TSI SAMPLE MANAGEMENT PLANNER INITIAL. Training Services International, Inc. Qualifications & Functions

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1 MANAGEMENT PLANNER INITIAL Asbestos Training Course Federal Edition Training Services International What management planning qualifications exist? How do I become certified to perform management planning? What are a management planner functions? P. 1 AHERA Inspection Qualifications & Functions Section 13 Qualifications Which Federal Agencies require a Management Planner? Certified Inspector LEA s Schools k-12 Management Plan Certified Management Planner SAMPLE Qualifications Qualifications Which Federal Agencies require a Management Planner? P. 1 NESHAP No ASHARA No Commercial & Public buildings OSHA No P. 1-2 P. 1 1

2 Certifications Certification Asbestos Inspector & Management Planner Functions Date, name & signature HA& sample locations Sample procedures, protocols & dates ACM type Laboratory & HA results Assessment Inspection Evaluate & Interpret survey results Hazard assessment Select response actions O&M plan Management Plan P. 3 P. 6-7 What should I know now? 1. What are the qualifications required to perform management planning? P What are the Federal regulations that require asbestos management plans to be performed by a Certified Asbestos Management Planner? 3. What additional licensing do I usually need to develop management plans? 4. What are the functions of a Management Planner? SAMPLE EVALUATING SURVEY RESULTS Section 14 What are keys to evaluating asbestos survey results? How do asbestos regulations apply to asbestos inspection reports? P. 8 What is included in an asbestos management plan? P. 9 2

3 Evaluating Survey Results Regulatory Application Does scope support MP development? AHERA minimum interior accessible materials Additions based on owner s needs Is report accurate & complete? Dates Inspector information ACM information Non-ACM information Sample information Assessments Federal Asbestos Regulations All LEA s -public or private, not-for profit school system consisting of grades K-12. Manage/ abate all (ACBM) Response actionsinclude all friable asbestos abatement projects conducted in a school building P P 12 Regulated Levels of Asbestos AHERA 40 CFR Part 763 subpart E NESHAPS 40 CFR Part 61 subpart M OSHA 29 CFR Ohio, Indiana, Illinois, New York, and most other states None Detected (0%) Amount of Asbestos in Homogeneous Area Trace up to 1.0% Greater than 1% No No Yes No No Yes No Yes Yes No No Yes Quantities and type of ACM vary between state regulations Federal Asbestos Regulations OSHA (29 CFR ) All asbestos jobs covered Class I Removal of & surfacing Class II Removal of all materials except & surfacing Class III any repairs up to 1 glovebagor disposal bag Class IV cleanup where ACM is contacted but not disturbed Unclassified operations PACM- Presumed Asbestos-Containing Material. SAMPLE Federal Asbestos Regulations NESHAP (40 CFR Part 61 Subpart M) Category I NF (pliable) Category II NF (brittle, rigid) RACM basically any currently or will become friable material Notification requirements Emission control procedures Disposal requirements State Asbestos Regulations P. 11 P 12 P. 12 P 13 3

4 Elements of the Management Plan General building description and a summary of the Inspection Report. Elements of the Management Plan Schedule for implementation. Hazard assessments descriptions Recommended preventative measures and/or response actions Response action locations Reasons for selecting the measures and actions What should I know now? 1. What are two key determinations a management planner should make to decide if an asbestos inspection report can be used to develop an asbestos management plan? 2. What does a reliable asbestos inspection report include? 3. What are the key asbestos regulations that may apply to asbestos materials? 4. What is included in an asbestos management plan? P 13 P. 14 Identification of ACBM remaining after response actions Plan for periodically re-inspecting ACBM. Program for informing workers and building occupants Evaluations of resources needed to implement the management plan HAZARD ASSESSMENT Section 15 SAMPLE P 13 What is hazard assessment? What factors are used to determine a hazard ranking? What is a common asbestos hazard ranking system? What are the control options available to manage ACM in a building? What are the benefits and disadvantages to each control option or response action? P. 15 P. 15 4

