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1 Asbestos Operations & Maintenance 09/13 Website sample with selected sections for viewing Welcome to: Training Services International, Inc. TOC-0 training.com

2 Asbestos Operations & Maintenance 09/13 Operations & Maintenance OSHA Class III Asbestos Training Course Your name: Organization: This manual has been developed to meet the requirements of the EPA AHERA and OSHA Asbestos Construction Standard regulation for Asbestos Operations & Maintenance (OSHA Class III) training It serves as a guide for asbestos repair personnel, managers, and building owners to effectively manage asbestos issues in buildings and on job sites. This manual contains information from EPA and OSHA standards, and state of the art methodologies. Due to the constantly changing nature of government regulations, it is impossible to guarantee absolute accuracy of the material contained herein. The publisher and editors, therefore, cannot assume any responsibility for omissions, errors, misprinting, or ambiguity contained within this publication and shall not be held liable in any degree for any loss or injury caused by such omission, error, misprinting or ambiguity presented in this publication. All rights reserved. Neither the publication nor any part thereof may be reproduced in any manner for distribution for outside company use without prior written permission of the publisher. EPA Model Curriculum, United States laws and Federal regulations published as promulgated are in public domain. However, their compilation and arrangement along with other materials in this publication are subject to the copyright notice. Manual originally developed 06/01. Revised 03/02, 02/03, 12/04, 01/09. 07/09, 09/13. Printed in the United States Training Services International, Inc. Training Services International, Inc. TOC-1 training.com

3 Asbestos Operations & Maintenance 09/13 Table of Contents: Operations & Maintenance/ OSHA Class III Asbestos Training Course Table of Contents Section Title Page Introduction Course Outline Table of Contents TOC-1 TOC-2 TOC-3 1 Asbestos Characteristics and Uses 1 2 Asbestos Exposure 14 3 Health Effects 18 4 Liability & Responsibilities 21 5 Asbestos Sampling 30 6 Medical Surveillance 36 7 Personal Protective Equipment 39 8 Asbestos Abatement Preparation 48 9 Isolating the Work Area Asbestos Repair Work Practices Competent Person Responsibilities Safety Concerns 80 Appendix A Glossary A-1 Training Services International, Inc. TOC-2 training.com

4 Asbestos Operations & Maintenance 09/13 Course Outline: Operations & Maintenance/ OSHA Class III Asbestos Training Course Initial Day 1 Topic 0.25 hours Introduction Sign-In, Introductions and Overview of Course 1.5 hour Asbestos Basics Characteristics, production, uses, bans Materials Class Sign-in Sheet Manual Section hours - Break 1.5 hour Asbestos Risks & Responsibilities Asbestos exposure, health effects, liability, responsibilities, and regulations, and sampling Manual Sections 2-4, Appendices 1.0 hours - Lunch 1.5 hours Protecting Yourself Sampling, Medical Surveillance, Respirators, Protective Clothing Manual Sections hours - Break 1.0 hours Asbestos Repair Preparation & Work Practices Preparation, Work Area Isolation, Basic Work Practices 0.5 hours Hands On Activities Asbestos Repair & Fit Testing Manual Section 8-10 Appendices, Federal Regulations Asbestos Repair Supplies 0.25 hours Final comments, review Training Services International, Inc. TOC-3 training.com

5 Asbestos Operations & Maintenance 09/13 Course Outline: Operations & Maintenance/ OSHA Class III Asbestos Training Course Initial Day 2 Topic 0.5 hours Review Sign-In and Review of Course 1.5 hour Asbestos Work Practices Glovebagging & Mini-Enclosures Materials Class Sign-in Sheet Manual Section hours - Break 1.5 hour Hands On Activities Glovebagging Asbestos Repair Supplies 1.0 hours - Lunch 1.0 hour Hands On Activities Mini-Enclosures Asbestos Repair Supplies 0.25 hours - Break 1.0 hours Supervising & Safety Competent Person Responsibilities & Safety Concerns Manual Section hours Quiz 0.25 hours Final comments, review Training Services International, Inc. TOC-4 training.com

6 Asbestos Operations & Maintenance 09/13 Course Outline: Operations & Maintenance/ OSHA Class III Asbestos Training Course Refresher: ½ Day 0.25 hours Introduction Topic Sign-In, Introductions and Overview of Course Materials Class Sign-in Sheet 1.5 hour Asbestos Protection & Work Practices Manual Section hours - Break 1.5 hour Hands On Activities Asbestos Repair Supplies 0.25 hours - Break 0.25 hours Final comments, review Training Services International, Inc. TOC-5 training.com

7 Asbestos Operations & Maintenance 09/13 Notes SECTION 1 ASBESTOS CHARACTERISTICS & USES What questions will be answered in this section? 1. What is asbestos? 2. Where is asbestos found? 3. How is asbestos used? 4. Is asbestos banned? 1. What is Asbestos? Asbestos is a generic name given to the fibrous variety of six naturally occurring minerals with the following properties: Chrysoitile Asbestos State of California Photo Training Services International, Inc. 1 training.com

8 Notes Asbestos Operations & Maintenance 09/13 The six asbestos minerals currently regulated by Federal US regulations are listed in the following table. These minerals belong to two families: serpentine and amphibole. Other minerals with similar characteristics may be considered asbestos by some states, however this is limited. Asbestos Mineral Family Comments Chrysotile Amosite Crocidolite Actinolite Tremolite Serpentine (long-wavy structure) Amphibole (short, rigid structure; most hazardous) Amphibole (short, rigid structure; most hazardous) Amphibole (short, rigid structure; most hazardous) Amphibole (short, rigid structure; most hazardous) White asbestos Most common found in 90-95% ACMs. Currently mined. Brown asbestos Most common amphibole found in 5-10% ACMs. No current production Blue asbestos Found in 1-5% ACMs. Anthophylite Amphibole (short, rigid structure; most hazardous) No current production Can be in vermiculite Often associated with tremolite. No current production Can be in vermiculite Some current production in India, Rare, no current production Training Services International, Inc. 2 training.com

9 Asbestos Operations & Maintenance 09/13 Notes 2. Asbestos Locations Asbestos in the U.S. The USGS reports asbestos has been identified in 20 states and mined in 17 States over the past 100 years. It is found in many common rocks. The type of rock expected to contain asbestos occurs predominantly along the eastern seaboard from Alabama to Vermont, along the US Asbestos, 2005 USGS Map western seaboard from California to Washington, and in the upper Midwest in Minnesota and Michigan. Small occurrences of asbestos are in other areas, such as Arizona, Idaho, and Montana. The USGS has been studying the locations of naturally occurring asbestos (NOA) and updating previous locations. The USGS published asbestos location reports for all 48 contingent states between 2005 and Reports have not been issued addressing Alaska, or Hawaii. These reports contain maps and associated databases of asbestos and amphibole locations. USGS surveys have identified asbestos primarily in mountainous areas. Below is a summary of these findings: Area NOA Locations USGS Report Date Eastern United States 324 July 1, 2005 Central United States 36 August 8, 2006 Rocky Mountain States (Colorado, Idaho, Montana, New Mexico and Wyoming Southwestern United States (Arizona, Nevada, Utah) 48 July 12, March, 2008 Oregon and Washington 51 March 1, 2010 California 290 August 22, 2011 Training Services International, Inc. 3 training.com

10 Notes Asbestos Operations & Maintenance 09/13 Worldwide Asbestos Production World production of asbestos was estimated to be Mt in Production over the last 10 years has been consistent at roughly 2,000 Mt. Asbestos production from is provided below (numbers estimated in thousands of metric tons, information provided by USGS publications). Asbestos Producing & Consuming Countries In 2010 Russia continued to be the leading producer of asbestos, followed by China, Kazakhstan, Canada, and Brazil. These countries accounted for 95% of the world production. China was the leading asbestos-consuming country in 2007, followed by India, Russia, Kazakhstan, Brazil, Thailand, Uzbekistan, and Ukraine. These eight countries accounted for about 80 per cent of world asbestos consumption in that year (information provided by USGS publications). Jefferies Mine, Quebec Canada Photo from Quebec Government Training Services International, Inc. 4 training.com

