established by 40 U.S.C. Sec (g) and maintains current annual refresher training, and maintains current accreditation by the State of Michigan as an Asbestos Project Designer. Regulated area: An area established by the employer to demarcate areas where Class I, II, and III asbestos work is conducted, and any adjoining area where debris and waste from such asbestos work accumulate; and a work area within which airborne concentrations of asbestos, exceed or there is a reasonable possibility they may exceed the permissible exposure limit. Requirements for regulated areas are set out in paragraph (e) of this section. Regulated asbestos-containing material (RACM): Friable asbestos material, Category I non-friable ACM that has become friable, Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by 40 CFR 61 (NESHAP). Removal: All operations where ACM and /or PACM is taken out or stripped from structures or substrates, and includes demolition operations. Renovation: Altering a facility or one or more facility components in any way, including the stripping or removal of RACM from a facility component. Operations in which loadsupporting structural members are wrecked or taken out are demolitions. Repair: Overhauling, rebuilding, reconstructing, or reconditioning of structures or substrates, including encapsulation or other repair of ACM or PACM attached to structures or substrates. Surfacing material: Material that is sprayed, troweled-on or otherwise applied to surfaces (such as acoustical plaster on ceilings and fireproofing materials on structural members), or other materials on surfaces for acoustical, fireproofing, and other purposes. Suspect material: Any thermal systems insulation, surfacing material or miscellaneous material which has not been sampled by an accredited asbestos inspector and analyzed by an accredited laboratory.

27 Thermal system insulation (TSI): Material applied to pipes, fittings, boilers, breeching, tanks, ducts or other structural components to prevent heat loss or gain. University community: Central Michigan University staff, faculty, and students, visitors, external contractors and subcontractors, external consultants, and the general public. Visible emissions: Any emissions, which are visually detectable without the aid of instruments, coming from RACM or asbestos-containing waste material, or from any asbestos milling, manufacturing, or fabricating operation. This does not include condensed, uncombined water vapor. Work area: An area in which Class I, II, III, IV, or any combination of Class I-IV asbestos work is performed. This includes, but is not limited to regulated areas, critical barrier enclosures, negative pressure enclosures, and mini-enclosures.

28 Appendix B Variance Request Form

29 CENTRAL MICHIGAN UNIVERSITY Variance Request Form Instructions: This form is required to be completed by a Competent Person (as defined in Part 602) and submitted electronically to the Environmental Coordinator (EC) at environmental@cmich.edu. This Variance Request Form must be approved by the EC prior to requesting a variance of any kind from any regulatory agency. Completion and approval of this Variance Request Form is also required to receive a variance from any provision of the most current revision of the Central Michigan University s Asbestos Management Plan (AMP). The latest version of the AMP was revised August 19, 2014 and became effective September 1, Approved variances are project specific and cannot be transferred between projects, project sites, or work areas. It is the responsibility of the contractor or consultant to obtain final variance approval from regulatory agencies, if required. All variance approval or denial letters must be immediately submitted to the EC upon receipt and before any work subject to the variance commences. Date of Request: Contractor/Consultant: Competent Person: CMU Work Order #: Building: Functional Space(s): Is the building occupied?: If yes, by whom: From which provision is the variance being requested? Include the regulation, contract, and/or plan name, section and other information as necessary to clearly identify which requirement the variance is being requested for. Reason for request?: Certification After review, the variance request as described above has been approved / denied. EC Signature: Date:

30 Appendix C PCM Analytical Report

31 Central Michigan University PCM Analaytical Report Page of CMU WO #: Project Location: Laboratory: Date: Contractor: Supervisor: Sample # Sample Type Sample Description Sample Time On/Off Sample Time (MIN) Flow On/Off (L/MIN) Avg. Flow Volume (Liters) Fibers Fields F/MM² F/CC Contractor Certification: Laboratory/Analyst Certification: I,, hereby certify that the above I,, hereby certify that: (Print Name) Sample Descriptions, Sample Times (On and Off), and Flow Rates (On and Off) are true and accurate. (Print Name) 1) The above samples were received in satisfactory condition. 2) All samples were analyzed in accordance with the NIOSH 7400 Method, Issue #2, "A" Counting Rules. Supervisor Signature: Analyst Signature: AMB - Ambient BSL - Baseline OTH - Other PAC - Post Abatement Clearance PACA - Post Abatement Clearance, AHERA PRM - Perimeter PRS - Personal EL - Excursion Limit * - Sample Occluded or Damaged