5 Hazard Assessment Assessing ACM Condition Criteria Assessing ACM Condition Criteria 10% Distributed Damage 25% Localized Damage P. 15 P 17 Potential for Disturbance - Vibration High No Damage No damage, very minor if any Good Damage Up to 10% overall, 25% localized Fair Significant Damage Over 10% overall, 25% localized Poor Potential for Disturbance - Contact High Moderate Low Workers in area > 1/week Public area P. 16 Workers in area < 1/week, > 1/ month Occupant/ employee area Workers in area < 1/ month Inaccessible SAMPLE Loud motors or engines Intrusive noises P. 17 Potential for Disturbance Air Erosion High High velocity air Moderate Motors or engines present, not obtrusive Occasional loud sounds Moderate Noticeable movement of air Low None of the above Low None of the above P. 17 P. 17 5

6 Potential for Disturbance Overall High Moderate Low Any high No high, at least 1 moderate No high, no moderate Control Options/ Response Actions Goals 1. Protect Human Health & Environment 2. Least Burdensome Operations & Maintenance (O&M) Program Encapsulation Maintaining ACM Enclosure Repair Control Options/ Response Actions Required before renovation & demolition P. 18 P. 20 Significant Damage (Poor) Damage (Fair) No Damage (Good) Advantages Hazard Assessment Any 1 High 2 Moderate 3 Low 4 High 5 Moderate 6 Low 7 Maintaining ACM ACM remains (performance) Minimal facility disruptions Low initial cost No/ minor waste generated Disadvantages ACM hazard remains Material may need repaired Future removal costs may be higher SAMPLE ACM Removal Recommended with ACM in poor condition P. 21 Removal Advantages No ACM in facility Life cycle cost may be less Controlling Exposure P. 19 P. 21 Removal Disadvantages Areas of facility must be regulated High initial cost Large amount of waste generated Many facility disruptions P. 21 6

7 Hazard Assessment & Control Option Worksheet Evaluate Condition & Potential for Disturbance Determine Hazard Ranking Recommend Control Options & Area Priority What is an owner s liability when ACM is in their building? What asbestos regulations address ACM in buildings? What liability issues does an asbestos management planner face? P. 22 What key legal factors are involved with managing asbestos in buildings? Asbestos Liability Building Owners Regulatory AHERA, OSHA, NESHAP, State Criminal Knowingly & willfully Civil P. 23 LEGAL CONCERNS IN ASBESTOS MANAGEMENT Section 16 What legal considerations should be applied when developing an asbestos management plan? What are key issues for when selecting insurance? What insurance coverage is needed for asbestos management? SAMPLE Responsibility to prevent exposure What Rules Apply? What type of facility? School or nonschool AHERA? What type of activities are conducted? What are key factors for evaluating an insurance company? P. 23 Construction or nonconstruction Construction Standard & NESHAPS or General Industry Standard? P. 23 P. 24 7

8 OSHA General Industry What Rules Apply Non-School/ Nonconstruction School/ Nonconstruction Non-School/ School/ Construction Construction OSHA Construction NESHAPS Training Occupants AHERA OSHA General Industry Housekeeping Maintenance AHERA OSHA Construction NESHAPS Asbestos Program Manager P. 24 P. 25 Previously installed material CAUTION: ASBESTOS HAZARDOUS DO NOT DISTURB WITHOUT PROPER TRAINING AND EQUIPMENT DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD Labeling Waste containers ACM Location Presence Quantity Inspections Normal operations Renovations/ demolitions Notifications Clean-up, repair, & abatements Occupants in adjacent areas P. 25 Multiple Repairs SAMPLE DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD Implementing & managing program Key Personnel Clean-up & repair activities Over 160 SF/ 260 LF RACM NESHAP Annual Notification P. 26 P. 26 P. 26 8

9 Recordkeeping Management Planner s Liability Regulatory Licensing & Certifications Criminal P. 27 P. 28 Management Planner s Liability Management Planner s Liability - Civil Contractual Scope of Work Cost Schedule P. 28 SAMPLE Indemnification Clauses Asbestos Management Legal Considerations Improper identification & remediation P. 29 Protection vs. other s negligence Management planner may be named for activities not responsible Proper planning & execution Development & implementation P. 29 P. 30 9