11 Asbestos Operations & Maintenance 09/13 Notes Asbestos Uses Asbestos has been used in literally thousands of products. Asbestos gained widespread use because it is plentiful, readily available, and low in cost. Because of its unique properties asbestos proved well suited for many uses in the construction trades. Asbestos-containing material (ACM) is defined as material containing more than 1% asbestos. A material s asbestos content is most often determined by extracting a small material sample and using a microscope to analyze the sample s optical properties. The analysis determines the types and quantity of asbestos present. Many Federal, state, and some local regulations apply when a material is determined to be ACM. Other terms commonly used relating to a material s asbestos content and how it must be treated include the following: Suspect ACM Material that may contain asbestos and the asbestos content is unknown. An inspector has a choice of treating the material as ACM (assuming) or testing it with proper protocols to determine the asbestos content. Assumed ACM A suspect material that has not been tested to determine the actual asbestos content and therefore must be treated as ACM. Asbestos-Containing Building Material (ACBM) This term is from the USEPA AHERA Regulation (40 CFR Part 763, Subpart E) and means ACM that is found in or on interior structural members or other parts of a school building. Presumed Asbestos Containing Material (PACM) - This term is from the US OSHA Asbestos Construction Standard (29 CFR ). The definition can often mislead those trying to comply with this standard because it is limited to thermal system insulation and surfacing material found in buildings constructed no later than Despite the limited materials defined as PACM, OSHA requires the use of due diligence to determine if any materials are asbestos-containing. Without due diligence any suspect material must be assumed or presumed to be ACM. Identifying Suspect Material Sampling (above) TSI photo Analysis (below) USEPA photo Training Services International, Inc. 5 training.com

12 Notes Asbestos Operations & Maintenance 09/13 A suspect material is one that usually has had a history of containing asbestos and the asbestos content is unknown. The EPA has listed examples of suspect asbestos materials in the following table and diagrams. States may have more comprehensive lists of suspect material. Cement Pipes USEPA Sample List of Suspect Asbestos - Containing Materials Cement Wallboard Cement Siding Asphalt Floor Tile Vinyl Floor Tile Vinyl Sheet Flooring Flooring Backing Construction Mastics (floor tile, carpet, ceiling tile, etc.) Acoustical Plaster Decorative Plaster Elevator Brake Shoes HVAC Duct Insulation Boiler Insulation Breaching Insulation Ductwork Flexible Fabric Connections Cooling Towers Pipe Insulation (corrugated air-cell, block, etc.) Heating and Electrical Ducts Electrical Panel Partitions Electrical Cloth Textured Paints/Coatings Ceiling Tiles and Lay-in Panels Spray-Applied Insulation Blown-in Insulation Fireproofing Materials Taping Compounds (thermal) Packing Materials (for wall/floor penetrations) Gaskets Laboratory Hoods/Table Tops Laboratory Gloves Fire Blankets Fire Curtains Elevator Equipment Panels Electric Wiring Insulation Chalkboards Roofing Shingles Roofing Felt Base Flashing Thermal Paper Products Fire Doors Caulking/Putties Adhesives Wallboard Joint Compounds Vinyl Wall Coverings Spackling Compounds Training Services International, Inc. 6 training.com

13 Asbestos Operations & Maintenance 09/13 Notes Asbestos Materials in Commercial & School Buildings USEPA Diagram Asbestos Materials in Residential Buildings USEPA Diagram Training Services International, Inc. 7 training.com

14 Notes Asbestos Operations & Maintenance 09/13 Non-Suspect Materials Non-suspect materials are those that can be treated as nonasbestos without a determination by sampling and analysis or other conclusive documentation. These materials can be ignored during an inspection. Other building materials are usually treated as nonsuspect, but may be tested under certain conditions. Suspect ACM are never to be treated as non-asbestos without testing. ACM Categories The EPA and OSHA recognize three categories of ACM; surfacing materials, thermal system insulation, and miscellaneous materials. These categories are based on the application and use of the asbestos materials. Determining a suspect material s correct ACM category is important for asbestos inspectors. Sampling protocols, assessment categories, and remediation requirements vary for different ACM categories. Surfacing Materials are sprayed or toweled on to surfaces (walls, ceilings, structural members) for acoustical, decorative, or fireproofing purposes. The primary surfacing materials are: acoustical plaster and fireproofing insulation. OSHA has further defined surfacing materials in a letter of interpretation (dated June 18, 1999) as materials with fibers loosely bound in the matrix. Left Fireproofing () Right Acoustical Plaster (USEPA Photo) Fireproofing (USEPA Photo) Training Services International, Inc. 8 training.com

15 Asbestos Operations & Maintenance 09/13 Notes USEPA Photos (above) (below) Thermal System Insulation (TSI) is material used to inhibit heat transfer or prevent condensation usually on mechanical equipment. Mechanical equipment includes heating, ventilation, and air conditioning (HVAC) systems, components of hot and cold water systems, and various process systems. Examples include the following types of insulation: Piping systems of all types, Boilers and breeching (exhaust duct), Tanks (insulated or coated), Ducts (exterior or interior insulation), There are various materials used to insulate these systems, three of the more common insulation materials include: block insulation batt insulation corrugated paper also known as aircell compressed layered paper cements and muds. Miscellaneous Materials are other materials not surfacing or TSI. Common examples include: roofing materials (felts, built up sections, shingles, and flashings) cemetitious siding and pipe (often referred to as transite) flooring materials (tiles and sheet flooring) and associated mastic ceiling tiles Above photos courtesy of D. Peders fire doors coated siding drywall & joint compound gaskets and valve packings window caulking and glazing fabrics electrical wiring, cable wrap, lighting insulation Training Services International, Inc. 9 training.com

16 Notes Asbestos Operations & Maintenance 09/13 Miscellaneous Material Examples Training Services International, Inc training.com

17 Asbestos Operations & Maintenance 09/13 Notes 4. Asbestos Bans The history of asbestos bans in the United States is confusing. Yes, asbestos bans are in effect for some products, but most products do not have any asbestos bans. EPA bans for asbestos started in the 1970 s. The first bans were implemented under the National Emission Standard for Hazardous Air Pollutants (NESHAP). The next ban was the EPA Ban and Phase-out US Senate Photo Rule of In 1991 much of the Ban and Phase-out Rule was vacated and remanded by U.S. Fifth Circuit Court of Appeals. A summary of the current United States asbestos bans is listed in the following table. NESHAP Bans US Asbestos Bans Spray-applied fireproofing Spray-applied decorative uses - Preformed block pipe, boiler, 1978 tank, duct insulation Other decorative uses EPA Ban and Phase Out Rule Corrugated paper Specialty paper Roll board Flooring felt Commercial paper New uses of asbestos Examples of Products Not Banned Asbestos cement (transite) Asphalt roofing products Ceiling Tile Resilient flooring (tile & sheeting) Mastics Gaskets Wallboard & joint compound Enforcing the Bans The EPA does not track the manufacture, processing, and distribution in commerce of asbestos-containing products. This applies for banned products and products without asbestos bans. It would be prudent for consumers to use due diligence and inquire about the presence of asbestos when purchasing products. Friction products (disc brakes, brake drums, transmission parts & clutch facings) Clothing & cloth products Caulking & glazings Light concrete All other uses not mentioned in bans USEPA Training Services International, Inc training.com

18 Notes Asbestos Operations & Maintenance 09/13 International Asbestos Bans Based on information available from the International Ban Asbestos Secretariat (IBAS), fifty five countries have currently banned or severely restrict the use of asbestos. New Buildings & Materials Countries with Bans or Severe Restrictions Algeria Greece New Caledonia Argentina Honduras Norway Australia Hungary Oman Austria Iceland Poland Bahrain Ireland Portugal Belgium Israel Qatar Brunei Italy Romania Bulgaria Japan Saudi Arabia Chile Jordan Seychelles Croatia Korea (South) Slovakia Cyprus Kuwait Slovenia Czech Republic Latvia South Africa Denmark Lithuania Spain Egypt Luxembourg Sweden Estonia Malta Switzerland Finland Mongolia Turkey France Mozambique United Kingdom Gabon Netherlands Uruguay Germany There is misinformation regarding new buildings and building materials. A common question that often arises is: Can recently constructed buildings (after 1980) or newly installed materials need to be treated as asbestos? Yes is the answer in nearly all these cases unless documentation exists to demonstrate the material(s) do not contain asbestos. Training Services International, Inc training.com

19 Asbestos Operations & Maintenance 09/13 Notes Over the years there have been sources of confusion regarding new building materials. These general reasons include: Most materials are not banned from containing asbestos. There is no consistent enforcement of existing bans Many manufacturers are unaware that asbestos contamination can exist in raw materials. Asbestos is used in many parts of the world and may be present in materials and ingredients produced in these areas. Material documentation can provide evidence that asbestos is not present. The following table provides an overview of documentation that may be available to address the asbestos content in purchased materials. This table should be used as guidance only. Documentation Material Safety Data Sheets (MSDS) Manufacturer s Asbestos- Free Product Certifications Material Sample and Analysis Reports. Reliability Issues May provide useful if asbestos content information is provided. MSDS s that omit asbestos information are probably not reliable. May be reliable if they are based on conclusive testing. Considered the most reliable information, especially if sampling is performed in accordance with accepted protocols. May be required by regulatory agencies for new products. Training Services International, Inc training.com

