Safety Manual 1 of 9 Safety Manual Sect: 1.0 Purpose 2.0 Scope Rel. Date: Last Review: This program covers Ardent policy related to asbestos, either discovered or suspected in the workplace. Ardent recognizes asbestos as a very serious health hazard. The intent of this policy is to provide Ardent employees with general knowledge and guidelines enabling employees to protect themselves and others from unnecessary asbestos exposure. It is Ardent policy not to engage in asbestos abatement activities. Upon discovery or suspicion of Asbestos being present on a jobsite, Ardent employees are to stop the work and immediately inform their supervisor. This and Policy is intended for support of, and use by company operations both in business units and project operations. This program is hazard recognition and education focused and does not imply that any training associated with this program certifies or qualifies any Ardent employee to handle asbestos or carry-out operations associated with the encapsulation, removal, transport or disposal of materials containing asbestos. 3.0 Regulatory References This is primarily intended to satisfy the following regulatory requirements: 29 CFR 1910.1001, 29 CFR 1926.1101, Cal/OSHA T8 CCR1529 4.0 Policy 4.1 Stop the Work Immediately - Upon discovery or suspicion of asbestos being present on a jobsite, Ardent employees are to stop the work immediately and inform their supervisor. 4.2 Do Not Handle Asbestos Products - It is Ardent policy that employees shall not knowingly handle products or materials containing asbestos. 4.3 Do Not Engage in Abatement Activities - It is Ardent policy that employees shall not engage in asbestos abatement activities. 4.4 Do Not Dispose of Asbestos - It is Ardent policy that employees shall not participate in the disposal of products or materials containing asbestos. Jan 2011 March 2016
Page 2 of 9 4.5 Contact a Licensed Asbestos Professional - It is Ardent policy to contact a licensed Asbestos Abatement Contractor and/or a laboratory certified to perform asbestos analysis of samples upon discovery or suspicion of asbestos materials being present. 4.6 Avoid Exposure It is Ardent policy to train employees with general knowledge and guidelines enabling them to protect themselves and others from unnecessary asbestos exposure. 5.0 Responsibilities 5.1 Management Ardent Management is responsible for the following: Ensure that the HSE Management System includes an asbestos policy and that the policy is reviewed annually and revised as necessary. Provide asbestos hazard awareness training for all employees. Provide leadership and support for employees in communicating their responsibility to stop the work when asbestos hazard are discovered or suspected. Provide resources to address and correct any asbestos related events that arise. 5.2 Supervision Ardent Supervision is responsible for the following: Understand and enforce the Ardent Asbestos Policy Implement site controls isolating employees from asbestos hazards when asbestos is discovered or suspected on a jobsite. Immediately inform management of any asbestos discovery or suspicion on a jobsite. Provide immediate on-the-spot training for all employees on the jobsite regarding Ardent Asbestos Policy and guidelines enabling employees to protect themselves and others from unnecessary asbestos exposure. Contact a licensed Asbestos Abatement Contractor or a laboratory certified to perform asbestos analysis of samples. 5.3 Employees Ardent Employees are responsible for the following: Upon discovery or suspicion of Asbestos being present on a jobsite, Ardent employees are to stop the work and immediately inform their supervisor. Protect themselves and others from unnecessary asbestos exposure. Conduct operations in accordance with Ardent provided asbestos hazard awareness training.
Page 3 of 9 Immediately report to a supervisor any changes, deficiency or breaches in site controls established to isolate employees from asbestos hazards on a jobsite. 6.0 Hazard Recognition & Control Asbestos is a naturally occurring mineral fiber widely used in construction because of its special properties. Highly resistant to destruction by heat or chemicals, its fibers have been used extensively in insulation materials. Asbestos can be found in vinyl tiles, roof shingles, furnace insulation, pipe insulation, wall and ceiling joint compounds and textured coatings, with most applications occurring between 1945 and 1977. Widespread use in consumer products was banned in 1977. 6.1 Exposure & Health Exposure to asbestos occurs when asbestos fibers are released into the air and inhaled. Many believe there is no definite safe exposure level. Even short-term exposure to asbestos can be harmful. Exposure to asbestos may cause several types of serious diseases including, asbestosis, lung cancer, mesothelioma, and contribute to other cancers. 6.2 Hazard Recognition With the exception of product labels identifying asbestos content, laboratory testing is the only reliable method of confirming the presence of asbestos. Employees will be better served with knowledge of the types of products likely to contain asbestos. Asbestos containing materials generally fall into two categories which may be described as follows: Friable Asbestos Material is a term used to describe any asbestoscontaining material that when dry, can be easily crumbled or pulverized to powder by hand. Some common examples of friable asbestos are acoustic ceilings and tiles, many types of plasters, wallboard, joint compound or "mud" and thermal insulation for water heaters and pipes Non-Friable Asbestos Material contain a binder or hardening agent such as cement, asphalt or vinyl and cannot be easily crumbled. Examples are asphalt roofing shingles, vinyl asbestos floor tiles and transite siding made with cement. The danger with this type of material is that it can pose the same hazard as friable asbestos during remodeling, repairs or other construction where the material is subject to cutting, sanding or grinding.
