Office or Environmental Health and Safety

Asbestos Management Policy

Asbestos is recognized as a significant health hazard. Activities involving potential exposure to asbestos containing materials is regulated by the Occupational Safety and Health Administration (OSHA), the Environmental Protection Agency (EPA), the Connecticut Department of Environmental Protection and the Connecticut Department of Public Health.

This policy document has been developed to minimize potential exposure to airborne asbestos by all members of the college community, and to provide regulatory guidance for college employees and contractors of Connecticut College.

RESPONSIBILITIES

Director of Environmental Health and Safety (EH&S):

The Director of EH&S is a licensed Asbestos Inspector, and is responsible for the overall Asbestos Management Program at Connecticut College.

Provides consultative and technical assistance to campus groups involved in asbestos related activities.
Collects and submits asbestos samples to a qualified laboratory for identification.
Provides quality control/quality assurance for the Asbestos Management Program through monitoring of the different program elements.
Serves as liaison with regulatory agencies.
Notifies the Occupational Health Manager of new employees requiring Asbestos related physical examinations.
Conducts the Respiratory Protection Program.
Conduct Asbestos Awareness training for all affected employees. (Custodial, Mechanical Trades, Utilities, and Building Trades.)
Conducts periodic inspections of locations with "Asbestos Containing Materials". (ACM) and/or "Presumed Asbestos Containing Materials" (PACM).
Ensures contractors comply with Federal, State and local regulations regarding the removal and disposal of asbestos containing materials.
Serves as the central repository for all asbestos related documents.

Occupational Health Manager:

Maintains employee health information pertaining to asbestos related physical examinations and respiratory protection evaluations.
Coordinates all medical related aspects of this program.
Serves as liaison with off campus health care providers.

Physical Plant Administration: (Director of Physical Plant Services, Manager of Mechanical Trades, Supervisor of Building Trades, Supervisor of Custodial Services, Supervisor of Grounds, Engineering Systems Manager, and Manager of Planning Design and Construction)

Acts as liaison between his area of responsibility and the Director of EH&S, and is responsible for all asbestos activities in his/her division including: identification of projects involving asbestos, and informing contractors of the presence of asbestos within their work areas.
Ensures that Physical Plant employees whose job activities bring them into contact with ACM or presumed ACM, adhere to proper asbestos management procedures.
Ensures that affected Physical Plant employees receive appropriate training, and participate in medical surveillance and respiratory protection programs.
During construction, maintenance or renovation projects involving asbestos abatement, ensures that the abatement contractor is fully qualified and licensed.
Ensures that contractors have made the proper notifications to the Connecticut Department of Public Health.
Forward all asbestos related documents to the Director of EH&S for filing.

Asbestos Abatement Contractor(s):

Only experienced/certified asbestos abatement contractors shall be utilized by Connecticut College.

Abatement Contract specifications shall be based on OSHA'S "Work practices and engineering controls for Class I Asbestos Operations" - 29 CFR 1926.1101 App F.

Asbestos abatement contractors are required to maintain records associated with all abatement projects performed. A copy of all appropriate records will be provided to the Director of EH&S.
Asbestos abatement must be performed in accordance with specific work practices. These work practices are designed to limit potential exposure to asbestos for those performing asbestos abatement as well as the general public.
The determination that an asbestos abatement project is completed satisfactorily is made following an inspection by a licensed project monitor. Post abatement air sampling is also required prior to the facility being reoccupied.
Project monitoring shall be performed by a qualified asbestos supervisor (third party contractor). Monitoring shall include, but is not limited to: daily inspection, air sampling outside containment, and clearance air sampling as specified in the abatement contract.

PROGRAM ELEMENTS

Training Requirements:

All Custodial, Mechanical Trades, Building Trade and Power House employees will receive "Asbestos Awareness" training on an annual basis.

In addition, selected Tradesmen will receive 16 hours of asbestos "Operations and Maintenance" training. These employees will then be licensed to perform minor asbestos maintenance and repairs involving less than 3 linear feet, or 3 square feet of ACM.

Respiratory Protection:

Use of respiratory protection is required for all work with "friable" ACM, or in asbestos contaminated areas. The Director of EH&S coordinates a respirator program in accordance with 40 CFR 763.120. This program includes:

Respirator fit testing
Training on the use, care and limitations of respirators
Medical Surveillance
Annual review with employees in the program.

Medical Surveillance Program:

An initial, then annual medical examination is performed for all employees whose job activities require work with friable asbestos, or in asbestos contaminated areas in accordance with federal requirements (40 CFR 763.120). A concurrent respirator use evaluation will be made during that examination.

