Safety Policy and Procedure

Safety Policy and Procedure Policy Number 045 Authorized By: The Cianbro Companies Alan Burton Title: Asbestos Operations Effective Date: 03/25/09 Page 1 of 10 1 Status 1.1 Update of existing policy, effective 09/20/10. 2 Purpose 2.1 To ensure that any asbestos abatement for which Cianbro is responsible or which could affect Cianbro team members, is in compliance with OSHA 29 CFR 1926.1101, State and local regulations. 3 Applicability 3.1 This policy applies to all subsidiary companies and departments of the Cianbro Companies. 3.2 All organizations are required to comply with the provisions of this policy and procedure. Any deviation, unless spelled out specifically in the policy, requires the permission of the Corporate Safety Officer or designee. 4 Definitions 4.1 Asbestos: A widely used, mineral-based material that is resistant to heat and corrosive chemicals. Typically, asbestos appears as a whitish, fibrous material that may release fibers that range in texture from coarse to silky; however, airborne fibers that can cause health damage may be too small to see with the naked eye. 4.2 Asbestos Containing Material (ACM): Any material containing more than 1% asbestos. 4.3 Authorized Person: Any person authorized by the employer and required by work duties to be present in regulated areas. 4.4 Class I Asbestos Work: Activities involving the removal of thermal system insulation (TSI) and surfacing ACM. 4.5 Class II Asbestos Work: Activities involving the removal of ACM which is not thermal system insulation or surfacing material. This includes the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics. 4.6 Class III Asbestos Work: Repair and maintenance operations where ACM including TSI and surfacing ACM may be disturbed. Examples are working on boilers, valves or pipes or replacing light fixtures or ceiling tiles. 4.7 Class IV Asbestos Work: Maintenance and custodial activities during which workers contact but do not disturb ACM. Examples include clean-up after Class I, II, and III work, cleaning up construction waste and debris from the installation of new ACM, stripping and buffing resilient flooring and sweeping, dusting or vacuuming asbestos-containing dust from surfaces or carpeting. 4.8 Competent Person: A person who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure and who has the authority to take prompt corrective measures to eliminate them. In addition, for Class I and Class II work who has had a training course which meets the criteria of the EPA s Model. Policy: 045 Asbestos Operations Rev. 09/20/10 Page 1

4.9 Fiber: A particulate form of asbestos 5 micrometers or longer, with a length-to-diameter ratio of at least 3 to 1. 4.10 Friable Asbestos: A term used to describe any asbestos containing material that when dry, can be easily crumbled or pulverized to powder by hand. Some common examples of items that may contain friable asbestos are pipe and vessel insulation, gaskets, wallboard, some plasters, and acoustical ceiling tiles. 4.11 Glove bag: A not more than a 60 x 60 inch impervious plastic bag-like enclosure affixed around an asbestos-containing material, with glove-like appendages through which materials and tools may be handled. 4.12 Non-Friable Asbestos: A term used to describe any asbestos that is not as likely to become airborne because it contains a binder or hardening agent such as cement, asphalt or vinyl. Although not as hazardous if it is not disturbed to create particulate, it still needs to be removed, handled and disposed of by qualified individuals. Examples are asphalt roofing shingles, vinyl asbestos floor tiles and transite siding made with cement. Non-friable asbestos can be made friable if disturbed. 4.13 Regulated Area: An area established by the employer to identify and mark locations where airborne concentrations of asbestos exceed, or there is a reasonable possibility they may exceed, the permissible exposure limits. All Class I, II, and III asbestos work must be conducted in regulated areas. 5 Policy 5.1 Cianbro does not self perform asbestos abatement. Any asbestos work managed by Cianbro must meet the minimum requirement contained in this policy. 5.2 There are specific limited cases where Cianbro directly supports the asbestos abatement activities of an abatement subcontractor (Heavy equipment operation is one example) and would need to be trained to a higher level. These are all on a case by case basis and must have the approval of the Corporate Safety Officer or designee. 6 Responsibilities 6.1 The Corporate Safety Officer or designee is responsible for providing approval for any deviations from the requirements contained in this policy. 6.2 The top Cianbro manager at the job site is responsible for the implementation of this policy. 6.3 Corporate Safety is responsible for maintaining this document. Policy: 045 Asbestos Operations Rev. 09/20/10 Page 2

