Asbestos Management Program. Hamilton Wentworth Catholic District School Board 90 Mulberry Street Hamilton, On L8N 3R9

Transcription

1 Asbestos Management Program Hamilton Wentworth Catholic District School Board 90 Mulberry Street Hamilton, On L8N 3R9 September 2013

2 TABLE OF CONTENTS 1.0 INTRODUCTION Purpose of this Document Direction of the Asbestos Management Program DEFINITIONS BACKGROUND INFORMATION Occurrence and Types of Asbestos Asbestos-Contaminated Vermiculite Health Effects of Asbestos Exposures Asbestosis Mesothelioma Lung Cancer Other Asbestos-Related Conditions REGULATORY FRAMEWORK AND REFERENCE MATERIAL Regulatory Framework Summary of Applicable Reference Material DUTIES AND RESPONSIBILITIES Asbestos Coordinator(s) Management Health and Safety Committees Asbestos Contractors ACM ASSESSMENT AND RECORD DEVELOPMENT Existing Document Review Visual Assessment Location ACM Status Condition Friability Bulk Material Sampling Sample Collection Sample Analysis Accredited Analytical Laboratory ACM Record Development Documentation of ACMs Notification of Results Record Retention ACM Re-Assessment and Record Updates... 21

3 7.0 NOTIFICATIONS TO TENANTS AND WORKERS Tenants/Lessees Workers Maintenance Activities Contract Workers Maintenance Activities Construction Projects DUTIES, ACTIONS, RESPONSIBILITIES & ADMINSITRATIVE PROCEDURES FOR NOTIFYING AND CONDUCTING ASBESTOS WORK Workers Contract Workers Maintenance Workers (Minor work) Construction Workers (Major work) MANAGEMENT OF ASBESTOS CONTAINING MATERIALS Classification of Work Involving Asbestos Type 1 Operations Type 2 Operations Type 3 Operations Asbestos Abatement Operations Pre-Renovation Testing and Supplemental Assessment Cleaning Repair Encapsulation/Encasement Removal Asbestos Abatement Procedures Air Clearance Sampling and Monitoring INFORMATION & TRAINING Basic Asbestos Awareness Training Advanced Asbestos Awareness Training (Including Small Scale Disturbance as a Type 1) Asbestos Abatement Operations Type 2 & 3 Operations General Notes Regarding Training NOTIFICATION TO THE MINISTRY OF LABOUR Unexpected Discovery of ACMs Advance Notice of Type 2 Glove Bag and Type 3 Asbestos Operations CONCLUSIONS AND RECOMMENDATIONS... 35

4 LIST OF TABLES (IN TEXT) Table 1: Minimum Sampling Requirements... 17

5 LIST OF APPENDICES APPENDIX A APPENDIX B APPENDIX C General Asbestos Procedure Unexpected Discovery of Potential Asbestos-Containing Materials General Asbestos Procedure Emergency Asbestos Clean-Up Forms: - Asbestos Coordinator Contact Information - Form 1 ACM Assessment Update Log - Form 2 Notification Letter to Workers - Form 3 Planned ACM Work Review Form - Form 4 Asbestos Work Order Form - Form 5 Pre-Renovation Checklist - Form 6 Active Asbestos Abatement Project Inspection Form APPENDIX D Summary List of Additional BHI Asbestos Reports and Documentation

6 ASBESTOS COORDINATOR CONTACT INFORMATION HAMILTON WENTWORTH CATHOLIC DISTRICT SCHOOL BOARD ASBESTOS COORDINATOR (PRIMARY CONTACT) Name: Taylor Drysdale Cell: NA Phone: ext 2144 Fax: Office Location: 57 Stuart Street Asbestos Management Program - i - September 2013

7 1.0 INTRODUCTION 1.1 Purpose of this Document This document is intended to outline the procedures and work practices which are necessary for the management of asbestos-containing materials (ACMs) within all facilities which are owned and operated by the Hamilton Wentworth Catholic District School Board (). It is a designed to maintain a safe environment for students, staff and public as whole during facility maintenance, alteration, repair or other activities where ACMs may be disturbed. The overall purpose of this Asbestos Management Program (AMP) document is to: 1) Outline the s program for the control of worker exposure to asbestos as prescribed by Ontario Regulation 278/05; 2) Outline the regulatory framework surrounding asbestos and provide access to appropriate reference material pertaining to the identification and management of ACMs within facilities; 3) Outline the necessary processes for the ongoing identification, assessment, maintenance and management of confirmed, or suspected, ACMs within facilities, including record preparation and retention; and, 4) Outline the necessary processes for the adequate control of worker, contractor and occupant activities which may disturb, or will likely disturb, ACMs. This includes, but is not limited to, appropriate notification to workers, contractors and regulatory agencies regarding the presence of ACMs, clearly defined procedures for work involving, or in close proximity to, ACMs and training which is appropriate for a worker s task and/or likelihood of coming into contact with ACMs. 1.2 Direction of the Asbestos Management Program The, under the direction of the Asbestos Coordinator(s), will manage all ACMs within their facilities, as prescribed by Ontario Regulation 278/05, by: 1) Arranging regular assessments and/or reassessments of accessible ACMs within all facilities through the services of qualified asbestos consultants. This includes updating and maintaining current copies of such assessments at each location; 2) Responding to any concerns regarding known, or suspected, ACMs, including those materials which may become damaged through normal operations, wear and tear, maintenance, renovation, construction, demolition, or unforeseen events, by retaining a qualified asbestos consultant or certified asbestos contractor. Responses may include additional assessment, clean up, repair, removal, isolation or containment of the ACM so that it will not pose a risk of asbestos exposure to workers, occupants or members of the public; Asbestos Management Program September 2013