20 Notes Asbestos Operations & Maintenance 09/13 SECTION 2 ASBESTOS EXPOSURE What questions will be answered in this section? 1. What is asbestos exposure? 2. How is asbestos exposure measured? 3. How is asbestos exposure controlled? 1. Asbestos Exposure Asbestos exposure occurs when asbestos fibers are released from materials, become airborne, and is inhaled. Exposure levels can vary greatly in facilities containing asbestos materials. Asbestos inspectors evaluate how well the asbestos fibers are contained in its material. Additionally, airborne fiber levels have been established to help determine asbestos exposure concerns. Fiber Release Factors Two key factors that help determine how easily a material may release asbestos fibers are the material s friability and whether the material is intact or non-intact. A material s friability determines its potential to release asbestos into the air. Whether a material is either intact or non-intact often determines if asbestos fibers are currently being released. Asbestos materials are considered to be either friable or non-friable. Friable ACM can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Non-Friable ACM cannot be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friable materials have a greater exposure potential than non-friable materials. If the material has become crumbled, pulverized, or otherwise deteriorated so that the asbestos is no longer bound in the material s matrix it is considered by OSHA as non-intact. If the asbestos remains in the material s matrix (i.e in pieces) it is generally considered intact. USEPA Photo Training Services International, Inc training.com

21 Asbestos Operations & Maintenance 09/13 Notes These terms reflect the current release of asbestos into the air. An intact material generally does not release asbestos into the air unless forces act upon it. Non-intact materials readily release asbestos into the air, causing some level of exposure. 2. Measuring Asbestos Exposure Airborne Fiber Levels Permissible Exposure Limits (PEL s) If airborne fiber levels are a concern, OSHA and EPA have established levels relating to worker and occupant exposure. These levels can be compared to airborne fiber levels within a facility or at a jobsite. OSHA has permissible exposure limits (PEL s) to determine worker exposure concerns and EPA has a clearance level to determine occupant exposure concerns. OSHA has established two Permissible Exposure Limits based on time periods. 0.1 fibers per cubic centimeter (f/cc), 8-hr. time weighted average (TWA). TWA means exposure concentration averaged over an 8-hour period. 1.0 f/cc 30-minute excursion. The excursion limit is the highest 30 minute exposure period anticipated over an entire shift. EPA Photo EPA has established a Clearance Level of 0.01 f/cc. This is an air level commonly used to determine if an area can be re-occupied after an asbestos abatement (large indoor projects). Typically, air sampling is not part of an asbestos building survey. Visual assessments and evaluations are viewed as better ways to determine the exposure potential of in place asbestos materials. Air sampling protocols may occasionally be used to supplement assessments, but air sampling data does not provide a clear picture of asbestos exposure in an ambient indoor environment. Training Services International, Inc training.com

22 Notes Asbestos Operations & Maintenance 09/13 Negative Exposure Assessment (NEA) An NEA is an employer s demonstration that employee exposures are below the PEL s. OSHA allows for this data to be developed from the following sources: objective data (obtained from trade group or manufacturer) personal air sampling results collected from similar projects within the last 12 months, or initial monitoring for the current job, 3. Controlling Asbestos Exposure Controlling asbestos exposure requires a proactive approach and includes the following steps: 1. Identify asbestos materials and hazard levels 2. ACM identified in a facility can either be: Maintaining ACM a. Maintained in place b. Removed using proper engineering controls & work practices There are a number of factors why building owners decide to maintain asbestos in their facilities instead of remove it. The advantages and disadvantages of maintaining ACM are listed below. Advantages 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 Operations and maintenance (O&M), repair, encapsulation, and enclosure can be implemented individually or in combination to maintain the ACM. Encapsulation, enclosure, and repair are abatement activities that leave the ACM in place. These control options are defined accordingly: Training Services International, Inc training.com

23 Asbestos Operations & Maintenance 09/13 Notes Operations & Maintenance Program (O&M) - a program of training, cleaning, work practices, and periodic surveillance to maintain friable ACM in good condition, ensure cleanup of asbestos fibers previously released, and prevent further release by minimizing and controlling friable ACM disturbance. Encapsulation - treating ACM with a liquid that, after proper application, surrounds or embeds asbestos fibers in an adhesive matrix to prevent fiber release. Enclosure - an airtight (or as close to USEPA Photo airtight as is possible to construct) barrier installed between the friable asbestos and the building environment. Repair - returning damaged ACM to an undamaged condition or to an intact state through limited replacement and patching. ACM Removal Removal is an abatement method that means stripping ACM from its substrate and placing it in containers for burial in an approved disposal site. Removal may also include removing pieces of ACM or entire components containing ACM. These projects are usually conducted by certified asbestos contractors and often involve asbestos consulting firms. Removal for most ACM is required in buildings: 1. before demolition, and 2. before renovation activities where ACM may be disturbed. USEPA Photo Additionally, removal becomes the only feasible alternative when the ACM is in very poor condition and there is no other way to prevent fibers from releasing. In nearly every other situation, removal of asbestos becomes a choice for the building owner. Removal s advantages and disadvantages compared to maintaining the ACM in place are listed in the following table. Advantages ACM no longer remains Life cycle cost may be less expensive than other alternatives Disadvantages Areas of facility must be regulated High initial cost Large amount of waste generated Many facility disruptions Training Services International, Inc training.com

24 Notes Asbestos Operations & Maintenance 09/13 SECTION 5 ASBESTOS SAMPLING What questions will be answered in this section? 1. Why is asbestos sampling conducted? 2. How is a material s asbestos content determined? 3. How are asbestos airborne levels determined? 4. What are the sampling procedures for determining exposure? 5. What air sampling records are required? 1. Types of Asbestos Sampling There are two main types of asbestos sampling: A. Bulk or material sampling used to determine the asbestos content of materials that may be disturbed during in construction activities B. Air sampling used to determine airborne asbestos levels. Air sampling is usually conducted during activities where asbestos is disturbed or contacted and occasionally conducted in ambient building environments. 2. Asbestos Bulk (Material) Sampling OSHA Photo Bulk or material sampling is performed to determine the asbestos content of building materials. The asbestos content is based on the percentage of asbestos in the material. Usually a series of bulk samples is taken from each type of material suspected of containing asbestos. The sample from the series with the highest asbestos content represents the amount of asbestos considered to be in the material. Proper asbestos certifications are required for individuals performing bulk sampling for purposes of determining asbestos content. The OSHA asbestos Class III Operations & Maintenance training does not qualify an individual to conduct asbestos bulk sampling activities. Training Services International, Inc training.com

25 Asbestos Operations & Maintenance 09/13 Notes The most common method of asbestos analysis for bulk samples is Polarized Light Microscopy (PLM). Another method used occasionally is Transmission Electron Microscopy (TEM). Both methods report sample results in percentage of asbestos. It is important for the supervisor of a repair activity to review the asbestos survey report to ensure all materials involved in the project have been properly evaluated for asbestos content. EPA s criteria for Asbestos-Containing Materials are materials found to have over 1% asbestos or not proven to have an asbestos content of 1% or below. OSHA regulations address materials with any amounts of asbestos be treated in accordance with their asbestos regulations. Based on this, if any sample analysis results show any amounts of asbestos for any of the samples taken from a material, then the material has some asbestos regulatory requirements. Additionally, if no testing data is available, the material is to be treated as asbestos. 3. Air Sampling Air sampling is the process of drawing air over a filter for the purpose of capturing asbestos fibers and structures. Air sampling is usually required at some level for all projects disturbing asbestos. During these activities, asbestos air sampling results are used to determine: EPA Photo Worker exposures, Effectiveness of isolation methods, work practices and engineering controls, and Suitability of an asbestos work area to be re-occupied Air sampling may also be used to determine ambient asbestos air levels in building s during normal activities. A. Types of Air Samples The types of samples taken during asbestos activities are determined by regulatory requirements and concerns for documenting air levels before, during, and at the conclusion of the project. Training Services International, Inc training.com

26 Notes Asbestos Operations & Maintenance 09/13 Background (Usually taken by consultant for the owner) Personals (Usually taken by contractor, contractor s responsibility) Environmental (Usually taken by consultant for the owner) Final Clearance (Usually taken by consultant for the owner) Type Description Example Determine air levels prior to starting an abatement project. Establish baselines often compared to perimeter samples Determine employee exposure. Performed daily for most large projects. Determine air levels outside and inside work area. Run daily during abatement. Determine air levels after final cleaning and visual inspection USEPA Photo TSI Photo USEPA Photo Training Services International, Inc training.com

