21.2 Asbestos Material Building Surveys
21.3 Asbestos Abatement Contractors
21.4 University In House Trained Abatement Perrsonel
21.13 ACM Flooring, Housekeeping, and Disposal
21.2 Asbestos Material Building Surveys #
An asbestos survey will be conducted prior to any renovation of any building, regardless of the date of construction. Representative samples are taken of every suspect material, which are analyzed at an independent laboratory. All surveys are conducted according to the requirements set forth in the MIOSHA Asbestos Standards for Construction. Any building material” not made of metal, glass, ceramic, or wood must be presumed to be asbestos containing and handled accordingly. A scope of asbestos work will be developed for each project that outlines the materials present as well as the abatement techniques to be utilized. Asbestos survey information is available on the EHS website. Contact EHS to report any accidental disturbances of asbestos or to have any suspect materials tested.
21.3 Asbestos Abatement Contractors #
The majority of renovation projects involving asbestos containing materials are managed by AEC. An asbestos abatement contractor is usually retained for abatement either by direct contract or as a subcontractor to a general contractor.
All asbestos abatement contractors must be prequalified to bid on University projects. Prequalification of asbestos contractors is conducted through AEC.
All contractors are required to follow “Section 028213 – Asbestos Remediation” of the University Master Specification, which is included in the bid documents. The specification will be modified for each project according to the scope of the abatement work to be completed.
21.4 University In House Trained Abatement Personnel #
Renovation and maintenance projects may also be conducted by University in-house trained personnel. Several groups within U-M-Facilities & Operations can conduct abatement activities for these projects. There are also other University Departments that have been trained to conduct routine maintenance activities within their respective areas as well.
All workers are trained and accredited as required by the Asbestos Standards for Construction and the State of Michigan Asbestos Worker Accreditation Act.
21.5 Air Monitoring #
EHS hires independent consultants to conduct asbestos air monitoring during ACM abatement projects conducted by asbestos abatement contractors as well as University personnel. These consultants typically conduct personal, area, and final clearance monitoring to ensure that airborne fiber concentrations are below established standards.
The MIOSHA Permissible Exposure Limit (PEL) for employee exposures to airborne asbestos is 0.1 fibers per cubic centimeter of air (f/cc) as an 8-hour time weighted average (TWA). MIOSHA has also established an Excursion Limit (EL) of 1.0 f/cc for a 30-minute sample.
The State of Michigan post abatement clearance level of 0.05 f/cc is required for any project involving more than 10 linear or 15 square feet or more of friable material that is performed within a negative pressure enclosure. The University strives to ensure that the clearance levels are below the EPA recommended level of 0.01 f/cc.
University employees’ personal exposure records are maintained in a database at EHS. The exposures are categorized by type of abatement to serve as a negative exposure assessment (NEA) when applicable, and as required by the MIOSHA standards. A negative exposure assessment is job specific and for workplace conditions, type of materials, control methods, work practices, and environmental conditions that most closely resemble those of the activity to be conducted. The NEA can be used to show that levels for a given job will be below the PEL and EL, so that lower levels of respiratory protection can be used.
21.6 Notification Procedures #
Occupant Notification #
Every effort is made to notify individuals who work in or adjacent to areas where asbestos activities will take place prior to work beginning. The notification includes the presence, location, and quantity of ACM at the site and can be verbal or written. EHS accomplishes this task by sending a written notice to the building contact(s) for the area prior to abatement activities beginning. The building contacts are then expected to convey the information to possible affected persons.
This notice is also sent to the construction project manager who is instructed to inform other employers of employees, i.e. other contractors, who may be working in the area.
State of Michigan Notification #
Asbestos abatement contractors are required to submit notification forms to the Michigan Department of Labor and Economic Opportunity (LEO), for all abatement of regulated asbestos materials exceeding 10 linear feet or 15 square feet.
Asbestos abatement contractors are also required to submit notification to the Michigan Department of Environment, Great Lakes and Energy (EGLE) for abatement of regulated asbestos materials exceeding 260 linear feet or 160 square feet.