8 3) Establishing procedures for both minor and major disturbances and/or removals of asbestos during building maintenance, renovation, construction, restoration or addition; 4) Ensuring that practices in building maintenance, renovation, construction, restoration or addition incorporate the removal of ACMs whenever such work is undertaken and is practical and cost effective to do so; 5) Establishing a record of ACM maintenance and repair in each facility; 6) Providing necessary training to all workers who will perform or oversee Type 1 asbestos operations, as prescribed by Ontario Regulation 278/05; 7) Providing adequate asbestos awareness training to all workers who will, or will likely, come into contact with ACMs; and, 8) Consulting with the Joint Health and Safety Committee (JHSC) regarding this program and associated training, remedial work, sampling, reports, communication, notice to the Ministry of Labour and other general information. 2.0 DEFINITIONS ACM means asbestos-containing material; any material which contains 0.5% or greater asbestos content by dry weight (O.Reg.278/05, s.1); Act means Ontario s Occupational Health and Safety Act (OHSA); AMP means the Asbestos Management Program; Asbestos means any of the fibrous silicates listed below: a) Actinolite; b) Amosite; c) Anthophyllite; d) Chrysotile; e) Crocidolite; f) Tremolite (O. Reg.278/05, s.1); Asbestos Coordinator means the person(s) appointed to coordinate the AMP; Building means any structure, vault, chamber or tunnel including, without limitation, the electrical, plumbing, heating and air handling equipment (including rigid duct work) of the structure, vault, chamber or tunnel; (O.Reg.278/05, s.1); Certified Asbestos Contractor means a contractor who employs and utilizes workers for Type 3 asbestos removal operations that are certified by the Ministry of Training Colleges and Universities (MTCU) as: a) Asbestos Abatement Worker, Trade Code (AAW) 253W; b) Asbestos Abatement Supervisor, Trade Code (AAS) 2535; Asbestos Management Program September 2013

9 Competent worker, in relation to specific work, means a worker who. a) Is qualified because of knowledge, training and experience to perform the work; b) Is familiar with the Act and with the provisions of the regulations that apply to the work; c) Has knowledge of all potential or actual danger to health or safety in the work (O.Reg.278/05, s.1); Construction includes erection, alteration repair, dismantling, demolition, structural maintenance, painting, land clearing, earth moving, grading, excavating, trenching, digging, boring, drilling, blasting, or concreting, the installation of any machinery or plant, and any work or undertaking in connection with a project but does not include any work or undertaking underground in a mine (OHSA, s.1); Constructor means a person who undertakes a project for an owner and includes an owner who undertakes all or part of a project by himself or by more than one employer (OHSA, s.1); Demolition includes dismantling and breaking up; (O.Reg.278/05, s.1); Friable means any material that, a) When dry, can be crumbled, pulverized or powdered by hand pressure; or, b) Is crumbled, pulverized or powdered (O.Reg.278/05, s.1); HEPA Filter means a high efficiency particulate aerosol filter that is at least 99.97% efficient in collecting a 0.3 micrometre aerosol (O.Reg.278/05, s.1); Homogeneous material means material that is uniform in colour and texture (O.Reg.278/05, s.1); JHSC means the Joint Health and Safety Committee; refers to: a) A joint health and safety committee established under Section 9 of the Act; b) A similar committee described in Section 9(4) of the Act; or, c) The workers or their representatives who participate in an arrangement, program or system described in section 9(4) of the Act (O.Reg.278/05, s.1); Management Plan means a plan to provide for management of the asbestos in place, pending removal, and to establish the recommended response action; also See AMP; Non-friable means any material that; a) Cannot be crumbled, pulverized or powered by hand pressure; or Asbestos Management Program September 2013

10 b) Is not crumbled, pulverized or powdered; O.Reg.278/05 means Ontario s Regulation Respecting Asbestos on Construction Projects and in Buildings and Repair Operations, as made under Ontario s Occupational Health and Safety Act; Made June 8, 2005, filed June 10, 2005 and printed June 25, 2005; Owner means a trustee, receiver, mortgagee in possession, tenant, lessee, or occupier of any lands or premises used or to be used as a workplace, and a person who acts for or on behalf of an owner as an agent or delegate (OHSA, s.1); Project means any maintenance, construction or renovation work conducted by inhouse worker or outside contractors. This includes, but is not limited to, a construction project, whether public or private, including: a) The construction of a building, bridge, structure, industrial establishment, mining plant, shaft, tunnel, caisson, trench, excavation, highway, railway, street, runway, parking lot, cofferdam, conduit, sewer, water main, service connection, telegraph, telephone or electrical cable, pipe line, duct or well, or any combination thereof; b) The moving of a building or structure; and, c) Any work or undertaking, or any lands or appurtenances used in connection with construction (OHSA, s.1); Qualified Asbestos Contractor means a contractor that has submitted the appropriate documents for review and been approved by ; also see Certified Asbestos Contractors ; Qualified Asbestos Consultant means a consultant that possesses the knowledge, experience and credentials to perform asbestos-related work; Suspect ACM, Assumed ACM and Deemed ACM means material which is suspected to contain asbestos but has not been sampled and analyzed to confirm or refute visual identification; "Tenant" includes a person who pays rent in return for the right to occupy a building; Worker means a person who performs work or supplies services for monetary compensation but does not include an inmate of a correctional institution or like institution or facility in a work project or rehabilitation program (OHSA, s.1). Qualified Asbestos Personnel means a person who is qualified because of knowledge, training, and experience, is familiar with asbestos procedures/operations, and its management as prescribed by applicable Acts and Regulations. Asbestos Management Program September 2013