27 Asbestos Operations & Maintenance 09/13 Notes B. Personal Air Sampling Personal air sampling is conducted to determine employees' exposure (outside the respirator) to airborne fibers. OSHA has requirements addressing sampling procedures and the information to be included in employee records. C. Sampling Procedures It is the competent person s responsibility to determine the employee s exposure level. For asbestos repair activities, this information can be obtained by personnel air sampling or using previous personnel air sampling data from previous projects that closely resemble the current project. Meeting the closely resemble criteria includes similar type of material and condition, level of training, and work practices. It is the competent person s responsibility to make sure any personnel air sampling be in accordance with the following procedures. Sample the employee s breathing zone at a 45º angle on the off shoulder Place the personal air sampling pump on the worker s backside. Run the sample at a flow rate usually liters/ minute (lpm). Calibrate the pumps flow rate at the start and completion of each sample. D. Recordkeeping Requirements The following information is required by OSHA for personal air samples to complete exposure monitoring records. EPA Photo Date of measurement Operation being monitored Sampling & analytical methods used & evidence of accuracy EPA Photo Number, duration, & results of samples taken Type of protective devices worn Name, identification number (recommended), & exposure of all represented employees Training Services International, Inc training.com

28 Notes Asbestos Operations & Maintenance 09/13 E. Sampling Results and Exposure Levels The personal air sampling results are required to be made available to employees whose exposures were represented. OSHA requires these results be available within 5 days of the monitoring. Typically the results are posted at a central location. The results are to be available to the employees for 30 years past the date of the measurement. The employee exposure monitoring results are used to compare with established exposure levels. OSHA has regulatory levels employers cannot exceed and EPA has a recommended level not to exceed. If exposure levels are exceeded, the results of the monitoring help to determine the appropriate level of worker protection. As previously discussed, OSHA has established two levels not to exceed during asbestos activities: 0.1 fibers per cubic centimeter (f/cc), 8-hr. time weighted average (TWA). 1.0 f/cc 30-minute excursion USEPA has established a Clearance Level of 0.01 f/cc An example of an air sampling form that includes required OSHA data is on the following page. Training Services International, Inc training.com

29 Asbestos Operations & Maintenance 09/13 Notes Training Services International, Inc training.com

30 Notes Asbestos Operations & Maintenance 09/13 SECTION 6 MEDICAL SURVEILLANCE What questions will be answered in this section? 1. What are the reasons for medical surveillance programs? 2. What is involved with an asbestos medical surveillance program? 3. What are the medical exam reporting requirements? 1. Reasons for Medical Surveillance Employers conduct medical surveillance programs for various reasons including; employee concerns due to potential asbestos exposure, determinations of employee pre-existing conditions, and regulatory requirements. A medical surveillance program is used for determining employee baseline health status (health status before beginning work), monitoring their health for the duration of their employment/project, and providing documentation of their health status upon completion of their employment/project. Medical surveillance EPA Photo includes tracking employees medical condition and their work history. Medical Surveillance Triggers Two levels of medical exams may be required in order to conduct asbestos abatement; approval for respirator use and a medical surveillance program. The triggers for these are listed below: Respirator Approval A doctor s or physician s authorization is required for employees to wear a negative pressure respirator. This exam must be given prior to wearing the respirator. Medical surveillance program This includes involved initial and annual exams with review of an employee s work history. Employers are required to place employees in a medical surveillance exam in all of the following cases: o All employees exposed at or above the PEL for 30 or more days within a calendar year. o Employees performing OSHA Asbestos Class I, II, or III asbestos work (over 1 hour) for days within a calendar year. Training Services International, Inc training.com

31 Asbestos Operations & Maintenance 09/13 Notes This exam is required within 10 days of the employees 30 th day of work or exposure. It is generally recommended that this exam be provided prior to the employee performing asbestos work, protecting the employee and employer. 2. Exam Content Respirator Approval The exam content for respirator approval is not specified by OSHA other than a doctor or licensed physician must sign the report. Often, the physician requires a pulmonary function test prior to signing the respirator approval. Medical Surveillance Program The medical surveillance program requires initial and annual exams as long as the employee performs work requiring medical surveillance. The results of this examination will be used for determining the employee s baseline health status, as well as determining whether an employee is capable of safely working under the requirements set forth by the employer. OSHA Photo The content of the initial and annual OSHA asbestos construction medical surveillance exams is summarized in the following table: Medical Surveillance Program Exam Component Initial Annual Medical questionnaire/history Comprehensive Abbreviated Comprehensive medical evaluation determined by licensed physician Yes Training Services International, Inc training.com Yes Pulmonary function tests Yes Yes Chest X-rays interpreted by a B reader Usually, up to physician Usually every 2-5 years, up to physician

32 Notes Asbestos Operations & Maintenance 09/13 3. Exam Results Physician s Responsibilities The physician s report is furnished to the employer for his/her files. The physician s exam report needs to include the following: The employee s ability to perform work while wearing a negative pressure respirator and any limitations Any medical conditions that would place the employee at an increased risk when exposed to asbestos The employee was informed of the exam results and activities that would increase his risk to asbestos exposure A statement that the employee has been OSHA Photo informed by the physician of the increased risk of lung cancer attributable to the combined effects of smoking and working with asbestos The physician is not to reveal in the written opinion given to the employer specific findings or diagnoses unrelated to occupational exposure to asbestos. Employer s Responsibilities The employer is responsible for maintaining required recordkeeping requirements. These requirements include: OSHA Photo Provide a copy of the physician s written opinion to the affected employee within thirty days from its receipt. Make exam results available to the affected employee or their designated representative. Maintain the results of the examination on file for the employee s duration of employment plus thirty years. In the event an employee files suit claiming a disability at some future date, the employer will be able to check his/her records for documentation when investigating whether or not the condition could have occurred as a result of employment with the company. Training Services International, Inc training.com

33 Asbestos Operations & Maintenance 09/13 Notes SECTION 7 PERSONAL PROTECTIVE EQUIPMENT What questions will be answered in this section? 1. What respiratory hazards may be present during asbestos activities? 2. When are respirators required? 3. What types of respirators & filters are to be worn? 4. How do I know if my respirator fits properly? 5. What protective clothing may be needed? 1. Respiratory Hazards Respirators Use during Asbestos Activities Asbestos is a toxic particulate contaminant that easily becomes airborne. OSHA requires determining the presence and exposure level of respiratory hazards. Work practices & engineering controls are the primary methods to control exposure. Respirators are required if the hazard level cannot be reduced to acceptable levels or if employees choose to use them. Use of respirators requires medical clearance and proper fitting. It is recommended that a respirator be worn during any activity involving the release of asbestos. OSHA requires the use of a respirator for most asbestos activities. The triggers for wearing a respirator are listed below for asbestos repair (OSHA Class III) activities. Training Services International, Inc training.com

34 Notes Asbestos Operations & Maintenance 09/13 2. Respirator Selection A. Respirator Types and Assigned Protection Factors OSHA identifies various respirators approved for asbestos use in the Respiratory Protection Standard (29 CFR (d)). OSHA has X established assigned protection factors (APF s) for these respirators. OSHA s Asbestos Standard (29 CFR (h)) prohibits the use of filtering face pieces (i.e. dust masks). Most respirators approved for asbestos are tight fitting. These respirators protect the wearer by EPA Photo creating a seal between the respirator facepiece and the user s skin. Tight fitting respirator users are expected to be in compliance with the following when wearing their respirator: Clean shaven. Men are expected to have shaved the same day the respirator is worn. Medically cleared by a medical doctor. The seal and high efficiency filters create stress on the user s lungs and heart. In order to understand the effectiveness of a respirator, one must understand the concept of a protection factor (PF). The protection factor is defined as the concentration of a contaminant measured outside the mask divided by the concentration you would expect to find inside the mask. This simple formula is illustrated below. Protection Factor (PF) = B. Maximum Use Concentration (MUC) TSI Photo Concentration Outside Mask Concentration Inside Mask The MUC is the work area s highest allowable hazard concentration when a specified respirator is worn. It is determined by multiplying the permissible exposure limit (PEL) by the selected respirator s APF. A simple formula for determining the MUC of a respirator during asbestos activities would be: MUC = Respirator s APF x 0.1 f/cc (Asbestos 8-Hr TWA PEL) Training Services International, Inc training.com