7 Asbestos Policy Index 7.1 Exposure Limits... 3 7.2 Precautionary Procedures and Personal Monitoring... 3 7.3 Methods of Compliance... 4 7.4 Personal Protective Equipment... 5 7.5 Hygiene... 6 7.6 Signs, Barricades, and Labels... 7 7.7 Training Requirements... 7 7.8 Medical Surveillance and Recordkeeping... 8 7.9 State and Local Requirements... 8 9 Related Documents... 9 9.1 Appendix A Asbestos Awareness... 10 7.1 Exposure Limits Although Cianbro does not perform asbestos abatement, we are sometimes asked to manage other contractors who do asbestos work. This policy is intended to be a general overview that provides minimum requirements for asbestos abatement activities. Project sites can utilize this policy 7.1.1 When asbestos is crushed it disperses a dusting of microscopic fibers into the air that can remain for very long periods of time. These fibers can be unknowingly inhaled and permanently lodged in lung and other body tissues, yet symptoms might not appear for 20 years or more. Exposure to asbestos can cause asbestosis (scarring of the lungs resulting in loss of lung function that often progresses to disability and to death); mesothelioma (cancer affecting the membranes lining the lungs and abdomen); lung cancer; and cancers of the esophagus, stomach, colon, and rectum. Unfortunately there is no known safe level of exposure. 7.1.2 Subcontractors engaging in asbestos work must ensure that no worker 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). In addition, no worker may be exposed to an airborne concentration of asbestos in excess of 1.0 fiber per cubic centimeter of air (1 f/cc) as averaged over the excursion sampling period of thirty (30) minutes. 7.1.3 Asbestos awareness will be reviewed with all Cianbro team members during the site specific orientation. 7.1.4 If asbestos is identified in the work area, all work that could disturb the asbestos will stop until the asbestos is abated by a qualified asbestos abatement company. 7.2 Precautionary Procedures and Personal Monitoring 7.2.1 Precautionary Procedures Regulated areas must be established wherever airborne concentrations of asbestos are in excess of the TWA. The regulated area must be identified from the rest of the workplace and access must be limited to authorized personnel. Each person entering a regulated area must be issued and required to wear a respirator and must be instructed not to eat, drink, smoke, chew gum or tobacco, or apply cosmetics while inside the regulated area. Engineering and work practice controls must be implemented, when feasible, to reduce and maintain worker exposure to or below the TWA. When such controls are not sufficient to reduce exposure to or below the TWA, they must still be used to reduce exposure to the lowest achievable level and supplemented with appropriate respiratory protection. Whenever practical, asbestos should be handled, mixed, applied, removed, cut, scored, etc. in a wet state sufficient to prevent emission of airborne fibers. ANSI compliant local exhaust ventilation and dust collection systems may also be utilized to minimize exposure. Policy: 045 Asbestos Operations Rev. 09/20/10 Page 3

7.2.2 Personal Monitoring Determinations of worker exposure shall be made from breathing zone air samples that are representative of the 8-hour TWA and 30-minute short-term excursion exposures of each worker. Representative 8-hour TWA worker exposures shall be determined on the basis of one or more samples representing full-shift exposures for each shift for each worker in each job classification in each work area. Initial monitoring must be done for each worker who is, or may reasonably be expected to be exposed to airborne concentrations at or above the TWA permissible exposure limit and/or 30 minute excursion limit. After the initial determinations, samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of the worker. In no case shall sampling be at intervals greater than six months for workers whose exposures may reasonably be foreseen to exceed the TWA permissible exposure limit. 7.3 Methods of Compliance 7.3.1 Due to the fact that exposure to airborne asbestos is sometimes difficult to measure reliably, OSHA standards require certain controls for specific asbestos jobs, regardless of measured exposure levels. OSHA groups together work operations that have similar exposure levels and risk into four classes (I, II, III, and IV). Methods of compliance for each category are as follows: 7.3.2 Class I Jobs Require: Supervision by a competent person. Critical barriers over all openings to the regulated area, or another barrier or isolation method which prevents the migration of airborne asbestos from the regulated area. Isolation of HVAC systems in the regulated area (double layer of 6 mil plastic or equivalent). Impermeable drop cloths on surfaces beneath removal activity. Covering of all objects within the regulated area with impermeable materials. Where employer cannot produce a negative exposure assessment, or where PEL is exceeded, ventilation of the regulated area to move air from the employee s breathing zone toward HEPA-filtered collection device. One or more of the following specific control methods shall be used for Class I work: Negative Pressure Enclosure (NPE) Systems, where the configuration of the work area does not make erection feasible. Glove Bag Systems, for removal of PACM and/or ACM from straight runs of piping, elbows, and other connections. Negative Pressure Glove Bag Systems, for removal of ACM or PACM from piping. A small walk-in enclosure accommodating no more than 2 persons, if the project can be completely contained in the enclosure. 7.3.3 Class II Jobs Require: Supervision by a competent person. Critical barriers over all openings to regulated area, or another barrier or isolation method which prevents the migration of airborne asbestos from the regulated area. For all Class II jobs where there is no negative exposure assessment. For Class II jobs where there may be exposure above the PEL. For Class II jobs where the employer does not remove the ACM in a substantially intact state. Impermeable drop cloths on surfaces beneath removal activity. Additional specific controls are listed for various types of Class II work. Removal of vinyl and asphalt flooring materials which contain ACM or for which in buildings constructed no later than 1980, the employer has not verified the absence of ACM. Removal of roofing material which contains ACM. Policy: 045 Asbestos Operations Rev. 09/20/10 Page 4