11 3.0 BACKGROUND INFORMATION 3.1 Occurrence and Types of Asbestos Asbestos is a fibrous, naturally-occurring silicate mineral which is strong, durable and resistant to chemicals and heat. Due to these desirable physical properties, asbestos has been historically incorporated into various construction materials including but not limited to building materials, finishes, thermal insulation, acoustical insulation and fireproofing. In general, there are six commercially relevant types of asbestos which have been used in construction: Chrysotile, Crocidolite, Amosite, Actinolite, Anthophyllite and Tremolite. Typically, the incorporation of asbestos into construction materials began in the 1930s and steadily increased with peak usage in the 1950s and 1960s. Following the discovery of adverse health effects associated with asbestos exposure, a sharp decline in asbestos use in construction materials occurred in the 1970s with most manufacturers switching to non-asbestos substitutions in the early to mid-1970s. Throughout the 1980s, a gradual phasing out of asbestos use occurred, and therefore buildings constructed in the 1980s have a potential for the presence of asbestoscontaining construction materials. Although the use of asbestos in construction materials typically began in the 1930s and was gradually phased out in the 1980s, consideration must be given to buildings constructed prior to the 1930s given that maintenance and renovation activities during times of peak usage could potentially have introduced asbestos-containing materials into these buildings. In accordance with Ontario Regulation 278/05, materials containing asbestos at a concentration of 0.5% or more by dry weight are considered asbestos-containing Asbestos-Contaminated Vermiculite Vermiculite is a mica-like mineral which was mined and commonly used as loose-pour insulation in concrete block walls, cavity walls and attics as thermal and acoustical insulation. Vermiculite mined in Libby, Montana from the 1920's to 1990 was sold in Canada under the brand name Zonolite and possibly other brand names. The vermiculite from the Libby Mine, which supplied the majority of the world market in vermiculite-based insulation 1, may be contaminated with asbestiform amphibole (asbestos or asbestos-like fibres). The asbestos contamination originates from naturally-occurring geological formations of asbestos which co-existed in the vermiculite formation. Libby vermiculite is subsequently cross-contaminated with unbound asbestiform which readily becomes airborne when disturbed. 1 It s Your Health -Vermiculite Insulation Containing Amphibole Asbestos, Health Canada September2009 Updated: September 2009 Original : March 2004 Her Majesty the Queen in Right of Canada, represented by the Minister of Health, Asbestos Management Program September 2013

12 Due to the nature of Libby vermiculite insulation being contaminated with unbound asbestos, rather than containing bound asbestos within the matrix of the material, and the subsequent mechanism and potentially high exposure concentration, the Ontario Regulation 278/05 threshold value for ACMs of 0.5% asbestos by dry weight should not be used as a cut off value to classify vermiculite as asbestos-containing or non-asbestos-containing. A significant exposure risk exists with concentrations of asbestiform in vermiculite below 0.5%. The percentage of asbestos identified in vermiculite cannot be directly or confidently correlated to an airborne concentration or worker/occupant exposure value. Although Ontario Regulation 278/05 does not specifically address asbestos contaminated vermiculite, it is considered prudent and diligent that vermiculite insulation containing any amount of asbestos be treated as asbestos-containing/contaminated material. Type 2 or Type 3 measures and procedures (as prescribed by Ontario Regulation 278/05) should be followed to control worker exposure to asbestos during activities such as maintenance, renovation, construction or demolition which may or will disturb vermiculite. Site specific risk and activity based exposure assessments can be conducted, however, they are typically costly and must be considered on a case-bycase basis. 3.2 Health Effects of Asbestos Exposures Asbestos has been recognized for many years as a health hazard for workers employed in its mining, production, processing and use. Several serious, and often fatal, diseases have been linked to the inhalation of asbestos fibres. Normally there is a latency period of more than ten (10) years between the first exposure to asbestos and the appearance of the disease Asbestosis Asbestosis is characterized by fibrosis (scarring) of the lung tissue, which makes breathing difficult. The most prominent symptom is breathlessness. Detection of asbestosis is possible by X-Ray examination and lung function testing. The disease is irreversible and will progress even after exposure has ceased. Rarely a cause of death itself, asbestosis results in an appreciable reduction in life expectancy from related illness Mesothelioma Mesothelioma is rare form of cancer that develops from transformed cells originating in the mesothelium, the protective lining that covers the many of the internal organs within the body. The most common anatomical sites for the development of mesothelioma associated with asbestos are the pleura (outer lining of lungs and internal chest wall), the peritoneum (the lining of the abdominal cavity) and the pericardium (the sac that surrounds the heart). The latency period for mesothelioma is typically between fifteen (15) to forty (40) years. Once develop, there is little to no effective treatment for Asbestos Management Program September 2013