10 Insurance Coverages Abatement design and Implementation Minimize exposure Proper abatement activities In-house staff vs. contract labor for O&M Use of previous inspections Recordkeeping Errors & Omissions Insurance General Liability Insurance Occurrence & Claims Made Pollution Prevention Insurance Occurance Claims Made P P What should I know now? 1. What regulations and legal principles affect an owner when ACM is in their building? 2. What are key factors that determine the applicable asbestos regulations in a given situation? 3. What liability issues does an asbestos management planner face? 4. What key legal factors are involved with managing asbestos in buildings? 5. What legal considerations should be applied when developing an asbestos management plan? 6. What are key issues for when selecting insurance? 7. What insurance coverage is needed for asbestos management? 8. What are key factors for evaluating an insurance company? P.37 Carrier s quality Coverage Financial stability Management Insurance Concerns Anticipated risks covered by policy Insurance carrier is financially capable Evaluating Insurance Company Commitment Insurance carrier responds to claims fairly Insurer has longevity P. 33 Staying in asbestos industry Continue to provide insurance SAMPLE P EVALUATION AND SELECTION OF RESPONSE ACTIONS Section 17 10

11 Operations and Maintenance (O&M) Program What considerations are involved with selecting a response action? Advantages O&M ACM remains (performance) Minimal facility disruptions Low initial cost No/ minor waste generated Disadvantages ACM hazard remains Material may need repaired Future removal costs may be higher What are key factors considered for deciding when to perform response actions? P 38 Required for all friable ACBM P. 39 Recommended for all ACBM Encapsulation Limited application ACM remains Bridging Includes SAMPLE Enclosure Limited application Abatement ACM remains, difficult to monitor Mechanical systems Spray-applied Advantages & disadvantages Abatement & part of O&M Repair Damaged Undamaged Advantages & disadvantages Worker protection Training, Periodic surveillance Initial cleaning P.38 Abatement Penetrating Advantages & disadvantages P P P

12 Removal Removal Examples No visible debris remains Multiple removal methods Permanent solution Isolate building area Required before renovations & demolitions Recommended for poor condition ACM Staging and Prioritizing Response Actions Hazard Rank Efficiency Occupancy Patterns Remaining life of building Planned renovation and maintenance P. 44 P Plaster Layers In metal lathe Sprayed applied Concrete slabs Metal beams & decking Boiler Pipe line & ftgs Hazards Electrical, heat, fire, slips What should I know now? P What are the five response actions and one advantage and disadvantage for each? 2. What are key factors considered for deciding when to perform response actions? SAMPLE AIR MONITORING Section 18 Why is asbestos air sampling performed? What are the primary asbestos air sampling alternatives? What certifications do air sampling personnel need? P. 49 What equipment is used for air sampling? P 50 12

13 Reasons for Air Sampling During asbestos activities What are the types of asbestos air samples? PCM What procedures are required to perform asbestos sampling? What are the asbestos air sampling calibration procedures? Reasons for Air Sampling Building ambient air levels Regulatory compliance Contractual requirements Reduce liability Determine exposure levels P 50 P. 50 Determines worker exposures Measures isolation methods, work practices and engineering controls effectiveness Types of Air Samples Background Personals Environmental Final Clearance SAMPLE Air Sampling Alternatives Procedure OSHA levels USEPA clearance level Identifies fibers NIOSH 7400 Method Air Sampling Alternatives TEM Suitability to re-occupy asbestos work area Procedure AHERA Method PCME Sample turnaround Costs P.50 P.51 P P

14 Air Sampling Certifications Air Sampling Equipment Low volume No Federal requirements Many states have requirements Air Sampling Equipment liters per minute (l/min) Battery operated, 8-12 hours Used for personals and inside the work area samples High volume 2-16 l/min Electric motors Backgrounds Perimeters Final clearance Types of Air Samples - Personal Purpose of sample Sampling procedure Analytical methods P. 54 P. 56 Cassettes How they work Components Types of Air Samples Purpose of sample Analytical methods Sampling pumps Key reference levels Sample volume Flow rate Use of results Responsible party, who takes sample? SAMPLE Types of Air Samples - Personals Required Information (29 CFR (n)(2)) Date of measurement P P Sampling pumps Key reference levels Sample volume & flow rate OSHA recommended sampling, use of results Responsible party, who takes sample? Operation being monitored Sampling & analytical methods used & evidence of accuracy Number, duration, & results of samples taken 8 Hr. TWA equation P. 58 Type of protective devices worn P