For projects conducted by University in-house personnel, notifications to the State of Michigan are required to be submitted to EGLE only, if their jobs are above the 260 LF/160 SF lower limits.
Notifications to the State of Michigan must be filed 10 days (calendar days for LEO, working days for EGLE) prior to the start of any asbestos abatement project. Copies of all notifications are maintained at EHS and should be posted at the job site for the duration of the project. Any changes to the notification must be approved by the State of Michigan.
21.7 Regulated Areas #
All Class I – III work must be conducted within a regulated area. A regulated area must have the following:
- Must be demarcated in a manner to restrict persons from entering and protect from exposure to airborne asbestos.
- Must have signs posted with the following information:
DANGER
ASBESTOS
MAY CAUSE CANCER
CAUSES DAMAGE TO LUNGS
AUTHORIZED PERSONNEL ONLY
and
WEAR RESPIRATORY PROTECTION AND
PROTECTIVE CLOTHING IN THIS AREA
(If required for the type of work.)
- Must require the use of respirators, if required, prior to entry.
- Must not allow employees to eat, drink, smoke, chew tobacco or gum, or apply cosmetics.
- Must be supervised by a competent person.
Under no circumstances is a University employee that has not been trained as an asbestos worker allowed to enter a regulated area. Special provisions will be made by EHS for emergency personnel depending on the situation.
21.8 Methods of Abatement #
All asbestos abatement contractors and University in-house employees must follow all requirements for work practices as outlined in “Section 028213 – Asbestos Remediation of the University Master Specification”.
21.9 Respiratory Protection #
Abatement Contractors are responsible for their respiratory protection program and issuance of employee respirators. University employees will be issued respirators by the EHS department, as required. All employees must be medically cleared for respirator use prior to issuance. (Refer to the Respiratory Protection program.)
Respirators must be worn when conducting any of the following abatement activities:
- All Class I activities;
- All Class II activities where ACM is not intact;
- All Class II and III activities where wet methods are not used;
- All Class II and III activities that do not have a negative exposure assessment;
- All Class III work involving thermal systems insulation or surfacing materials;
- All work where employees are exposed above the PEL or EL;
- In emergencies.
Respiratory protection that may be issued for asbestos activities includes the following: half-face or full-face tight-fitting air-purifying respirators with HEPA cartridges, or Powered Air-purifying respirators (PAPR) with a HEPA filter. All negative pressure respirators will be quantitatively fit tested at EHS and all mandatory users will be required to be fit tested annually.
21.10 Protective Clothing #
University employees conducting asbestos abatement activities will be supplied with protective clothing consisting of disposable material suits. The suits are required to be worn during Class I operations involving greater than 25 linear feet or 10 square feet, or any operation without a negative exposure assessment, or any operation where exposures will exceed the PEL or EL.
Suits should be routinely inspected for rips or tears while working. Damaged suits should be mended or immediately replaced. All contaminated suits should be disposed of as asbestos contaminated waste.
21.11 Hygiene Facilities #
Decontamination areas must be established for Class I work that is greater than 25 linear or 10 square feet of thermal system insulation or surfacing materials. It must be set up adjacent and connected to the regulated area. All employees must exit and enter through the decontamination area that must consist of an equipment room, shower area, and clean room, in series.
Decontamination is also required for Class I work involving less than 25 linear or 10 square feet, or Class II and III work where exposures exceed the PEL or EL, or where there is no Negative Exposure Assessment.
An equipment area must be established adjacent to the regulated area for the decontamination of employees and equipment. It must consist of an impermeable dropcloth on the floor surface. Work clothes must be HEPA vacuumed before removal, all equipment must also be cleaned prior to removal and employees must enter and exit through the equipment area from the regulated area.
21.12 Training Requirements #
To avoid potential exposure, and in accordance with regulations, only trained and qualified individuals may disturb ACM. Contact EHS for training, if employees fall into one of these groups or are otherwise likely to disturb ACM.