13 mesothelioma; often patients die within a year of diagnosis and few survive longer than five (5) years Lung Cancer Unlike asbestosis and mesothelioma, lung cancer is not associated solely with asbestos exposure. There is little basic difference between the outcome of lung cancer caused by asbestos and lung cancer resulting from other causes. In general, the risk of contracting lung cancer increases as the exposure to asbestos increase. The risk of developing lung cancer is greatly enhanced by smoking Other Asbestos-Related Conditions A number of less serious effects have been associated with asbestos exposure, namely pleural plagues and asbestos warts. Pleural plagues are areas of scarring on the pleural surfaces. These are typically not a functional abnormality, but rather an indicator of asbestos exposure. Asbestos warts consist of skin growths that occur when asbestos fibres penetrate the skin. 4.0 REGULATORY FRAMEWORK AND REFERENCE MATERIAL 4.1 Regulatory Framework Under current health and safety legislation in Ontario, eleven (11) chemical agents are listed as Designated Substances due to their adverse effects on workers and the environment. Designated Substances in the work place are typically regulated by several key pieces of legislation, which prescribe agent-specific practices for their safe use, disturbance, identification, management and disposal. These key pieces of legislation, made under the Occupational Health and Safety Act (OHSA), are commonly referred to as the Designated Substances Regulations. Based on the known adverse effects associated with exposure, asbestos is one of the chemical agents listed as a Designated Substance. In Ontario, asbestos is regulated by the following Designated Substance Regulations: Ontario Regulation 490/09 entitled Designated Substances Ontario Regulation 278/05 entitled Designated Substance Asbestos on Construction Projects and in Buildings and Repair Operations Specifically, Ontario Regulation 490/09 regulates all Designated Substances; however, with respect to asbestos, it primarily regulates worker exposure during the manufacturing of asbestos-containing products. It includes requirements related to appropriate respiratory equipment, measurement of airborne fibres and medical surveillance of workers. Asbestos Management Program September 2013

14 On the other hand, Ontario Regulation 278/05 regulates the identification, management and disturbance of asbestos-containing materials (ACMs) within a building during construction, building and repair operations. As defined by Ontario Regulation 278/05, an ACM is any material which contains 0.5% or more asbestos by dry weight. With regards to the identification and management of ACMs within a building, Ontario Regulation 278/05 prescribes that: A building owner shall prepare, and keep on premises, a record of all ACMs within the building (Section 8(3)(a)). At a minimum, for each ACM, the record shall contain information regarding the location, friability, condition and type of asbestos present (Section 8(4)); A building owner shall inspect all ACMs at reasonable intervals, and at least annually, to re-assess their condition (Section 8(3)(f)); and, A building owner shall update the record at least annually, or whenever they become aware of new information relating to the ACMs (Section 8(5)). Once ACMs within a facility have been identified and an appropriate record has been prepared and updated regularly, there are no requirements to remove ACMs simply because they are present. However, as prescribed by Section 8 of Ontario Regulation 278/05, the building owner is required to implement and maintain a program for the management of asbestos within all facilities where ACMs are confirmed, or suspected, present. Typically, an Asbestos Management Program (AMP) consists of: The identification of ACMs within a facility; Providing notification to workers, contractors and tenants regarding the presence of ACMs within a facility; The control of employee exposure to asbestos fibres through: o Engineering controls; o Policies; o Procedures; o Training; o Personal protective equipment; o Hygiene; and, The maintenance of information regarding asbestos. In addition to the Designated Substances Regulations, the disposal of asbestos waste in Ontario is regulated by Ontario Regulation 347/90, made under Ontario s Environmental Protection Act and entitled General - Waste Management. As defined by Ontario Regulation 347/90, asbestos waste is any solid or liquid waste which results from the removal of asbestos-containing construction or insulation materials or the manufacture of asbestos-containing products and contains asbestos in more than a trivial amount or proportion. Asbestos Management Program September 2013

15 4.2 Summary of Applicable Reference Material The following Acts, regulations, guidelines and documents are applicable to the successful identification and management of ACMs within facilities and should be read in conjunction with this report (where appropriate): The Ontario Occupational Health and Safety Act (OHSA); Designated Substance Asbestos on Construction Projects and in Buildings and Repair Operations (Ontario Regulation 278/05); Designated Substances (Ontario Regulation 490/09); General Waste Management (Ontario Regulation 347/90); and, A Guide to the Regulation Respecting Asbestos on Construction Projects and in Buildings and Repair Operations (Ministry of Labour, 2007). Copies of these documents, as well as lists of commonly encountered ACMs, can be requested from the Asbestos Coordinator. In addition, Acts, regulations and/or guidelines can be downloaded from the Ontario Ministry of Labour website at It is the responsibility of the reader to ensure that they are referencing the most current version of the above mentioned documents. 5.0 DUTIES AND RESPONSIBILITIES 5.1 Asbestos Coordinator(s) The Asbestos Coordinator(s) is responsible for coordinating all aspects of this AMP, as outlined below. The Asbestos Coordinator shall: a. Ensure that this AMP is reviewed on at least an annual basis, and that necessary updates or revisions are completed. The JHSC shall be included in such a review; b. Review any correspondence or documentation pertaining to future amendments of asbestos regulations and/or procedures, and distribute such information to the affected departments and/or workers. Documentation of such information will be kept on file with the AMP; c. Arrange for ACMs within all facilities to be inspected on a regular basis and the ACM assessment report properly and completely updated, as required by this program and Ontario Regulation 278/05. This inspection/update must be conducted at least annually, or as new information becomes available; d. Arrange for the immediate repair of damaged and/or deteriorated ACMs, as identified during period periodic inspections; e. Ensure that notices are sent annually to departments and the JHSC reminding department representatives that copies of Form 1 (ACM Assessment Update Log) are to be completed by, and maintained by the Asbestos Coordinator; f. Ensure that any person, company, organization, or association who occupies the building(s) owned by the are given notice regarding any information in Asbestos Management Program September 2013