32 Appendix D Visual Inspection Certification

33 CENTRAL MICHIGAN UNIVERSITY Visual Inspection Certification Instructions: This Visual Inspection Certification is required to be completed by a Competent Person (as defined in Part 602) employed by the Contractor and, when retained for air monitoring and/or project oversight, the Environmental Consultant. Completed forms must be submitted to the Environmental Coordinator either by or by hard copy in person no later than the following business day after the visual inspection. An electronic copy must be submitted by with the final report/invoice. Do not fax this or any other form to EH&S. Work Order #: Building: Specific Work Area: Contractor Certification I, (Print Name), hereby certify that I have conducted a successful visual inspection pursuant to the current version of the American Society for Testing and Materials (ASTM) Standard E1368, Standard Practice for Visual Inspection of Asbestos Abatement Projects, or equivalent. Competent Person: (Signature) Date: Title: Environmental Consultant Certification I, (Print Name), hereby certify that I have conducted a successful visual inspection pursuant to the current version of the American Society for Testing and Materials (ASTM) Standard E1368, Standard Practice for Visual Inspection of Asbestos Abatement Projects, or equivalent. Environmental Consultant: (Signature) Date: Title:

34 Appendix E Asbestos Work Area Summary Report

35 Central Michigan University Asbestos Work Area Summary Report CMU WO #: Building: Date: Supervisor: Contractor: Room #: Description of Activity: Asbestos Activity Overview Work Class: Quantity: Friable: Notification Submitted: EL < 1.0 f/cc: TWA < 0.1 f/cc: Perimeter < 0.01 f/cc: All other samples < 0.01 f/cc: If no to any of the above, explain: Air Monitoring *Air monitoring is required for all asbestos activities, regardless of NEA status. Regulated Area Banner tape: Sign(s): Access restricted to authorized personnel only: Prohibited activities obeyed: If no to any of the above, explain:

36 Central Michigan University Asbestos Work Area Summary Report CMU WO #: Date: Personal Protective Equipment Respirators worn?: if yes: Half-face: Full-face: PAPR: Other: P100 filters: Other: Full-body coveralls?: Other PPE: Waste Waste properly containerized: Describe: Waste containers decontaminated: # of containers removed: Waste containers properly labeled: Waste containers stored on-site?: Waste containers removed from site?: Describe: If yes, submit the waste manifest to the EC Visual Inspection Certification I, (Print Name), hereby certify that I have conducted a successful visual inspection pursuant to the current version of the American Society for Testing and Materials (ASTM) Standard E1368, Standard Practice for Visual Inspection of Asbestos Abatement Projects or the EPA Publication 560/ , Guidance for Controlling Asbestos-Containing Materials in Buildings, or equivalent. Competent Person: Date: Title:

37 Central Michigan University Asbestos Work Area Summary Report CMU WO #: Date: Negative Pressure Enclosure Equipment room (ER) or multi-stage decon (MSD): If MSD, # of stages: If MSD, was shower compliant with Part 474?: Critical barriers: HVAC system isolated: If ER, 6-mil dropcloth for decon?: If ER, HEPA Vac decon?: Enclosure integrity checked: Impermeable dropcloths?: # of negative air machines operating: # of backup negative air machines installed: # of air exchanges / hour: Enclosure integrity checked?: Magnahelic/manometer: Negative pressure readings logged: Wet methods employed: Prohibited work practices obeyed?: Magnahelic/manometer calibrated within 12 months: Pressure < throughout entire process: HEPA vacuum (cleanup): GFCI(s): Notes/difficulites:

38 Central Michigan University Asbestos Work Area Summary Report CMU WO #: Date: Mini-Enclosure Equipment room (ER) or multi-stage decon (MSD): If MSD, # of stages: If MSD, was shower compliant with Part 474?: Critical barriers: HVAC system isolated: Negative air machine (NAM) or HEPA Vac (HV) used for negative pressure? Wet methods employed: Prohibited work practices obeyed?: If ER, 6-mil dropcloth for decon?: If ER, HEPA Vac decon?: Enclosure integrity checked: Impermeable dropcloths?: 6-mil poly walls: HEPA vacuum (cleanup): GFCI(s): Notes/difficulites:

39 Central Michigan University Asbestos Work Area Summary Report CMU WO #: Date: Regulated Area without Enclosure Equipment room (ER) or multi-stage decon (MSD): If MSD, # of stages: If MSD, was shower compliant with Part 474?: Critical barriers: Wet methods employed?: HVAC system isolated: If ER, 6-mil dropcloth for decon?: If ER, HEPA Vac decon?: Negative air machine for local exhaust: HEPA vacuum used?: Prohibited work practices obeyed?: Glovebag?: if yes: Glovebag completely covers ACM: Two workers present: Encapulant after removal/cleaning: Each glovebag (all) smoke tested: Dropcloth in place: Glovebag collapsed with HEPA Vac: Notes/difficulites:

40 Appendix F Environmental Procedure

41 Facilities Management ENVIRONMENTAL WORK PROCEDURE Applies to: - staff - student employees - visitors - contractors Purpose: Environmental Scope: Contracting for Environmental Work: This procedure defines the requirements for completion of environmental work by Facilities Management. The scope of environmental work associated with construction projects shall be developed as follows: At the beginning of the project the PEP Project Manager will work with the Environmental Coordinator to define the scope of work based on the following guidelines: All friable asbestos will be abated. All environmental materials (asbestos, PCB s, etc.) that are required to be removed to support the project scope shall be abated. Any environmental product that could be disturbed during the course of the work must be removed. For example, pipelines covered with asbestos insulation that could be bumped and damaged during the construction of the project shall be abated. Environmental materials shall not be covered up with new construction unless approved by the Manager of Risk Management, Environmental Health and Safety, Emergency Management and the Director of Engineering and Planning. For major building renovations, in general abatement contracts greater than $25,000, the Environmental Coordinator shall develop scope and estimate for the work required based on the above guidelines. In addition the Environmental Coordinator will develop a list of additional environmental work and an estimate for consideration. For maintenance and small projects work will be completed under the Master Service Agreements held by Environmental Health and Safety. This work shall be initiated by Facilities Management by the creation of a work order. For major building renovations and building demolition an Environmental Consultant will be hired to prepare plans and specifications so that the work can be bid to CMU Prequalified Contractors. These specifications shall be reviewed and approved by Environmental Health and Safety and Plant Engineering and Planning. C:\Users\suty1ja\AppData\Local\Microsoft\Windows\Temporary Internet Files\Content.Outlook\9WAXZWMQ\Environmental Work Procedure (002).doc Page 1 of 3

42 Facilities Management ENVIRONMENTAL WORK PROCEDURE Environmental Firm Prequalification: Environmental Health and Safety will maintain a list of prequalified environmental consultant firms and abatement contractors. Plant Engineering and Planning will restrict bidding for major projects to contractors that are on this list. If an expanded list of prequalified firms is desired for major projects, additional firms shall submit for CMU prequalification at least 30 days ahead issuing documents for bid. Environmental Consultant Selection: Abatement Contractor Selection: The contract for the Environmental Consultant will be held and managed by Environmental Heath and Safety. Selection of the firm will be done through Contracting and Purchasing Services. Plant Engineering and Planning will provide input into the selection process. It is expected Environmental Health and Safety and Plant Engineering and Planning work together to define requirements and contract the work so that selected consultants meet both the CMU technical and implementation requirements. Environmental Health and Safety will insure a Master Service Agreement is in place for routine maintenance and small projects. Plant Engineering and Planning will provide input to the selection process. Plant Engineering and Planning will lead the contracting and selection process for major renovations or building demolition. Environmental Health and Safety will provide input to the selection process. It is expected Environmental Health and Safety and Plant Engineering and Planning work together to define requirements and contract the work so that selected contractors meet both the CMU technical and implementation requirements. C:\Users\suty1ja\AppData\Local\Microsoft\Windows\Temporary Internet Files\Content.Outlook\9WAXZWMQ\Environmental Work Procedure (002).doc Page 2 of 3

43 Facilities Management ENVIRONMENTAL WORK PROCEDURE DOCUMENT CONTROL PAGE: Document Published: October X, 2016 Prepared By: Reviewed By: Approved By: Linda Slater Jon Kujat, Jeff Suty, Deb Goodwin, PEP staff Linda Slater Revision History: Date Revision Approved By: C:\Users\suty1ja\AppData\Local\Microsoft\Windows\Temporary Internet Files\Content.Outlook\9WAXZWMQ\Environmental Work Procedure (002).doc Page 3 of 3