Notifications:

The Director or EH&S will be notified prior to any asbestos abatement or maintenance procedures. Additionally:

The Connecticut Department of Public Health (DPH) must be notified of asbestos abatement involving more than ten (10) linear feet or more than twenty-five (25) square feet of asbestos containing material. This notification may be made by the contractor, but a copy of the notification form must be forwarded to the Director of EH&S.Notification of asbestos abatement must be made utilizing the DPH prescribed form and be accompanied by the notification fee.
The notification form must be postmarked or hand delivered at least ten (10) days before the start of asbestos abatement, or in the case of an emergency asbestos abatement, within one working day of the start of the asbestos abatement.
Emergency project notification should be made to the proper regulatory authority and EH&S as soon as possible but no longer than 48 hours after commencement.

In-house Activity Restrictions:

Only those employees who have received the 16 hour "O&M" training, shall engage in incidental asbestos removal and repair.

Only activities such as small cleanups of disturbed friable material, small removals of damaged asbestos containing material or incidental asbestos removal involving less than 3 square feet, or 3 linear feet of ACM where the glove-bag technique may be employed is permitted by Connecticut College employees.

All O&M activities will be performed using wet/dustless methods, or in a glovebag.

Large asbestos removals shall be performed by experienced/certified asbestos abatement contractors, as noted above.

Note: The Connecticut Department of Public Health clarified that certain ACM removal activities involving non-friable ACM, are not considered to be asbestos abatement (Unscrewing transite panels, removal of asbestos containing fire doors, etc.). Therefore these activities are not regulated activities under Section 19a -332 of the Connecticut General Statutes, as long as the material:

Is undamaged and non-friable, such as unbroken floor tiles, fire doors and transite panels. (A case by case evaluation must be made for "slightly" broken floor tiles.)
The ACM is removed intact and without breakage or other disturbance.
The material is removed without the creation of a visible residue.
The ACM is not subject to sanding, cutting, grinding or abrading during the removal or collection process.
The material does not become a Regulated Asbestos Containing Material as defined by NESHAPS (40 CFR Part 61, Subpart M).

Connecticut Division of Environmental Health Circular Letter #2003-10

Custodial and Maintenance Precautions and Procedures:

Cutting, sawing, drilling, sanding or otherwise disturbing asbestos containing material (ACM), or presumed asbestos containing material (PACM) is prohibited.
Sanding of asbestos-containing flooring materials are prohibited.
Never dry strip ACM Flooring - Always use wet methods. When stripping, only use low abrasion pads, at speeds lower than 300 RPM. Never buff or burnish ACM flooring, without at least 3 coats of floor finish in place.

Asbestos Spill Clean-up Procedures:

If damaged ACM or PACM is discovered, immediate action to prevent spread of the spilled material should be taken:

Prevent the spread of the spilled material by keeping people from walking through the area by roping off the area and/or posting signs.

Secure fans, A/C units, and ventilation.

Initiate clean up procedures.
When cleaning small ACM spills, avoid stirring up dust. Never use brooms or brushes, as this will disturb the tiny asbestos fibers, causing them to become airborne and easily inhaled.
Always use wet methods. Thoroughly spray the spilled material with a soapy water solution, prior to commencing the clean up. Clean up the spilled asbestos by carefully wiping the wet material. The only approved vacuum cleaner for asbestos is one equipped with a high-efficiency particulate (HEPA) filter.
Never use compressed air to remove ACM dust.
Properly dispose of waste materials:
- The ACM itself.
- Contaminated cleaning supplies.
- Gloves.
- All other materials used in the clean up.
- Dispose of waste into a polyethylene “Asbestos” bag. The asbestos bag should be taken to the service building, where it will be stored in the HAZWASTE Storage Trailer,
  pending proper disposal. The Director of EH&S will provide the bag.

Inspections:

There are two separate inspection components to the Connecticut College Asbestos Management Program:

An annual inspection of known or suspected asbestos containing materials located in all campus buildings, except Holmes hall.
Asbestos management under AHERA, at Holmes Hall.( See below.)

40 CFR 763, Subpart E is the U.S. EPA's Asbestos Hazard Emergency Response Act. AHERA became law in 1989, and covers asbestos management and regulation in public and private schools grades K through 12. The Human Development/Children's Program in Holmes Hall meets the definition of a K-12 school. AHERA requirements include:

An asbestos management plan must be developed, and a copy maintained in the school's main office. (At Connecticut College, a duplicate copy is maintained by the Director of Environmental Health and Safety)
A comprehensive reinspection and Management Plan update is required every three years. An inspection report listing the location and results of samples taken to confirm suspected ACM will be filed with the Management Plan.
Parents, teachers and employees be notified in writing of the whereabouts and availability of the management plan on an annual basis.
Warning labels must be affixed (or in close proximity) to known or suspected ACM.
An asbestos surveillance inspection is required every six months. Areas of damage or wear will be immediately corrected.

Record Keeping:

Physical Plant supervisors should forward a copy of the contract and contractor's license to the Director of EH&S prior to commencement of work.

The original copy of all asbestos abatement documents will be forwarded to the Director of EH&S for filing.

For comments or questions, contact
Steve Langlois, Director of Environmental Health and Safety, (860) 439-2252

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