16 the ACM assessment which relates to the area occupied by the person, company, organization or association; g. Be appointed to a position including, but not limited to, Project Coordinator, liaison or similar role for all projects where known, or suspected ACMs will be disturbed. This includes those projects which will be conducted in the vicinity of known, or suspected, ACMs; h. Notify workers, building occupants and the JHSC of all ongoing asbestos projects; i. Ensure that any prospective constructor receives a copy of the ACM assessment report before requesting tenders, quotations, or costs; j. Review drawings, specifications, and documents of any and all proposed project(s) where known, or suspected, ACMs will be disturbed, and manage and coordinate the necessary ACM remediation, removal or repair work; k. Ensure that proper drawings, plans, and specifications (as appropriate) are prepared for each major abatement project, that the specifications properly reflect the requirements of the appropriate regulation(s), and that major projects are properly monitored by qualified consultants to ensure compliance with the specifications and applicable Acts, regulations, guidelines or standards; l. Ensure that all asbestos operations are inspected prior to, during, and after work is completed (as required) using Forms 5 and 6; m. Ensure that the contractor has notified, orally and in writing, the Ministry of Labour inspector nearest the workplace of any Type 3 operation, or Type 2 glove bag operation which involves the removal of greater than 1 m 2 of asbestoscontaining insulation from a pipe, duct or similar structure; n. Ensure that air monitoring is conducted following all Type 3 asbestos operations to ensure that airborne fibre concentrations are acceptable prior to dismantling the associated work enclosure(s); o. Ensure that air monitoring results, following Type 3 asbestos operations, are posted in a conspicuous location within the facility where the samples are collected, with a copy provided to the JHSC. All air monitoring results should be retained for a period of at least one (1) year following receipt; and, p. Ensure that a qualified asbestos consultant and/or certified asbestos abatement contractor is retained (if necessary) when an unscheduled emergency response asbestos maintenance activity occurs. 5.2 Management Management is responsible for ensuring that this AMP is adhered to within their department and/or jurisdiction, and shall: a. Notify the Asbestos Coordinator of any planned or proposed renovation, alteration or demolition project which will disturb, or will likely to disturb, ACMs. Notification to the Asbestos Coordinator should be provided an adequate length of time prior to commencement of the project to allow for proper record review and/or supplemental assessment (where required); Asbestos Management Program September 2013

17 b. Ensure that all new workers, management or occupant employees receive the appropriate asbestos training as required by this AMP, and as prescribed by Ontario Regulation 278/05; and, c. Be prepared to provide prompt response to unscheduled asbestos-related maintenance activities (i.e. leaking pipes, must do emergency response work, clean-ups involving minor amounts of ACM, or any activity which may disturb ACMs). 5.3 Health and Safety Committees Joint Health and Safety Committees shall be: a. Consulted prior to any asbestos remedial actions involving facilities within their areas of responsibility; b. Consulted prior to any asbestos sampling or inspections which may be required, and shall be given the opportunity to attend at the start of such activities; c. Provided with copies of all reports, sampling results and general information regarding any asbestos related activity; and, d. Notified of any and all training. 5.4 Asbestos Contractors Contractors hired to perform asbestos consulting and/or remediation work shall be qualified and certified (as appropriate) for the work to be completed. Emergency responses to an unscheduled asbestos maintenance activity shall be made by the Asbestos Coordinator who will contact a qualified asbestos consultant and/or a qualified/certified asbestos abatement contractor. Asbestos contractors shall: a. Provide the Asbestos Coordinator with proof of asbestos training and/or certification prior to commencing with work; b. Provide the Asbestos Coordinator with a valid copy of their Workplace Safety Insurance Board (WSIB) clearance certificate, as well as a copy of their Occupational Health and Safety Policy Statement and OHS Program, prior to commencing with work; c. Comply with all policies and/or procedures; d. Conduct all work in accordance with this AMP, Ontario Regulation 278/05 and all other applicable Acts, regulations, guidelines and/or standards; e. Ensure that all workers are provided with tools and equipment, including personal protective equipment (PPE), which is appropriate to the work being completed, as prescribed by the applicable Acts, regulations, guidelines and/or standards; f. Ensure that all HEPA-filtered equipment, including but not limited to vacuums and air scrubbers, undergo performance leak tests to verify the overall efficiency Asbestos Management Program September 2013