Removal of cementitious asbestos-containing siding and shingles or transite panels containing ACM. Removal of gaskets containing ACM. Performing any other Class II removal of asbestos-containing material. Installation, removal, or repair of intact bituminous/resinous encapsulated roof flashings and asphaltic pipeline wraps. Class I methods may also be used for Class II work, except that glove bags are allowed if they fully enclose the Class II material to be removed. 7.3.4 Class III Jobs Require: Workers are to wear a minimum of a half face cartridge respirator equipped with a HEPA (N100) filter. Use a glove bag for removal of TSI. Plastic sheeting is to be used as a drop cloth on the floor below any TSI and surfacing material that is to be removed. Wet methods of ACM removal are to be used to minimize airborne asbestos. The room or area must be isolated from the building ventilation system. Enclosures under negative pressure are to be constructed to isolate the ACM removal from other areas of the building. Perform the work using local exhaust ventilation, to the extent feasible. 7.3.5 Class IV Jobs Require: Use of wet methods for cleanup. Use of a HEPA vacuum. Respiratory protection. Bag or wrap and label the material and place in the designated asbestos container. 7.3.6 Cianbro must ensure subcontractor compliance with these, and all other requirements under the asbestos regulations. In order to effectively do this, the following documentation must be required from the subcontractor and be reviewed by the site management team for compliance; Written asbestos abatement plan. Medical surveillance records. Air sampling results. Training records. Documented daily inspections made by the competent person. Required notifications and permits. Asbestos waste shipment manifests. 7.3.7 Inspections of the work areas by site management must also be completed (to the extent allowed under the regulations) to ensure compliance with established work practices. 7.4 Personal Protective Equipment 7.4.1 After engineering and work practice controls are in place to minimize the asbestos hazard, protective clothing must be utilized. At a minimum, this shall include gloves, coveralls or Tyvek suits, head coverings, boots, eye protection and hard hats. These items will be provided at no cost to the worker. Clean protective coveralls or Tyvek suits must be provided weekly, or as necessary to insure that they maintain their effectiveness. However, Tyvek suits must be repaired or replaced immediately if ripped or torn. Respiratory protection will be provided at no cost to the worker and should only be used as a last resort or under the following circumstances; When there is no reasonable way to eliminate the airborne contaminant. During periods necessary to implement feasible engineering and work practice controls. If initial air monitoring results show that the contaminant still exists at levels above the PEL despite engineering and work practice controls. During emergency situations. When necessary, respiratory protection shall be selected in accordance with Table 1 below and used in accordance with 29 CFR 1910.134. PAPR s must be made available Policy: 045 Asbestos Operations Rev. 09/20/10 Page 5