15 Types of Air Samples Final Clearance Environmental IWA key sampling factors OWA key sampling factors Purpose of sample Analytical methods Sampling pumps Key reference levels Sample volume Flow rate Use of results Responsible party, who takes sample Types of Air Samples Final Air Sampling Alternatives PCM Number of 5 IWA per AHERA Samples 3 IWA per Ohio Dept. of Health Volume Clearance Levels Types of Air Samples PCM 1080 L NIOSH min 3850 L for NIOSH recommended fiber loading TEM AHERA & ODH (if TEM is selected) Z-test method = 5 IWA, 5 OWA, 2 FB, 1 LB or 5 IWA TEM Minimum 560 L 1200 L-1800 L recommended Visual inspection P P. 63 Sampling Cassettes Final clearance sampling Aggressive sampling Types of Air Samples Final Air Sampling Alternatives PCM 25 mm dia. w/ 0.8 µm MCE filter Flow Rate 0.5 L / min - 16 L / min TEM Protocols P mm dia. w/ 0.45 µm MCE filter Over 1 L / min, less than 10 L / min SAMPLE Final Air Sampling Alternatives Each sample limit of quantification is 0.01 f/cc Z-test or average of 5 IWA samples does not exceed filter background level of 70 s/mm 2 P. 63 Air Sampling Procedures Work area readiness Certified personnel Proper protocol Correct pump & cassettes Number of samples & blanks Record sample data Set up & calibrate sample Remove & calibrate sample Package/ prepare samples for analysis P. 63 P

16 Calibration What should I know now? 6. What are key steps when taking an air sample? 7. When should an asbestos air sample be calibrated and what calibration equipment should be used? P P. 68 What are some of the key factors involved with asbestos management planning? What should I know now? 1. What are 3 reasons asbestos air sampling is performed? 2. What are the 2 primary asbestos air sampling analytical methods? 3. What are the Federal and state certifications required to perform asbestos air sampling? 4. What are the primary types of air sampling cassettes and pumps used for asbestos projects? 5. What types of air samples are taken during asbestos projects and what is their purpose? P. 68 ROLES OF OTHER PROFESSIONALS Section 19 SAMPLE Who are the key people that can assist the management planner? What contributions can each of these people make? Input from others improves AMP Team Approach Others needed to: Provide input Implement P. 69 P

17 Team Approach What should I know now? Industrial Hygienist Building Owner Architect/ Engineer Analytical Laboratory Building Engineer Abatement Contractor ASBESTOS IN-PLACE MANAGEMENT Section 20 Asbestos Management Goals O&M Plans Maintain in place ACM Protect human health & environment Comply with regulations P What are some of the key factors involved with asbestos management planning? 2. Who are the key people that can assist the management planner with determining the best asbestos management approach? 3. What contributions to the management plan can each of these people make? What are the asbestos management goals? What are the elements of an asbestos operations and maintenance program? P 73 What are the regulatory requirements for owners of buildings with ACM? SAMPLE Facility Owner requirements Identify and track ACM location and condition Control access to ACM Clean up existing contamination Elements of an O&M Program An ACM inventory Training Work permit system Notification Employee protection programs Special maintenance work practices Labeling Specialized cleaning procedures Specialized cleaning procedures P 74 Reduce liability Maintain ACM until it is removed P. 74 Emergency response procedures Recordkeeping P

18 O&M Program Elements O&M Program Elements Current ACM Inventory Activities O&M Program Elements Specialized cleaning procedures Reduce fiber release during cleaning Moist, low abrasion No dry methods No ACM disturbance Presence Location Quantity Initial 3 yr Periodic ACM Surveillance Final Line of Defense Material locations Labeling ACM Post signs P Asbestos Activities Work Practices P. 78 Work Practices Maintenance Reasons Presence & location of ACM Locations of asbestosrelated activities Avoid the asbestos hazard Methods Posting signs Distributing notices Holding awareness or informational seminars. AHERA SSSD & OSHA Class III Response Actions OSHA Class I OSHA Class II P Types of Asbestos Activities Performance requirements Asbestos trained personnel Work area isolation Wet methods, HEPA vacs, prompt clean up Worker protection SAMPLE Training P. 78 Emergency clean-ups Response to unplanned, uncontrolled ACM disturbance Minor & major fiber release episodes OSHA Class IV P P. 79 Awareness Work Practices Multiple Levels Initially & Annually 18