18 of filters and units. Copies of performance leak tests shall be provided to the Asbestos Coordinator prior to commencing work; g. Notify, orally and in writing, the Ministry of Labour inspector nearest the workplace of any Type 3 operations, or Type 2 Glove Bag operations which involve the removal of greater than 1 m 2 of asbestos-containing insulation from a pipe, duct or similar structure. A copy of the notice of project shall be provided to the Asbestos Coordinator; h. Supply and provide a waste collection bin which is impervious to asbestos fibres, suitable for the waste to be contained and of a sufficient capacity to hold the quantity of asbestos waste generated by the project; i. Ensure that the waste collection bin is closed and locked or otherwise secured at the conclusion of each work day and prior to removal from the project facility; j. Ensure that the location of the waste collection bin on, or near, the owner s () premises is acceptable to the owner (); k. Ensure that all asbestos waste generated during a project is removed from the Site in a properly labeled waste container and disposed of in accordance with the requirements prescribed by Ontario Regulation 347/90, made under Ontario s Environmental Protection Act and entitled General - Waste Management and O.Reg.278/05; and, l. Provide the Asbestos Coordinator with a copy of the receipt and/or weigh bill from the land fill or transfer station where the asbestos waste was sent for disposal. 6.0 ACM ASSESSMENT AND RECORD DEVELOPMENT As prescribed by Section 8(3) of Ontario Regulation 278/05, the has a regulatory requirement to assess ACMs within all of their facilities and develop an appropriate record for each facility. At a minimum, this record shall include: 1. The location of all known, or suspected, ACMs within each facility; 2. The status of all ACMs within each facility; 3. For each location, whether the ACM is friable or non-friable; 4. The condition of ACMs at each location; and, 5. In the case of friable sprayed-on ACMs: a. The type of asbestos present, if known; or, b. A statement that the material will be treated as though it contains a type of asbestos other than Chrysotile. Typically development of this record for each facility shall include conducting an ACM assessment which consists of: 1. A review of existing documentation pertaining to the presence or absence of ACMs within the facility; 2. A visual assessment of the facility to determine the location, status, condition and friability of ACMs; Asbestos Management Program September 2013

19 3. Bulk material sampling, where necessary, to assess whether a material is asbestos-containing by determining the concentration and type of asbestos present; 4. Documenting the location, status, condition, friability and type of asbestos present for all ACMs within the facility in an ACM assessment report. Recommended remedial actions for ACMs which are damaged and/or deteriorated shall be included in the ACM assessment report; 5. On-Site retention of the ACM assessment report in a location at the facility which is accessible to all workers; 6. Providing notification to the Asbestos Coordinator regarding the findings of the ACM assessment; and, 7. Regular re-assessment of ACMs within each facility and updates to the record. As prescribed by Section 10(5) of Ontario Regulation 278/05, the Asbestos Coordinator shall provide a copy of this record to any prospective contractor or constructor prior to requesting tenders for, contracting for or arranging any work. The following subsections provide a detailed summary of how ACMs will be assessed and an appropriate record developed. 6.1 Existing Document Review Prior to commencing with an ACM assessment for a particular facility, a desktop review of available documentation pertaining to previous sampling activities, previous abatement activities and/or the known location and condition of ACMs within the facility shall be conducted. The desktop review shall be completed to: 1. Identify which materials have been previously sampled and analyzed to determine asbestos content and the type of asbestos present; 2. Identify whether or not previous sampling activities have been conducted in accordance with the minimum sampling requirements prescribed by Table 1 of Ontario Regulation 278/05; and, 3. Identify whether or not previously sampled materials are considered ACMs based on the provided analytical results and criteria prescribed by Ontario Regulation 278/05. Based on the findings of the desktop review, potential data gaps shall be identified and an appropriate sampling and assessment strategy developed for the ACM assessment. Wherever possible, existing information shall be incorporated into the ACM assessment in an effort to consolidate data and retire historical information. Materials which are identified in the existing documentation, have been sampled in sufficient quantities (as prescribed by Ontario Regulation 278/05) and were adequately analyzed in accordance with Ontario Regulation 278/05 do not require re-sampling; however, previous sampling activities shall only be considered applicable if they are supported by complete and legible Certificates of Analyses prepared by an accredited and/or qualified analytical laboratory. Asbestos Management Program September 2013

20 For the purposes of the desktop review, historical documentation shall include, but not be limited to, the s existing online ACM database, previous designated substance surveys, ACM assessments, abatement records and construction/renovation drawings. 6.2 Visual Assessment Following a desktop review of the available documentation, and development of an appropriate sampling and assessment strategy, a visual assessment of ACMs within the facility shall be conducted. The purpose of the visual assessment is to determine the location, status, condition and friability of known, or suspected, ACMs within the facility Location Visual assessments shall be conducted with the intent and purpose of identifying all known, and suspected, ACMs within the facility. The assessment shall be conducted on a room-by-room basis and information regarding ACMs within each room recorded. The visual assessment shall be conducted by a Qualified Asbestos Consultant and include a detailed visual and physical inspection of the premises in order to identify, evaluate and record information on the presence or absence of ACMs for each of the following building components: Floor (identified by type of finish); Wall (identified by construction and type of finish for each wall in an area); Ceiling (identified by type of ceiling finish or system); Structure (identified by structural components [i.e. beam, deck, joist, column, etc.]); Piping system; Mechanical equipment (i.e. tanks, boilers, gas flue breaching, fan units, etc.); Ductwork (identified by system [i.e. supply, return, exhaust, etc.]); and Other (e.g. ACMs on electrical equipment, building exterior, sprayed-on materials, etc.). The surveyor shall inspect all areas of the facility which are accessible at the time of assessment. Areas which are not accessible shall be recorded, and listed as potential hazards in the ACM assessment report. ACM assessments conducted for compliance purposes will be non-intrusive in nature. The inspection of concealed areas shall be limited to access ways provided through existing hatches and by lifting finishing materials, such as ceiling tiles and carpets, where present. Demolition and/or invasive inspection work shall not be performed, unless specifically requested by the Asbestos Coordinator. Therefore, ACMs which are present but visually or physically concealed by contents, finishes, ceilings, roofs, floors, sub-floors, walls, foundations, bulkheads, vertical chases, shafts, tunnels, crawl spaces, vaults, chambers, or other similar structures will not be inspected. Where possible, ACMs in concealed and/or inaccessible areas shall be listed as a potential ACM hazard. Asbestos Management Program September 2013