35 JDH Systems, Inc. Asbestos Operations & Maintenance 09/13 Notes C. What Respirator Do I Wear? Which respirator to use is based on the MUC. If the expected employee exposure is below the MUC for that respirator, then the respirator can legally be worn during the asbestos activity. Following this requirement will prevent exposure above the PEL inside the respirator facepiece. It is recommended that respirators provide greater protection than the MUC. Fiber levels inside the respirator facepiece are not recommended to exceed the USEPA final clearance level, 0.01 f/cc. The MUC and the recommended use concentration are listed in the following table for respirators commonly used during asbestos activities. These levels are for asbestos repair activities. Respirator OSHA APF Half-Mask Air Purifying 10 Full Facepiece Air- Purifying Powered Air- Purifying (PAPR) Helmet/ Hood Powered Air- Purifying (PAPR) Full Facepiece 10 w/ Qualitative Fit Test 50 w/ Quantitative Fit Test MUC (APF x PEL) 1.0 f/cc (10 x 0.1 f/cc) 1.0 f/cc (10 x 0.1 f/cc) 5.0 f/cc (50 x 0.1 f/cc) 2.5 f/cc (25 x 0.1 f/cc) 100 f/cc (1000 x 0.1 f/cc) Recommended Use Concentration (APF x 0.01 f/cc) 0.1 f/cc (10 x 0.01 f/cc) 0.1 f/cc (10 x 0.01 f/cc) 0.5 f/cc (50 x 0.01 f/cc) 0.25 f/cc (25 x 0.01 f/cc) 2.5 f/cc (1000 x 0.1 f/cc) Training Services International, Inc training.com

36 Notes Asbestos Operations & Maintenance 09/13 TSI Photo D. Types of Filters 3. User Seal Checks Filters used for asbestos protection must be HEPA (High Efficiency Particulate Air) rated for particulates. This mandates a filter efficiency rating of 99.97% at 0.3 µm. Additionally the National Institute of Occupational Safety and Health (NIOSH) rates the ability of the filter media to resist airborne oil mists and solvents. This procedure is to be performed every time the respirator is put on. If the selected respirator fails to pass the user seal checks, the wearer should readjust the straps and try again. If it still fails, the condition of the respirator should be checked to ensure that no damage has occurred. These simple procedures are described in this section. Training Services International, Inc training.com

37 Asbestos Operations & Maintenance 09/13 Notes User Seal Check Example (NIOSH Photos) Procedures Passing Criteria 4. Fit Tests Negative Pressure Seal Check close off the filter or cartridge inlets by covering them with the palms of the hands, or by blocking the breathing hose so that air cannot pass through; inhale so that the facepiece collapses slightly; and holds breath for about 10 seconds Facepiece remains slightly collapsed and no inward leakage of air is detected Positive Pressure Seal Check close off the exhalation valve of the respirator; and gently exhales into the facepiece for about 10 seconds Positive pressure can be built up inside the facepiece without evidence of outward air leakage around the facepiece Either a qualitative or quantitative fit test must be performed once a year for each make, model, and size of tight fitting respirator worn. Fit tests are to be conducted by persons deemed competent to perform the tests. A formal certification is not required. 1. normal breathing 2. deep breathing Fit Test Exercises Each Performed 1 Minute 3. turning head from side to side 4. nodding head up and down 5. talking 6. grimace (quantitative only) 7. bending over or jogging 8. normal breathing. Training Services International, Inc training.com

38 Notes Asbestos Operations & Maintenance 09/13 A. Qualitative Fit Testing Qualitative fit testing involves the use of contaminants and test exercises to determine whether a respirator s fit is sufficient. In order to pass, the individual cannot detect the test solution when exposed while the exercises are performed. The qualitative fit test procedure also requires a screening to ensure that the individual is sensitive to the solution used during the fit test. The following table lists the contaminants with advantages and disadvantages for each. Solution Advantages Disadvantages Isoamyl Acetate (Banana Oil) Saccharin Bitrex Irritant Smoke (Stannic Chloride) Not harmful to human health Not harmful to human health Not harmful to human health Causes involuntary reaction Causes involuntary reaction Does not cause involuntary reactions Requires use of organic vapor filter Test conducted under hood No hood required Does not cause involuntary reactions Test conducted under hood Test conducted under hood Can be harmful to human health (carcinogen) Training Services International, Inc training.com

39 Asbestos Operations & Maintenance 09/13 Notes B. Quantitative Fit Testing Quantitative fit testing requires specialized equipment to measure differences in airborne particulate concentrations and a trained tester. Approved OSHA methods (29CFR ) include; Condensation Nuclei Counter Portacount TM Controlled Negative Pressure (CNP) The airborne concentration of NIOSH Photos particulate is measured both outside the respirator and inside the respirator (through a probe). During the test, the fit factor must be met or exceeded. The fit factor for a ½ mask respirator is 100, and the fit factor for a full face respirator is Cleaning and Disinfection of Respirators Whenever possible, a respirator should be reserved for the exclusive use of a single individual. After each use, the respirator should be cleaned and disinfected as follows: NIOSH Photo Wash the mask body in warm water using a brush with a detergent or a detergent/disinfectant combination. Rinse it in clean water, or rinse it once with a disinfectant and once with clean water. The cleanwater rinse is particularly important because traces of detergent or disinfectant left on the mask can cause skin irritation and/or damage to respirator components. Air-dry the respirator on a rack or hang it in a position that does not distort the shape of the elastomeric facepiece. Training Services International, Inc training.com

40 Notes Asbestos Operations & Maintenance 09/13 6. Maintenance of Respirators Respirator inspection is an important, routine task that should be performed before and after each use. Each part of the respirator should be checked to ensure that it is functioning properly. At some point any respirator will need replacement parts or some other repair. Only trained, qualified persons can legally repair respirators. Respirator parts from different manufacturers are not interchangeable. NIOSH approval is invalidated if parts are substituted, or nonapproved parts are used. 7. Respirator Storage Proper storage is very important. Respirators must be protected from dust, sunlight, heat, extreme cold, excessive moisture, and damaging or contaminating chemicals. When not in use, the respirator should be placed in a closed, re-sealable plastic bag, and stored in a clean, convenient, sanitary location. 8. Protective Clothing Protective asbestos clothing usually consists of disposable coveralls, gloves, foot covering and head covering. Protective clothing: Keeps asbestos off the body, and Is disposable Protective clothing is required in the following situations: If airborne concentrations of asbestos exceed the PEL, or No NEA exists Requirements for wearing protective clothing include: Put on before entering regulated area, and EPA Photos Remove in decontamination area (drop cloth outside regulated area) Once the repair is completed and all regulated area has been cleaned, the protective clothing can be removed according to the following procedure: Training Services International, Inc training.com

41 Asbestos Operations & Maintenance 09/13 Notes Proceed to decontamination area (drop cloth outside regulated area), HEPA vac suit while wearing (use buddy system when in teams), Take suit off inside-out, rolling suit down body, and Dispose of suit as asbestos waste in asbestos waste bag. Training Services International, Inc training.com

42 Notes Asbestos Operations & Maintenance 09/13 SECTION 8 ASBESTOS ACTIVITY PREPARATION Overview of Preparation Generally, the following steps are to be followed before conducting an asbestos repair with approval of the competent person. 1. Determine if the material to be disturbed contains asbestos 2. Evaluate the material condition and amount involved with the repair. 3. Determine if NEA exists that "closely resembles" the conditions of the expected repair. 4. Determine the level of effort needed to make the repair 5. Check to make sure people in adjacent areas are aware of the planned repair and the presence of asbestos. 6. Assemble the asbestos repair kit and check for all needed tools and supplies. 1. Determining the Asbestos Content If the material to be disturbed during the repair has been previously tested for asbestos content there should be a testing report available. The report will determine if the material to be disturbed must be treated as asbestos or not. If you are not sure of the report results, the person in the facility responsible for the asbestos program should be able to help. Treating Material as Non-Asbestos There must be testing results specifically referring to the material in question. The report must state that the material is non-asbestos in order to treat it this way. Treating Material as Asbestos Containing Both of the following situations require material to be treated as asbestos containing: 1. Testing reports demonstrate the material contains asbestos. 2. There are no test results specifically addressing the material in question. EPA Photo Training Services International, Inc training.com

43 Asbestos Operations & Maintenance 09/13 Notes 2. Evaluating the Amount and Condition of the Material Before starting a repair, it is important to determine the amount of material that will be disturbed and the material s condition anticipated during the repair. A. Material Quantities B. Material Condition (Intact vs. Non-Intact) OSHA defines repairs disturbing asbestos containing materials that can be contained in one glovebag or disposal bag as Class III activities. Personnel with the two day Asbestos Operations & Maintenance (O&M) course can perform these repairs. Asbestos activities involving more than one glovebag or disposal bag generally have to be performed by personnel with an Asbestos Worker course (4 days) or an Asbestos Supervisor course (5 days). The condition of the material during the repair affects the controls and work practices required to perform the repair. If the material has become crumbled, pulverized, or otherwise deteriorated so that the asbestos is no longer bound in the material s matrix it is considered by OSHA as non-intact. If the asbestos remains in the material s matrix it is generally EPA Photo considered intact. Repairs keeping the material intact often have fewer controls than materials becoming nonintact during the repair. 3. Does a Negative Exposure Assessment (NEA) Exist? An NEA permits similar repairs to be conducted as if they were below the PEL (0.1 f/cc). The repair activity must closely resemble the conditions where the NEA was developed. Conditions closely resembling the previous work includes similar type of material and condition, level of training, and work practices. It is the competent person s responsibility to make sure that an NEA exists for the repair. An NEA for a repair activity reduces some of OSHA s requirements. Repair activities with an NEA do not require personnel air sampling and can reduce the levels of work area isolation and personal protective equipment. Training Services International, Inc training.com

