DISTRIBUTION: A, D, G, J

NEXT REVIEW DATE: April, 1996

POSITIONS RESPONSIBLE FOR REVIEW: Director, Work Management, and

Director, Environmental Health and Safety

 

PURPOSE: To document FMS policy and procedures for handling lead, including lead-based paint (LBP), and asbestos-containing materials (ACM) discovered or known to exist in campus facilities.

BACKGROUND: Although similar in the history and timing of the discovery of their health risks, in their subsequent discontinuation in construction, in their common medium of exposure (airborne), and in the methods of worker and public protection from exposure, lead and asbestos receive different treatments in the handling of their abatement, when either anticipated or identified in a work location.

Lead is an element common to several construction trades--roofing, painting, plumbing, and electrical; even as its use or installation was once common in those fields, so too is its removal or abatement a common assignment of those same trades in construction today. By contrast, asbestos is a "new" material belonging historically to none of the trades as a key aspect of their work; its abatement is seen as a highly specialized undertaking, regulated in detail, and posing risks that, even today, classic trade apprenticeships do not address.

Further, although the effect of acute or chronic exposure to lead can be potent, albeit quickly detectable, systemic poisoning, because the body can in time purge itself of lead, especially of small, discontinuous exposures, and especially in adults, it presents a relatively low level of risk; by contrast, the effects of asbestos, even in small exposures, are permanent, irreversible, and unlikely to become manifest for two decades or more.

Finally, even professional participants in the construction field, architects in particular, routinely refuse contractual involvement in the problems facing their clients who own facilities with ACMs; by contrast, architects are relatively confident of writing abatement specifications for lead that might be discovered in a renovation site.

For these reasons, lead and asbestos, even with similar construction use histories, exposure media, and health risks, receive very different treatments in practice during construction and renovation projects.

 

POLICY: FMS policy is to operate in accordance with all Environmental Protection Agency, Occupational Safety and Health Act, and Pennsylvania Department of Labor and Industry guidelines to ensure a safe environment, both during construction work and during subsequent use by the occupants. Only staff members or contractors who are properly trained, licensed and supervised, and medically examined and approved, may work in asbestos contaminated areas.

PROCEDURES:

1. Project managers, estimators and renovations/maintenance superintendents or their designees must coordinate an asbestos survey with the Office of Environmental Health and Safety (OEHS) prior to planned renovation work to determine if there are asbestos containing materials (ACM) within the scope of work. If ACM exist, appropriate methods of removal, encapsulation and/or other protective measures will be recommended by the OEHS asbestos management staff. In addition, the OEHS Project Monitor must be contacted prior to commencement of work to coordinate work site inspections and air testing. Should abatement of some or all ACM be necessary, the OEHS Project Designer shall develop technical specifications for such abatement.

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2. When routine maintenance or repair work is being performed, the OEHS should be consulted prior to disturbing insulation on piping, boilers, equipment or other surfaces, as well as other suspect building materials (for example, wall and ceiling plaster, drywall etc.) for possible asbestos.

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3. Removal or drilling of floor tiles, sheet floor covering, wall board, plaster or other suspect ACM will not be performed without consulting with the OEHS.

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4. Consult with the OEHS on air quality where employees routinely work in an asbestos environment. After assessment of air and environmental quality, the safety measures and procedures recommended by the OEHS will be followed. Only personnel from the asbestos task force or from the removal crew will be allowed to work in these areas, as per the OEHS recommendations.

5. A required 20-day advance notification shall be submitted to the State Department of Labor and Industry by OEHS prior to the Facilities Management asbestos abatement crew starting an asbestos abatement project greater than 10 lineal or square feet. Notification to the OEHS will be made at least five working days before this. When abatement is performed by an outside contractor, the Department of Labor and Industry notification will be performed by the contractors.

The only projects that do not require a 20 day advance notification are those that qualify as emergencies and those where a 20 day delay would represent an "unreasonable financial burden". Emergencies include, but are not limited to (1) leaking or ruptured pipes, (2) accidentally damaged or fallen asbestos that could expose non-asbestos workers or the public, and (3) unplanned mechanical outages or repairs essential to the process that requires asbestos removal and could only be removed safely during the mechanical outage. Lack of planning or inspection for asbestos before commencement of general renovation projects does not constitute an emergency. Should the 20 day advance notice represent an unreasonable financial burden, the details of this situation shall be described in a memo to the OEHS and will be submitted with the Department of Labor and Industry's notification.

Notification to the OEHS of all such emergency projects shall be made as soon as plans are made to proceed with the project. The OEHS shall then submit the Department of Labor & Industry's notification.

RESPONSIBILITIES:

1. The OEHS will maintain a listing of areas and corresponding floor plans where samples of suspected ACM have been taken and analyzed. The project or cost center manager will consult with the OEHS asbestos management staff prior to the performance of renovation and/or maintenance work.

2. The project or cost center manager will coordinate the abatement project notification with the OEHS as outlined under Procedures, paragraph 5. The project supervisor will coordinate all ACM repair activities with the OEHS prior to repairs being performed.

3. The Facilities Management safety coordinator will arrange basic indoctrination and periodic refresher training programs as well as respirator fit testing through the OEHS for the asbestos task force. The specialty trades superintendent will arrange all asbestos work, supervisory, and annual update training with state-approved training agencies for the asbestos abatement crew.

4. The safety officer will maintain annual medical examination and recommendation forms, training records and a current list of asbestos task force personnel and asbestos removal crew members, along with dates of all such activities described above.

5. Respirator qualitative fit test records are maintained by the OEHS respirator program administrator. Respirator qualification printouts are jointly maintained through the cooperation of Facilities Management, Employee Health and OEHS.

6. The superintendent of the asbestos abatement crew will ensure that all members have current licenses and have signed the reports of personal air monitoring for all asbestos abatement projects. The superintendent shall maintain copies of all such air testing reports for future reference.

7. Supervisors of the building trades, service crew, HVAC, and renovations will be responsible for maintaining an adequate number of personnel assigned for work on the asbestos task force in asbestos contaminated areas.

 

REFERENCE(S):

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CANCELLATION(S): None

SIGNATURES:

 

Edward A. Guida, PE, CIH Larry Young

Director, Environmental Health & Safety Director, Work Management

ATTACHMENT(S):