Page 4 of 9 Listed below are some of the more common locations or products that may contain asbestos: 6.2.1 Corrugated Sheets - Asbestos corrugated sheets used as a siding material on some industrial buildings and fencing. This wave shaped material appears whitish to grayish in color. 6.2.2 Transite Conduit and Pipe This product is a cement pipe material used in various underground conduit installations and appears whitish to grayish in color. 6.2.3 Asbestos Insulated Wire Asbestos insulated wire generally has a fibrous appearance and may have designations AF, A, AA, AIA. 6.2.4 Asbestos Insulated Cable Asbestos insulated cable generally has a fibrous appearance to either the outer jacket and/or inner conductor insulation and may have designations AVA, AVB, or AVL. 6.2.5 Pipe Insulation - Any piping used for hot or chilled services is likely to be insulated. Segmented blocks formed to the pipe diameter; asbestos blankets and asbestos paper tape were all used on piping systems installed between 1920 and 1972. Asbestos insulation may also be found on furnace ducts and boilers. If broken or exposed to ware, these insulations should be tested. Encapsulating these installations is often the best approach for limiting exposure. 6.2.6 Vinyl Floor Tiles and Sheeting Added for strength it is also present in the backing on some vinyl sheet flooring and adhesives use to place flooring. While mostly bound in compounds asbestos fibers can be released if the surface is sanded or cut. 6.2.7 Patch Compounds and Textured Paints Some wall and ceiling joint compounds and textured paints sold before 1978 contained asbestos fibers. If in good condition, they are best left alone. Sanding or cutting these surfaces should be avoided. 6.2.8 Ceilings Many buildings built or remodeled between 1945 and 1978 may contain asbestos material. These finishes were sprayed or troweled onto the ceiling or walls. If these surfaces are crumbly or damaged, testing should be performed to determine if they contain asbestos. 6.2.9 Stove Insulation Cement sheets, millboard and paper products containing asbestos were often used in homes with wood-burning stoves to shield the floor and walls. Cement sheets are less likely to release fibers but any of these products exposed to ware should be tested. 6.2.10 Furnace Insulation - Oil, coal and wood burning furnaces found in some older homes may contain asbestos in the insulation. If
Page 5 of 9 insulation is in good condition, it is best left alone. If broken or exposed to ware, it should be tested. 6.3 Control Education, isolation and avoidance will be the primary controls used by Ardent to protect employees and enable employees to protect themselves and others. 7.0 General Guidelines for Asbestos Events It is Ardent policy that employees shall not knowingly handle products or materials containing asbestos. 7.1 Do Not Handle Asbestos Materials 7.1.1 Ardent employees are to stop the work and immediately inform their supervisor. 7.1.2 Do not disturb any material suspected to contain asbestos. 7.1.3 Obey all warning signs or labels and do not disturb any asbestos containing material. 7.1.4 Seal off the work area as reasonably possible. Be cautious not to track asbestos dust into other areas. 7.1.5 Do not dust sweep or vacuum particles suspected to contain asbestos. 7.1.6 If you suspect you have handled materials containing asbestos, wash-up immediately. Work clothes should be isolated in a plastic bag and washed separately from other laundry. 7.2 Multiple Contractor Jobsites In the event that Ardent employees become exposed to asbestos due to the inadequate containment of work by other contractors, all Ardent employees will be removed from the area until the containment issue is resolved and the results of an initial exposure assessment pursuant to Section 7.3 indicate that the area is safe for work. 7.3 Exposure Air monitoring of the breathing zones will be used to ensure that no employee is exposed to an airborne concentration of asbestos in excess of 0.1 fiber per cubic centimeter of air as an eight (8) hour time-weighted average (TWA) and 1.0 fiber per cubic centimeter of air (1 f/cc) as averaged over a sampling period of thirty (30) minutes,
Page 6 of 9 7.4 Written In the event that exposure levels exceed the limits as indicated in Section 7.3, a written program will be developed and implemented to reduce employee exposure. 7.5 Regulated Areas A regulated area is an area established to demarcate areas where Class I, II, and III asbestos work is conducted, and any adjoining area where debris and waste from such asbestos work accumulate; and a work area within which airborne concentrations of asbestos, exceed or there is a reasonable possibility they may exceed the exposure limit as indicated in Section 7.3. 7.5.1 Warning signs that demarcate the regulated area shall be provided and displayed at each location where a regulated area is required to be established. Signs shall be posted at such a distance from such a location that an employee may read the signs and take necessary protective steps before entering the area marked by the signs. 7.5.2 The warning signs required by this section shall bear the following information: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY 7.5.3 In addition, where the use of respirators and protective clothing is required in the regulated area under this section, the warning signs shall include the following: RESPIRATORS AND PROTECTION CLOTHING ARE REQUIRED IN THIS AREA 7.6 Engineering Controls In the event Ardent is requested to work in proximity to a regulated area, the supervisor shall request that the client provide engineering controls to reduce employee exposure. 7.6.1 Engineering Controls may include the following: Vacuum cleaners equipped with HEPA filters to collect all debris and dust.