19 Training Asbestos General Awareness O&M (OSHA Class III) Material-Specific (OSHA Class II) Designated Person Program Manager AHERA MAP P Recordkeeping Training Fit testing Medical Notifications Exposure monitoring Inspections Remediations Repairs What should I know now? 1. What are four (4) asbestos management goals? 2. What inspection activities are required by AHERA and how often do they need to be performed? 3. What are three (3) ways building occupants can be informed of ACM presence? 4. What areas does AHERA require asbestos warning signs posted? 5. In a school building with ACM, who is required to be trained and what courses are required? 6. Who is the person under AHERA responsible for keeping the LEA in compliance? 7. What in-place programs are an employer required having who issues respirators to employees? 8. What are three (3) work practices required for asbestos repairs and cleanup activities? P. 83 Employee Protection Programs Work Practice Summaries Piping System Insulation Repair-P. 83 Surfacing Material Repair-P. 84 Boiler and Tank Insulation Repair-P. 85 Drywall/ Joint Compound Repair-P. 86 Gasket Removal-P. 87 Repairs Involving Flooring Material-P. 88 Repairs Involving Transite Siding-P. 89 Repairs Involving Roofing Material-P. 90 Clean-up Procedures/ Fiber Release Episodes-P. 91 SAMPLE P. 92 P. 81 P ASBESTOS MANAGEMENT PLAN CONTENTS Section 21 19

20 When is an asbestos management plan required? Does an asbestos management plan have to be available and to whom? Contact Information What are the asbestos management plan key contents? P 93 App H P. 1 P Introduction LEA required to have AMP Required Information Each school building name & address ACBM content ACBM removal dates AMP available: Central location in each school building LEA administration offices AMP addresses all asbestos activities Working document, continuously updated School Building List Suggested Information P 93 Original date of the building construction Addition and renovation dates SAMPLE AMP Contents Designated Person Assurances Evaluation of Resources Maintenance & Custodial Training Records Required: Student s name and job title Training date Training location Suggested Training agency Course name Training certificate AMP Contents Inspection and Reinspection Reports App H P. 2 P 96 Initial inspections All 3 yr reinspections All periodic surveillance Inspector course covered detailed information App H P. 3-4 P 95 App H P P 95 20

21 Recommended & Implemented Response Actions AMP Contents Management Planner Information Recommended preventive measures and response actions information Implemented response actionand major fiber release episode information Remaining ACBM After Response Actions Name of person performing each surveillance Date of surveillance Any changes in condition of material Periodic Surveillance Plan/ Report Steps taken to notify all parties A dated copy of each notification Plan to Inform AMP Contents What should I know now? App H P P App H P When is an asbestos management plan required? 2. Does an asbestos management plan have to be available and to whom? 3. What individual is responsible for the implementation of the management plan? 4. What inspection activities have to be included in the management plan? 5. What is the annual notification requirements required in the AMP? P 98 Worker protection policies Work practices Recordkeeping O&M Plan SSSD/ Class III activities Minor Fiber Release Episode/ Class IV Activity Cleaning Activity O&M Activity Records App H P P AHERA Asbestos Management Plan (AMP) Requirements Needed by LEA s for every school building EPA Region 2 has 2 guidance documents Model Asbestos Management Plan Guide for certified MP s Self Audit Checklist Designed for designated persons Used by regulators SAMPLE P 101 P RESPONSE ACTION COST ESTIMATES Section 22 21

22 Introduction What factors affect cost estimates? What is involved with developing a cost estimate? What are some approaches to developing costs estimates? General Factors Affecting Costs Size of Project Amount and Application of ACM Quality of Contract Specification P 102 Complexity of the Project Need for Replacement Materials P MP required to present least burdensome response action All response actions have costs Costs + effectiveness = response Elements of Cost Estimation ACM Abatement Project Design and Monitoring Services O&M Programs Indirect Costs SAMPLE Approaches to Cost Estimates Unit Cost Approach What should I know now? P 102 P What factors affect cost estimates? 2. What is involved with developing a cost estimate? Itemized Bid Approach 3. What are some approaches to developing costs estimates? P P

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