44 Notes Asbestos Operations & Maintenance 09/13 4. Repair Level of Effort The level of effort required to make a repair can range from limited isolation and basic work practices to completely containing the work area and establishing engineering controls. The level of effort needed to make the repair depends on the material s condition and if an NEA exists. Repairs involving intact materials with an NEA require the least amount of controls, while repairs involving non-intact materials or the absence of an NEA require greater controls. A summary of these methods is provided below. Detailed descriptions of the work practices and controls are provided in Section 8. Level A Repair Intact Removal These repairs involve basic asbestos work practices and establishing an asbestos work area. Extensive isolation of the repair area is not required because the material is intact. Respirators and protective clothing are not required when the air levels have been determined to be below the PEL. Level B Repair Glovebag Removal This involves the use of one glovebag to completely contain the area where asbestos will be removed so that the repair can be made. A glovebag seals the area and the material is handled from outside the sealed bag with gloves and arms extending into the bag. Glovebags can be used for repairs where the material will be removed non-intact and/ or an NEA does not exist. Glovebags are commonly used to remove pipe insulation during repair activities. These repairs also require establishing an asbestos work area and using basic asbestos work practices within the glovebag. Training Services International, Inc training.com

45 Asbestos Operations & Maintenance 09/13 Notes Level C Repair Mini-Enclosures This involves enclosing the asbestos repair area and isolating it from the rest of the facility. An enclosure is constructed with 6-mil plastic sheeting and evacuating the air through a HEPA filtered vacuum or air filtration device. This creates a negative pressure and airflow within the enclosure. EPA Photo The enclosure and negative pressure prevents asbestos fibers from escaping the work area when material is disturbed. Airflow keeps the fibers from building up around the repair worker s breathing zone. Mini-enclosures can be used for repairing non-intact material or where an NEA does not exist and the repair area cannot be isolated with a glovebag. These repairs also require using basic asbestos work practices within the enclosure. 5. Notifying Personnel in Adjacent Areas It is the building owner s responsibility to notify personnel in adjacent areas. This may be the role of supervisors or other personnel in the facility. In any event, those performing the repair should check to make sure this was done. There are two choices regarding the areas surrounding the site of the repair. 1. Make sure all personnel have been removed and stay out of all adjacent areas during the entire repair. 2. Notify all personnel in surrounding areas of the repairs to the gaskets that will involve the disturbance of asbestos. There are a number of ways to satisfy the notification requirements prior to conducting an asbestos repair. These include: Sending notices to affected personnel prior to starting the repair Posting signs at the start of the repair readable by all personnel in adjacent areas Holding meetings to discuss the repair activities. Training Services International, Inc training.com

46 Notes Asbestos Operations & Maintenance 09/13 6. Assembling the Tools & Supplies Asbestos repairs require specialized supplies and tools. It is recommended that a tool kit be kept stocked with the supplies and tools designated for asbestos repairs. These tools should be kept separate only for asbestos use. The following are often needed for asbestos repairs and are recommended to be kept in the asbestos tool kit. Example Asbestos Supplies List 1. Plastic sheeting (6 mil) 2. Glovebags 3. Smoke tubes 4. Misting bottles and/ or garden sprayer 5. Duct tape 6. Asbestos disposal bags (6 mil) labeled properly per OSHA, EPA and DOT regulations 7. HEPA-filtered vacuum cleaner approved for asbestos use 8. Utility knifes, 5 in 1 s, or wire flex saw to cut into material. 9. Respirators (assigned to individual) disposable suits 11. Scrub pads 12. Disposable towels or rags 13. Surfactant-Small bottle of dish soap 14. Spray encapsulant 15. Asbestos danger signs and barrier tape Training Services International, Inc training.com

47 Notes Asbestos Operations & Maintenance 09/13 SECTION 10 ASBESTOS REPAIR WORK PRACTICES Overview of Work Practices There are a number of steps involved to properly repair asbestos gasket material. In this section, the following areas will be discussed: 1. General asbestos work practices and prohibitions that apply to nearly all asbestos activities. 2. Glovebagging procedures 3. Mini-Enclosures 1. General Asbestos Work Practices 4. Waste disposal requirements and handling procedures that apply to asbestos repair and many other asbestos activities. 5. Specific procedures based on the type of material. The use of wet methods, HEPA vacuums, and prompt clean-up for materials that contain any amount of asbestos prevents uncontrolled asbestos fiber release. These practices are to be used regardless of the level of exposure during the repair activities. Some exceptions do apply when safety is compromised or equipment may become damaged. A. Wet Methods Under normal conditions, wet methods are required. Wet methods normally involve the use of water with a surfactant (i.e. detergent). In some situations, other solutions which wet the gasket material and may make removal easier may be preferred. It is important to know any hazardous properties or disposal issues these solutions present. Wet methods are beneficial for the following reasons: Reduces airborne fiber concentrations Material dislodges from substrate easier Training Services International, Inc training.com

48 Asbestos Operations & Maintenance 09/13 Notes There may be a occasions when wet methods create safety concerns such as on high temperature pipe or around live electrical hazards. If this type of work cannot be avoided, wet methods may need to be omitted. B. HEPA Vacuums A HEPA vacuum requires an asbestos certified HEPA filter. These filters retain 99.97% of all 0.3 microns in diameter. HEPA vacuums need to be maintained so that they are in reliable working order. If a HEPA vacuum does not appear to be working properly or may be full, report it to the competent person. If it is inoperable, report it and use another HEPA vacuum. C. Prompt Clean-up TSI Photo D. Prohibited Work Practices Ideally, the waste will be containerized as soon as practical, but no later than end of the repair activity. Prompt clean-up prevents the waste from drying out and releasing asbestos fibers into the air Certain work practices will uncontrollably release asbestos fibers into the air. OSHA prohibits these practices on ACM or materials that have not been proven to be non-acm. These work practices include: Cutting material with a high speed abrasive disc saw that does not have a HEPA exhausted collection system at the cut point. Using compressed air to remove asbestos from a substrate (without specially designed ventilation system). Any dry clean-up of ACM dust or debris including dry sweeping or dry shoveling. Training Services International, Inc training.com

49 Notes Asbestos Operations & Maintenance 09/13 2. Glovebagging Procedures When any of the asbestos material becomes non-intact glovebagging is a control option for preventing asbestos fiber release. The material disturbed during the repair must be able to be contained completely within the sealed glovebag. Repairs involving pipe insulation are commonly performed within a glovebag. Procedures used for glovebagging are listed below: A. Check area where the work will be performed. If the glovebag will be sealed onto pipe insulation, wrap the pipe insulation with 6-mil plastic sheeting securing with duct tape. Plastic sheeting only needs to be applied where glovebag will attach to pipe. B. Place necessary tools into pouch located inside glove bag (or into a sleeve turned inside out). Tools needed typically include: wire saw, 5 in 1 scraper, wire brush, disposable towels, and plant mister. C. If a plant mister is not used within the glovebag, then a garden sprayer is to be used. The wand of the garden sprayer should be inserted into an open port in the glovebag and sealed so that the spray nozzle is inside the bag while the operating handle is outside the bag. D. Secure and seal glovebag in place with duct tape. Stapler can be used if preferred and available. E. Insert nozzle from HEPA vac through an open port. Duct tape port tightly around the nozzle to prevent leakage. F. Use smoke tube and aspirator bulb to test seal. Pierce smoke tube into glovebag, squeezing bulb and filling bag with visible smoke. Remove smoke tube seal opening. Gently squeeze glove bag and look for smoke leaking out, (especially at the top and ends of the glove bag). If leaks are found, tape closed using duct tape and re-test. G. Insert arm(s) into glovebag sleeves. H. Wet the material to be disturbed with amended water or other solution that is best suited for repair. I. Cut into the material needing repair and remove it from the area where the repair will occur. Avoid puncturing glovebag. J. Throughout this process, keep asbestos material wet. K. Once the material has been removed, clean the pipe or substrate where the asbestos material was previously located. L. Wash down inside of glovebag with amended water and wipe as necessary to move all debris and residue to lower part of glovebag (below where bag will be twisted and cut). Training Services International, Inc training.com