21 If necessary, the Asbestos Coordinator may request that a figure be prepared to graphically depict the location of ACMs within a facility, including sample locations ACM Status Throughout the course of visual assessment, building materials shall be classified by ACM status based on the following criteria: Confirmed ACM: Materials which were identified and confirmed to contain 0.5% or more asbestos by dry weight through sampling and laboratory analysis. Assumed ACM: Materials which are suspected of being ACM but could not be sampled to confirm visual identification, due to inaccessibility and/or the non-destructive nature of the ACM assessment. These materials are identified as a potential risk and should be treated as ACM and managed accordingly, or sampled prior to disturbance. For the purposes of this AMP, the term Assumed ACM is synonymous with Deemed ACM and Suspect AMC. Materials which are Assumed ACM are assumed to contain a type of asbestos other than Chrysotile for the purposes of selecting respiratory protection in accordance with Table 2 of Ontario Regulation 278/05. Non ACM: Materials which were confirmed to contain less than 0.5% asbestos by dry weight through sampling and laboratory analysis, or materials which are known to historically not contain asbestos. This includes materials which were installed after 1990 (excluding asbestos-cement products which may have been installed after this date) Condition Throughout the course of visual inspection, the condition of accessible ACMs shall be categorized as good, fair or poor based on the following criteria: Good: ACMs which are intact and in a non-deteriorated condition, or ACMs which are completely encapsulated within an outer non-asbestos material or covering. ACMs in this state are assumed to represent a negligible risk as a source of airborne respirable asbestos fibres. Therefore, no remedial actions are currently required for ACMs in this state; however, annual re-inspection shall still be maintained. Fair: ACMs which are slightly deteriorated with no visible dust or debris present, or ACMs which are enclosed within an outer non-asbestos material or covering, where the outer material exhibits minor signs of physical damage to the integrity of the covering material (i.e. small nicks, tears, or shrinkage cracks). ACMs in this state are assumed to represent a low risk as a source of airborne asbestos fibres. Therefore, remedial actions are not immediately required for ACMs in this state; however, repair and/or removal of the damaged material is recommended prior to further deterioration. Annual re-inspection of ACMs which are repaired, but not removed, shall be maintained. Asbestos Management Program September 2013

22 Poor: ACMs which are significantly damaged and/or deteriorated, or the observed presence of ACM dust and/or debris. ACMs in this state are assumed to represent a high risk for the fugitive release of airborne asbestos fibres. Therefore, removal and/or repair of ACMs in this state should be conducted as soon as possible by a qualified asbestos abatement contractor Friability Throughout the course of visual inspection, ACMs shall be classified as friable or nonfriable. As defined by Section 1 of Ontario Regulation 278/05, a friable material is an ACM which: a) When dry, can be crumbled, pulverized or powdered by hand pressure; or, b) Is crumbled, pulverized or powdered. ACMs which do not meet this definition shall be classified as non-friable. 6.3 Bulk Material Sampling In the event that analysis of a building material is required to confirm or refute visual identification of an ACM, or the type of asbestos present, bulk material sampling should be conducted. However, it is recommended that all sampling activities be completed by a Qualified Asbestos Consultant. For the purposes of ACM assessments conducted for compliance purposes, only the following materials shall be sampled: Friable spray fireproofing; Lay-in acoustic ceiling tiles, to accommodate routine and small scale disturbances by maintenance and operations staff; Suspect ACMs which are observed to be in a deteriorated condition and may require repair and/or removal; and, Any additional materials requested by the Asbestos Coordinator. All other materials shall be deemed asbestos-containing and assumed to contain a type of asbestos other than Chrysotile for the purposes of selecting respiratory protection in accordance with Table 2 of Ontario Regulation 278/05. Any materials which are identified in the existing documentation, have been sampled in sufficient quantities (as prescribed by Ontario Regulation 278/05) and were adequately analyzed in accordance with Ontario Regulation 278/05 do not require re-sampling; however, previous sampling activities shall only be considered applicable if they are supported by complete and legible Certificates of Analyses prepared by an accredited and/or qualified analytical laboratory. Asbestos Management Program September 2013