to workers should they request them provided known exposure limits for PAPR use are not exceeded. Table 1 -- Assigned Protection Factors Type of respirator 1, 2 Quarter mask Half mask Full facepiece Helmet/ hood Loose-fitting facepiece 1. Air-Purifying Respirator 5 10 50 2. Powered Air-Purifying Respirator 50 1,000 25/1,000 25 (PAPR) 3. Supplied-Air Respirator (SAR) or Airline Respirator Demand mode Continuous flow mode Pressure-demand or other positive-pressure mode 10 50 50 50 1,000 1,000 25/1,000 25 4. Self-Contained Breathing Apparatus (SCBA) Demand mode Pressure-demand or other positive-pressure mode (e.g., open/closed circuit) 7.5 Hygiene 10 50 10,000 50 10,000 7.5.1 Good hygiene practices are essential to minimize not only the asbestos worker s exposure, but also the possible exposure of other workers not engaged in asbestos abatement that may be working in the general area. Minimum hygiene requirements where worker exposure is above the TWA include; Adequate and clean change areas, showers and lunchroom facilities. Workers must wash their hands and face prior to eating, drinking and smoking and shower at the end of their work shift. No smoking is allowed in the work area. Workers must not enter lunchroom facilities with protective clothing or equipment unless they are adequately decontaminated. Contaminated work clothing must be removed in change areas and not taken out of change areas unless by an authorized person for laundering or disposal. Anyone asked to launder contaminated clothing must be informed of the presence of asbestos and that it must be done so as to prevent the release of airborne asbestos fibers in excess of the established PEL. Surfaces must be kept as free as practicable of ACM waste and debris and accompanying dust. HEPA-filtered vacuuming equipment shall be used for vacuuming ACM waste and debris and must be used and emptied in a manner which minimizes the re-entry of ACM into the workplace. Policy: 045 Asbestos Operations Rev. 09/20/10 Page 6

7.6 Signs, Barricades, and Labels Warning signs in conjunction with red barricade tape (where applicable) must be provided and displayed at each regulated area. In addition, warning signs must be posted at all approaches to regulated areas so that workers can read the signs and take necessary precautions prior to entry. Where the use of respirators and protective clothing is required, it must be stated as well. Each sign must bear the following information: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA Example Warning labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers. When a building owner or employer identifies previously installed ACM, labels or signs shall be affixed or posted so that workers will be notified of what materials contain ACM. The employer shall attach such labels in areas where they will clearly be noticed by workers who are likely to be exposed, such as at the entrance to mechanical room/areas. Each label must bear the following information; DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD Example Cianbro team members must be trained to recognize asbestos signage, barricades and labels and to avoid asbestos areas. Any team member who enters an asbestos warning area without authorization or disregards an asbestos sign or label will be subject to disciplinary action. 7.7 Training Requirements 7.7.1 Training is required for all workers who perform Class I through IV asbestos work. The training must meet the requirements of the EPA Model Accreditation Plan (MAP) for asbestos abatement worker training. No untrained workers are to disturb any amount of asbestos. The appropriate level of training must be provided prior to initial assignment and annually there after. The training must be conducted in a manner which workers can understand and include the following topics; The health effects associated with asbestos exposure. The relationship between smoking and exposure to asbestos producing lung cancer. Policy: 045 Asbestos Operations Rev. 09/20/10 Page 7