50 Asbestos Operations & Maintenance 09/13 Notes M. Clean tools with disposable rags, leave disposable rags at the bottom of glovebag. N. Place tools in glovebag sleeve that has been turned inside-out. Twist arm, sealing from rest of glovebag. Tape the twisted arm with enough tape that when cut in the middle both tapped ends remain sealed. Cut through the middle of the taped arm. O. Evacuate air from glovebag using HEPA vacuum. With HEPA vacuum operating and waste materials at the bottom of the bag, twist the bag several times and tape it to keep the material in the bottom during removal of the glove bag from the removal area. P. Cut the glovebag off the pipe anywhere above the taped and sealed area. Q. Place sealed, removed glovebag in an asbestos waste disposal bag. 3. Mini-Enclosures If a glovebag cannot contain a disturbance of asbestos material, minienclosures may be needed if the material will become non-intact. A minienclosure completely contains the asbestos repair activity, creates a negative pressure, and controls the air movement within the enclosure. This control method prevents asbestos fibers from escaping to the outside and collects them into a HEPA vacuum or small HEPA-filtered air filtration device (AFD). Steps to set up mini-enclosures are listed below. A. Set up the framework in a configuration that will contain the area to be repaired. The size of the area will need to house the repair and 1-2 workers activities. It is recommended not to make the enclosure any larger than necessary so that the area to be cleaned is kept at a EPA Photo minimum. A variety of materials and methods can be used for framework. Examples include 2 x4 wood studs, PVC piping and fittings, and steel piping. B. Once the framework is erected, seal the area by attaching the 6-mil poly. The poly can hang either inside or outside the framework. If the poly sheeting is on the outside, the framework (inside) will need to be decontaminated after the repair is completed. Complete the decontamination area by hanging poly if a decontamination chamber is used, or laying a drop cloth. The drop cloth should be large enough to hold waste bags, equipment, and decontamination activities. Training Services International, Inc training.com

51 Notes Asbestos Operations & Maintenance 09/13 C. A decontamination area is required by OSHA if the activity is expected to exceed the PEL or no negative exposure assessment exists. Decontamination areas can consist of a dropcloth outside the enclosure s entrance up to a separate decontamination chamber. If a separate chamber is used, the framework should be erected in conjunction with the enclosure s work area. D. Install the HEPA-vacuum in a manner that an air flow will be established across the enclosure. Air movement is to be directed away from the employee s breathing zone during removal. E. Before repairs begin, start HEPA-vacuum to establish negative pressure. Inspect and smoke test the enclosure for leaks, breaches, and to verify air movement inside the enclosure. F. Prior to entering the enclosure, have each employee put on a high efficiency cartridge respirator approved for use against asbestos and check the face-fit. G. Outside the enclosure, have each employee put on a disposable fullbody suit. Remember, the hood goes over the respirator straps. H. If the section of insulation is covered with an aluminum jacket, this is removed first using the wire cutters to cut any bands and the tin snips to remove the aluminum. I. Mist the exposed material. Cut the insulation/material away from the substrate immediately placing it into a 6-mil disposal bag. The 6-mil disposal bag should be properly marked with OSHA danger and EPA generator labels. J. Remove the remaining material targeted for the repair. Water must be continuously supplied. K. Once material has been removed, scrub and wipe down the exposed substrate. No visible debris should remain on the equipment or substrate where ACM was removed. L. Spray the entire work area inside the mini-enclosure, washing all debris down and placing it into the disposal bag. Use the spray encapsulant to encapsulate the exposed ends of insulation or material and the substrate. M. Wipe down all tools and equipment inside the mini-enclosure. Dispose of all rags as ACM in the disposal bag. N. Collapse the disposal bag with another HEPA-vacuum. Gooseneck the bag and seal neck with duct tape. Training Services International, Inc training.com

52 Asbestos Operations & Maintenance 09/13 Notes O. Remove all equipment and materials from the enclosure. Shut off the HEPA vacuum providing negative air. The enclosure, once thoroughly cleaned can be reused or disposed. Disposed enclosure poly sheeting should be treated as ACM. P. Remove the disposable suits and place these into the disposal bag with the poly. Q. Using a clean damp rag, wipe the exterior of the respirator and leave the work area. Remove the respirator. R. Asbestos-containing material must be disposed of at an approved landfill in accordance with EPA regulations. Training Services International, Inc training.com

53 Notes Asbestos Operations & Maintenance 09/13 Description Work Area Set up Protective Gear 4. Summary Comparison of Asbestos Repair Activities Level A Intact Repair Material can be removed w/o it becoming crumbled/ pulverized/ powdery. NEA available representing this repair Demarcate with signs & barrier tape Only GFCI circuits live Drop cloth underneath repair activity Drop cloth outside demarcated zone (optional w/ NEA) Place tools/ equipment/ supplies in work area None required w/ NEA. (optional) Disposable suits and respirators required w/o NEA Level B Glovebag Repair Material is non-intact or no NEA and disturbance can be performed entirely w/in glovebag Demarcate with signs & barrier tape Only GFCI circuits live Drop cloth underneath repair activity Drop cloth outside demarcated zone Place tools/ equipment/ supplies in work area and in glovebag Candystripe insulation that will remain and glovebag will be sealed onto. Install, seal & smoke test glovebag Disposable suits and respirators required even if NEA is available Level C Mini-Enclosure Repair Material is non-intact or no NEA and disturbance cannot be performed w/in glovebag Demarcate with signs & barrier tape Only GFCI circuits live Place tools/ equipment/ supplies in work area Construct minienclosure with 6-mil plastic sheeting Install HEPA vac or small AFD to establish negative pressure and air flow Set up drop cloth outside mini-enclosure entrance Disposable suits and respirators required even if NEA is available Training Services International, Inc training.com

54 Asbestos Operations & Maintenance 09/13 Notes Work Practices Level A Intact Repair w/ NEA HEPA vac before, during, & after repair Wet material Use knife/ scraper to dislodge material and place in asbestos disposal bag Wet wipe substrate Clean tools & equipment Remove protective gear Collapse & seal bag w/ HEPA vac Remove signs & tape Complete repair Level B Glovebag Repair Wet material to be disturbed inside glovebag Remove material from repair site, keeping material wet Thoroughly clean substrate where material was removed Wipe down inside of bag Clean tools and place in glovebag arms/ gloves, twist, tape & cut to remove tools Collapse glovebag w/ HEPA vac and twist separating clean top from asbestos in bottom of bag Place glovebag in asbestos disposal bag Clean tools & equipment Place drop cloths in asbestos disposal bag Remove protective gear and place suits & used filters in asbestos bags Collapse & seal bag w/ HEPA vac Remove signs & tape Complete repair Level C Mini-Enclosure Repair Wet material to be disturbed inside minienclosure Remove material and place in asbestos disposal bag Thoroughly clean substrate where material was removed Clean tools and place on drop cloth outside mini-enclosure entrance Wipe down inside of min-enclosure Mini-enclosure can either be reused for future repair or disposed Place plastic sheeting from drop cloths and disposed mineenclosure in asbestos disposal bag Clean tools & equipment Remove protective gear and place suits & used filters in asbestos bags Collapse & seal bag w/ HEPA vac Remove signs & tape Complete repair Training Services International, Inc training.com

55 Notes Asbestos Operations & Maintenance 09/13 5. Waste Handling & Disposal Asbestos material and contaminated coveralls, plastic sheeting, and cleaning rags are to be disposed in 2 6-mil asbestos disposal bags. The following procedures meet EPA and OSHA requirements. Use asbestos disposal 6-mil bags with the proper OSHA & DOT labels. DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD Thoroughly wet the asbestos, parts, debris, used rags, drop cloth and place in 1 st 6-mil plastic asbestos disposal bag at the point of repair. Use a HEPA-vacuum to collapse 1 st bag and seal by goose-necking with duct tape. Place the 1 st bag, cleaned decon drop cloth, disposable suits, and used respirator HEPA filters are all placed in 2 nd asbestos disposal bag with proper labels. Use a HEPA-vacuum to collapse 2 nd bag with and seal by goose-necking with duct tape Take the sealed asbestos waste to the designated, secured storage location. OSHA Label DOT Label Asbestos waste can remain in secured location indefinitely. Once the material is removed it must have a generator label affixed to it. All asbestos waste leaving the facility must have a waste manifest accompanying it. The manifest must be returned to the generator (building owner) within 35 days showing the waste was disposed properly. Training Services International, Inc training.com