23 The following subsections provide a summary of sample collection, analysis and accredited laboratories Sample Collection In order to confirm or refute visual identification, a minimum number of bulk material samples will need to be collected from within a facility. Ontario Regulation 278/05 prescribes that a minimum number of samples (1, 3, 5 or 7 depending on quantity, application, use and homogeneity) must be collected and analyzed for a material to be considered non-asbestos. Table 1, provided below, outlines the minimum sampling requirements prescribed by Table 1 of Ontario Regulation 278/05. This table is provided as a convenience only and is subject to change. The reader must always reference an official and current copy of the Regulation prior to collecting bulk material samples for analysis of asbestos content. Ontario Regulation 278/05 defines a homogeneous material as a material that is uniform in colour and texture. Each homogeneous material identified within a facility shall be sampled independently, and an adequate number of samples collected from each material. In an effort to clearly identify sets of samples collected from a specific homogeneous material, each homogeneous material shall be assigned a unique sample identification number (i.e. S01, S02, etc.) followed by the suffix a, b, c, d, e, f or g (as applicable) to represent multiple samples of the same homogeneous material. Following collection, all samples shall be organized by homogeneity and submitted to a qualified and/or accredited laboratory analysis for analysis in accordance with the methods prescribed by Ontario Regulation 278/05. Table 1: Minimum Sampling Requirements Item Type of material Size of area of homogeneous material 1. Surfacing material, including without limitation material that is applied to surfaces by spraying, by troweling or otherwise, such as acoustical plaster on ceilings and fireproofing materials on structural members 2. Thermal insulation, except as described in item 3 Less than 90 square metres 3 90 or more square metres, but less than 450 square metres 450 or more square metres 7 any size 3 3. Thermal insulation patch Less than 2 linear metres or 0.5 square metres 4. Other material Any size 3 Minimum number of bulk material samples to be collected 5 1 Asbestos Management Program September 2013

24 All bulk material samples collected within facilities shall be collected by a Qualified Asbestos Consultant in the following manner: 1. As required by the Act, the JHSC worker representative for the area must be advised of sampling and be provided the opportunity to be present at the start of sampling; 2. Where possible without creating a hazard (i.e. slip and fall, electrical, etc.), wet the material prior to sample collection in order to minimize the potential for fibre release; 3. Where necessary, measures which are appropriate for the sampling environment and the material being sampled shall be taken to protect the health and safety of the sampler and the facility occupants. Examples of potential measures include, but are not limited to, the use of personal protective equipment (i.e. respiratory equipment, coveralls, gloves, safety glasses, etc.) and restricting access to the sampling area; 4. Collect the sample using a clean (dust free) extraction tool. During sample collection, ensure that the extraction tool penetrates all the way through the material being sampled so that all layers of the material are collected. A sample of sufficient size shall be collected in order to provide approximately 5 to 10 grams of material; 5. Immediately place the sample into a clean, polyethylene sample bag, which can be completely sealed (i.e. Ziploc); 6. Label the sample bag with a unique sample identification number and record the following information: a. Unique sample identification number (i.e. S01a), which clearly identifies whether the sample lies within a series of homogeneous material samples; b. Facility where the sample was collected, including room name or number (if appropriate); c. Description of the sampled material by location and type (i.e. ceiling tile, duct insulation, wall plaster, etc.); d. Characteristics of the material (colour, texture, etc.); e. Date and time of sample collection; f. The name of the sampler; 7. Following collection, the sample extraction point shall be covered using a suitable sealant or tape (as required); 8. Clean the extraction tool and repeat the above sampling procedure until a sufficient number of samples have been collected, as prescribed by Table 1 of Ontario Regulation 278/05. Wherever possible, samples shall not be collected at the same location, but rather spread out across the entire area of homogeneous material; and, 9. In areas where non-homogeneous materials are observed (i.e. several types of material with different colours and/or textures), a minimum number of samples shall be collected from each homogeneous material of concern. Asbestos Management Program September 2013

25 6.3.2 Sample Analysis All bulk material samples collected to confirm or refute visual identification of suspect ACMs shall be submitted to an accredited analytical laboratory for analysis of asbestos content by dry weight. In accordance with this AMP, and as prescribed by Ontario Regulation 278/05, analysis of the samples shall be conducted in accordance with the United States Environmental Protection Agency (USEPA), Test Method EPA/600-R- 93/116: Method for the Determination of Asbestos in Bulk Building Materials, June, It should be noted that not all bulk material samples collected will require analysis. If a homogeneous material is determined to contain asbestos (at a concentration of 0.5% or more asbestos by dry weight) in the preliminary phases of analysis, then subsequent samples of the same homogeneous material do not require analysis. The entire area of homogeneous material shall be determined to be asbestos-containing upon identification of the first positive analysis of a homogenous material. This process is referred to as stop positive methods. It should also be noted that some bulk material samples may be comprised of multiple layers (e.g. vinyl floor tiles, vinyl sheet flooring, plaster). In such cases, each layer shall be isolated by the analytical laboratory and analyzed independently to determine asbestos content. As a result, some bulk material samples may require multiple analyses Accredited Analytical Laboratory All bulk material samples collected for analysis of asbestos content shall be submitted to an analytical laboratory which is accredited by one of the following organizations and/or programs to conduct the specified analysis: 1. the National Institute of Standards and Technology (NIST); 2. the National Voluntary Laboratory Accreditation Program (NVLAP); 3. Canadian Association for Laboratory Accreditation (CALA); and, 4. American Industrial Hygiene Association (AIHA). 6.4 ACM Record Development Documentation of ACMs Upon completion of the ACM assessments, including bulk material sampling (if required), an ACM assessment report shall be prepared for each facility to document the type, location, status, condition and friability of ACMs. At a minimum, the ACM assessment report shall include, but not be limited to: Asbestos Management Program September 2013