Page 7 of 9 Wet methods, or wetting agents, during asbestos handling, mixing, removal, cutting, application, and cleanup. Prompt clean-up and disposal of wastes and debris. Personal Protective Equipment In the event that the Engineering Controls as indicated in Section 7.6 are not feasible, all Ardent employees will be provided with the following Personal Protective Equipment at no cost: o NIOSH approved respirators o Coveralls o Gloves o Head Coverings o Foot Coverings (other than steel toed foot wear) o Face Shields o Vented Goggles o Additional PPE as required 7.7 Disposal It is Ardent policy that employees shall not participate in the disposal of products or materials containing asbestos. The following guidelines are provided for education and awareness purposes only! 7.7.1 It is the legal responsibility of the property or building owner to properly package, transport and dispose of the wastes without posing any unnecessary risk to the public. 7.7.2 Asbestos waste must be handled and transported in one of the following ways: In sealed non-returnable containers with double 6-mil thick plastic bag liners from which fibers can t escape. Waste should be wetted to prevent blowing of fibers if the containing is broken. In closed vehicles if waste is too bulky to enclose in sealed containers. Waste should be wetted to prevent blowing of fibers. 7.7.3 Hazardous wastes are to be transported in closed containers and packed in a manner to prevent containers from tipping, spilling or breaking during transport.
Page 8 of 9 7.7.4 Different hazardous waste materials are not to be mixed in the same container during transport. 7.7.5 Caution labels are required on containers and must be conspicuous legible lettering that spells the following warning or equivalent: CAUTION! Contains asbestos fibers, avoid creating dust, breathing asbestos dust may cause serious bodily harm. Regulations regarding disposal of asbestos material may vary from state to state. Contact your local health department or fire department hazardous material unit for guidance in the handling and packaging of asbestos materials. 8.0 Training Ardent will provide asbestos hazard awareness training for all employees. All Asbestos Hazard Awareness Training shall be documented. 8.1 Training Content - Training will cover the following topics: 8.1.1 Asbestos Hazard Awareness Training Ardent Asbestos Policy Responsibilities Hazard Recognition & Control 8.1.2 All written training material will be available to all affected employees as well as the Assistant Secretary of Labor for Occupational Safety and Health and the director of the National Institute for Occupational Safety and Health. 8.2 Personnel Training Ardent personnel shall receive the following training: 8.2.1 All employees shall receive Asbestos Hazard Awareness training. 8.3 Training Frequency - Training and re-training frequency shall be as follows: 8.3.1 Initial awareness training shall take place in the first 180 days of employment and/or when employees mobilize to job-sites with known asbestos hazards. Asbestos awareness training shall be refreshed semi-annually as part of the Toolbox Safety Meeting, Hazard Communication agenda.
Page 9 of 9 9.0 Reporting and Recordkeeping 9.1 Reports All asbestos related events shall be reported. 9.1.1 Incident Report - All asbestos discovery events shall be record as Incidents on an Ardent Incident Report. 9.1.2 Near Miss Reports - Failures in containment, control methods, isolation, etc., not resulting in employee exposure shall be record as near miss events on an Ardent Near Miss Report. 9.2 Control & Retention Records associated with this program shall be handled in the following manner. Incident/Accident shall be handled pre the Incident Reporting and Record Keeping. Records shall be retained for a minimum of the employee s duration of employment plus 30 years.