56 Asbestos Operations & Maintenance 09/13 Notes 6. HEPA Vacuum Cleaning & Filter Replacement When the HEPA vacuum becomes full, the filter will need to be changed. This can be performed in an isolated shop area or outside in a secluded area. The following steps are recommended for replacing a HEPA vacuum filter. Step 1. Prep & Set-up 2. PPE Use 3. Access Contaminated HEPA Filter 4. Remove & Replace HEPA Filter 5. Clean Work Area Description Place a plastic sheet outside or in a shop-type area Place the HEPA vacuum in the center of the plastic along with the spray mister with amended water, disposable rags, and duct tape. The new HEPA filter box should be placed just off the edge of the plastic within easy reach. Respirators & protective clothing are optional If respirators are used: o Need medical clearance & current fit test o Don respirators & protective clothing prior to entering regulated area Seal filter opening with plug provided with vac or duct tape Open vacuum and mist the HEPA filter box and vacuum interior. Carefully remove the HEPA filter box Seal the second opening with the provided plug or a small piece of duct tape. Place the HEPA filter box into the disposal bag. Wet wipe inside of vacuum Install the new HEPA filer box into the vac. Remove plug on motor side before installing filter. in asbestos bag Mist and wet wipe drop cloth beneath repair activity Carefully fold drop cloth so that top surface is folded in. Place drop cloth and disposable rags Training Services International, Inc training.com

57 Notes Asbestos Operations & Maintenance 09/13 Step 6. Contain & Seal Waste Description Sealed plastic HEPA filter acts as 1 st container If wearing PPE, go to drop cloth outside regulated area: o HEPA vac and remove protective suits turning inside out o Wipe and remove respirators o Wet wipe drop cloth outside regulated area o Place suits and drop cloth in disposal bag o Place discarded respirator filters in disposal bag Collapse asbestos disposal bag with HEPA vac, gooseneck with duct tape 7. Closeout Take asbestos waste bag to designated location Material-Specific Requirements The following tables list various examples of cleaning and O&M activities that may occur in a facility. For each type of activity, notification, training, work area set-up, hygiene facilities, work practices, air sampling, medical, respiratory protection, protective clothing, and waste disposal requirements are summarized. The activities addressed are: Piping System Insulation Repair Surfacing Material Repair Boiler and Tank Insulation Repair Drywall/ Joint Compound Repair Gasket Removal Repairs Involving Flooring Material Repairs Involving Transite Siding Repairs Involving Roofing Material Clean-up Procedures/ Fiber Release Episodes Training Services International, Inc training.com

58 Asbestos Operations & Maintenance 09/13 Notes Scope Notification Training Isolate and Set-up Work Area Air Sampling Work Practices Respirator use Protective Clothing Hygiene Facilities Waste Disposal Medical Exams Piping System Insulation Repair Repairs not exceeding the amount contained in 1 disposal bag or glovebag (OSHA) and/ or limited to small scale-short duration repairs (AHERA) Employers inform employees in adjacent areas. Building owners notify tenants. Occupants notified per AHERA Worker 16- Hour Operations & Maintenance (O&M), annual refresher Competent Person 16- Hr O&M, annual refresher Establish a regulated area including: Demarcate with OSHA Danger signs, barrier tape recommended Limit access to authorized persons Seal or shut down HVAC in regulated area Place drop cloth under repair area Place at least a drop cloth at the work area entrance to act as a decontamination area to hold workers, waste, and equipment. Not required if NEA exists. All employers who have a workplace covered by this standard must conduct initial and periodic exposure assessment monitoring. Not required if a NEA has been conducted within last twelve months. Area and final clearance air samples are not recommended unless requested or concern exists regarding air quality. All work to be supervised by a competent person If only patching will be conducted (no disturbance), a drop cloth under repair area is usually sufficient Utilize glovebag techniques to remove insulation if feasible, use mini enclosure if glovebag is not feesible Utilize wet methods, HEPA-vac, and prompt clean-up to collect material as disturbed in mini-enclosure Exposed areas of insulation not to be removed can be repaired with wet-wrap techniques using re-wettable cloth and bridging encapsulant Wet wipe and HEPA-vac work area after removal Minimum of half mask APR required in regulated area when disturbing TSI. Must have respiratory protection program Disposable suits recommended in all situations, must be worn if no NEA exists. Must place a drop cloth outside the regulated area for decontamination purposes when no NEA exists for repair. May want to use decontamination chamber or shower for difficult repairs within the mini-enclosure. Access to at least hand washing facilities recommended All waste to be disposed of in sealed, labeled, leak-tight containers. Two 6-mil plastic bags, one 6-mil bag and a sealed drum, or equivalent. Glovebag acts as 1 6-mil layer. Send to an EPA approved asbestos landfill for disposal. Medical exam required through licensed physician for respirator clearance. Medical surveillance program required for any employee performing repair or exposed at or above the PEL 30 or more days per year (1 day counted after 1 hour of work) Training Services International, Inc training.com

59 Notes Asbestos Operations & Maintenance 09/13 Scope Notification Training Isolate and Set-up Work Area Air Sampling Work Practices Respirator use Protective Clothing Hygiene Facilities Waste Disposal Medical Exams Surfacing Material Repair Repairs not exceeding the amount contained in 1 disposal bag or glovebag (OSHA) and/ or limited to small scale-short duration repairs (AHERA) Employers inform employees in adjacent areas. Building owners notify tenants. Occupants notified per AHERA. Worker 16- Hour Operations & Maintenance (O&M), annual refresher Competent Person 16- Hr O&M, annual refresher Establish a regulated area including: Demarcate with OSHA Danger signs, barrier tape recommended Limit access to authorized persons Seal or shut down HVAC in regulated area Place drop cloth under repair area if local vac and collection system will effectively contain disturbance For repairs not effective with spread cone, set up tent or free-standing minienclosure containing immediate area where removal and repair (disturbance) will occur Place at least a drop cloth at the work area entrance to act as a decontamination area to hold workers, waste, and equipment. Decon chamber can be used if determined feasible and desired All employers who have a workplace covered by this standard must conduct initial and periodic exposure assessment monitoring. Not required if a NEA has been conducted within last twelve months. Area and final clearance air samples are not recommended unless requested or a lot of concern exists regarding air quality. All work to be supervised by a competent person Mist material with amended water prior to and during disturbance Utilize HEPA-vac to collect material as disturbed with spread-cone or conduct repair in mini-enclosure When spread cone airflow becomes restricted, dispose of debris promptly. In a mini-enclosure place material immediately into disposal bag Wet wipe and HEPA-vac work area after removal Minimum of half mask APR required in regulated area when disturbing surfacing materials. Must have respiratory protection program. Disposable suits recommended in all situations, must be worn if no NEA exists. Must place a drop cloth outside the regulated area for decontamination purposes when no NEA exists for repair. May want to use decontamination chamber or shower for difficult repairs Access to at least hand washing facilities recommended All waste to be disposed of in sealed, labeled, leak-tight containers. Two 6-mil plastic bags, one 6-mil bag and a sealed drum, or equivalent. Send to an EPA approved asbestos landfill for disposal. Medical exam required through licensed physician for respirator clearance. Medical surveillance program required for any employee performing repair or exposed at or above the PEL 30 or more days per year (1 day counted after 1 hour of work) Training Services International, Inc training.com

60 Notes Asbestos Operations & Maintenance 09/13 SECTION 11 COMPETENT PERSON RESPONSIBILITIES Overview An asbestos competent person or project supervisor is responsible for all activities that occur at the work site during asbestos repair activities. There is one competent person designated by the employer for the work site. 1. Competent Person Capabilities Identifying asbestos hazards at the workplace Selecting the appropriate control strategy for asbestos exposure. Authority to take prompt corrective measures to eliminate these hazards. Maintaining the proper training. Determining employee exposure levels (usually done with air sampling). 2. Competent person responsibilities Any violations, injuries, or damage at the project site. The competent person may be personally responsible. Must make regular inspections of the job site. 3. Competent Person Repair Activity Duties One competent person is assigned to each gasket repair activity. The assigned competent person is responsible for the overall performance of the repair, but is not obligated to do the work. Any personal air sampling is also the responsibility of the competent person. The sampling may be conducted by someone other than the competent person, but it remains his or her responsibility. Other personnel who may be conducting personnel air sampling during asbestos gasket repair activities includes environmental or industrial hygiene personnel and contracted environmental consultants. Training Services International, Inc training.com

61 Asbestos Operations & Maintenance 09/13 Notes Duties for each repair activity should include: Identify repairs that involve asbestos-containing gaskets or repairs on gaskets that the asbestos content is unknown Determine the requirements of the repair including the gasket condition and level of repair. Review available NEA and determine if personnel air sampling will be conducted. Make sure all assigned personnel are asbestos qualified and have the proper protective equipment, tools and supplies to complete the asbestos gasket repair. Review work area set up, work practices, clean up and disposal requirements with asbestos gasket repair personnel. This includes an understanding of the procedures for each level of work and how to adjust to an upper level if the material condition changes during the repair. Be available during the repair to respond to any questions or situations that require your attention. Review paperwork, repair site, and waste disposal location after repair to determine all activities were completed properly. Oversee keeping gasket repair kit stocked and maintained in good working order. File completed paperwork in designated location. Make available air sampling reports with asbestos gasket repair personnel. Training Services International, Inc training.com

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