Class I and II Training #
Required training for activities that involve the removal of asbestos containing materials which include, but are not limited to the following: thermal systems insulation, surfacing materials, wall board, floor tile and sheeting, ceiling tile, roofing materials, and siding. Training is 32 hours for worker level and 40 hours for competent person level.
If individuals are to be trained in Class II operations only, the training will consist of a minimum of 8 hours with hands-on training for the type of material that will be removed. Annual refreshers are required for both classes.
Class III Training #
Required training for activities that involve the disturbance of thermal system insulation or surfacing materials which can fit into only one 60” x 60” glovebag for the purpose of conducting repair or maintenance activities only. Training is 16 hours with a 4-hour refresher annually.
Class IV Training #
Class IV training is required for all maintenance and custodial staff that work in buildings that have asbestos containing materials. Initial training is 2 hours with refreshers required annually.
21.13 ACM Flooring, Housekeeping, and Disposal #
All asbestos-containing flooring materials must be maintained in the following manner:
- Sanding of ACM flooring material is prohibited.
- Stripping of finishes from ACM flooring should be done using low abrasion pads at speeds lower than 300 rpm and wet methods.
- Burnishing or dry buffing of ACM flooring should only be done on flooring that has sufficient finish so that the pad cannot directly contact the flooring material.
All asbestos waste and debris must be promptly cleaned up by properly trained workers and disposed of in the proper manner. Only HEPA filtered vacuums may be used when vacuuming asbestos materials. All asbestos waste needs to be disposed of in an Asbestos-accepting Type II landfill. Refer to the “Section 028213 – Asbestos Remediation of the University Master Specification” for specific waste handling procedures for each type of material.
Abatement contractors are required to arrange for disposal at a proper landfill location and supply EHS with the final disposition records upon receipt. University In-house employees must deliver ACM waste to the asbestos dumpster located at EHS’s North Campus Transfer Facility at 1655 Dean Road. A waste shipment record must be turned in to the front desk at the North Campus Transfer Facility before waste is deposited into the dumpster.
21.14 Medical Surveillance #
EHS maintains a Medical Surveillance Program in conjunction with Michigan Medicine Occupational Health Services. All employees who engage in Class I, II, or III work or are exposed at or above the permissible exposure limit for a combined 30 days or more per year will be included in the medical surveillance program for asbestos exposure. Employees otherwise required by this standard to wear a negative pressure respirator, must be physically able to perform the work and use the equipment. This determination shall be made under the supervision of a physician.
EHS also offers the same medical surveillance examination to employees with significant past asbestos exposure at the University. Involvement is voluntary and is aimed at those individuals who worked with asbestos containing materials routinely, prior to public knowledge of the health effects of asbestos exposure or regulations governing disturbance of ACM. Contact EHS at 647-1143 if interested in being included for past exposure or indicate on medical surveillance request form.
Medical surveillance is required upon assignment to a job involving asbestos exposure as indicated previously and annually thereafter. Medical surveillance will be conducted annually in accordance with the University Protocol for Asbestos Medical Surveillance.
The evaluation can be obtained by indicating that an employee is an asbestos worker on the Medical Surveillance Request Form. The form can be requested from EHS by calling 615-2140 or accessed from the EHS website. The completed form will be evaluated by EHS, and the employee will be contacted directly by the clinic to schedule an appointment.
21.15 Recordkeeping #
All data and records for asbestos projects are maintained at EHS. These data will be maintained for as long as needed. Any information regarding abatement projects will be maintained for the duration of ownership of the building.
All records regarding employee exposures are maintained at EHS offices. These records must be maintained for 30 years.
Medical surveillance information will be maintained by the University’s health care provider. The physician’s written opinion will be maintained in an employee file at EHS. All employee related information will be maintained for the duration of employment plus 30 years.
Training records will be maintained at EHS offices for 1 year past the last date of employment.