The quantity, location, manner of use, release, and storage of asbestos, and the specific nature of operations which could result in exposure to asbestos. The engineering controls and work practices associated with the worker's job assignment. The specific procedures implemented to protect workers from exposure to asbestos, such as appropriate work practices, emergency and clean-up procedures, and personal protective equipment to be used. The purpose, proper use, and limitations of respirators and protective clothing. The purpose and a description of the medical surveillance program. The content of the Asbestos standard 29 CFR 1926.1101, including its appendices. The requirements for posting signs and affixing labels and the meaning of the required legends for such signs and labels. 7.7.2 Training for Class I asbestos workers must consist of either 32 hours in order to be accredited at the worker level, or 40 hours in order to be accredited at the contractor/supervisor level and function as a competent person. An annual 8-hour refresher course is required for both the worker and contractor/supervisor level of training. 7.7.3 Training for Class II workers may be the same as for Class I work (asbestos worker or contractor/supervisor) or may be 8 hours of training, including hands-on training, in the specific type of material to be removed. Removal of the following materials falls under the 8-hour class listing: roofing materials, flooring materials, siding materials, ceiling tiles, and transite panels. An annual refresher is required for all workers. 7.7.4 Training for Class III workers is 16 hours with an annual 4-hour refresher course. 7.7.5 Training for class IV asbestos workers includes an initial two-hour asbestos awareness training with an annual refresher. 7.7.6 All Cianbro team members must receive asbestos awareness training prior to their initial assignment and each time they arrive at a new project site which could potentially contain asbestos. This training will consist of a review of Appendix A along with site specific asbestos hazards and will be conducted and documented as part of the jobsite orientation. 7.8 Medical Surveillance and Recordkeeping 7.8.1 Each asbestos subcontractor must comply with the medical surveillance and recordkeeping requirements set forth in 29 CFR 1926.1101. Subcontractor compliance with these requirements can be verified by reviewing their Asbestos Policy and by requiring documentation which will verify compliance. 7.9 State and Local Requirements 7.9.1 State Environmental Agency regulations also govern asbestos abatement activities in each state. In Maine, for example, DEP Chapter 425 regulations apply and set forth requirements for the following; Renovation and demolition inspections by a DEP certified asbestos inspector. Completion of an asbestos abatement plan by an asbestos abatement design consultant. Disclosures submitted to the owner by the asbestos abatement design consultant. Written notification of an asbestos abatement project to the DEP. Licensing and permit requirements for business owners and abatement contractors. Shipment and disposal of asbestos materials. Site management teams need to be comfortable that any asbestos abatement activities for which Cianbro is responsible, are conducted within all Federal, State and local requirements. Policy: 045 Asbestos Operations Rev. 09/20/10 Page 8

8 Budget / Approval Process 8.1 It is the responsibility of each jobsite to procure and provide all materials and PPE required and provide necessary training. 9 Related Documents 9.1 See attachments Policy: 045 Asbestos Operations Rev. 09/20/10 Page 9

9.1 Appendix A Asbestos Awareness Asbestos Awareness 1. Cianbro team members SHALL NOT perform work involving asbestos removal or disposal. 2. Cianbro expects our clients to advise us of the presence of any asbestos in areas we will be performing work. 3. Asbestos awareness training is required for all team members who work in areas that contain, or may contain asbestos. The training will be conducted and documented during jobsite orientations and through our activity planning process. 4. Protective barriers and/or warning signs may need to be installed in work areas to prevent team member exposure. Team members must abide warning signs and labels and avoid areas adjacent to asbestos abatement or storage of abated asbestos. 5. Asbestos Containing Material (ACM) can be friable or non-friable. Friable asbestos is a term used to describe any asbestos containing material that when dry, can be easily crumbled or pulverized to powder by hand. Some common examples of items that may contain friable asbestos are pipe and vessel insulation, gaskets, wallboard, some plasters, and acoustical ceiling tiles. Asbestos is a widely used, mineral-based material that is resistant to heat and corrosive chemicals. Typically, asbestos appears as a whitish, fibrous material that may release fibers that range in texture from coarse to silky; however, airborne fibers that can cause health damage may be too small to see with the naked eye. Non-friable asbestos is not as likely to become airborne because it contains a binder or hardening agent such as cement, asphalt or vinyl. Although not as hazardous, it still needs to be removed, handled and disposed of by qualified individuals. 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 if disturbed during remodeling, repairs or other construction. Burning ACM also creates friable asbestos. Although use of asbestos in these products was banned by 1978, those already in the marketplace remained on the shelves and were used in construction for many years there after. They are still commonly found in buildings and industrial facilities today. 6. When asbestos is crushed it disperses a dusting of microscopic fibers into the air that can remain for very long periods of time. These fibers can be unknowingly inhaled and permanently lodged in lung and other body tissues, yet symptoms might not appear for 20 years or more. Exposure to asbestos can cause asbestosis (scarring of the lungs resulting in loss of lung function that often progresses to disability and to death); mesothelioma (cancer affecting the membranes lining the lungs and abdomen); lung cancer; and cancers of the esophagus, stomach, colon, and rectum. Unfortunately there is no known safe level of exposure, which is why asbestos remains a concern today. 7. If loose asbestos is encountered accidently or due to poor work practices of an adjacent contractor (asbestos abatement or otherwise), team members are required to leave the area immediately and notify you re their supervisor. Rev 03/10 SD1053 Policy: 045 Asbestos Operations Rev. 09/20/10 Page 10