Document LpnwJVazvJx0zegbgDjzNyOEd

6/10/80 AT&T Long Lines Medical Director - Headquarters Medical Directors - Regions Some of you have become involved ir. environmental testing for asbestos. Enclosed are some guidelines for sprayed on asbestos in companyowned and leased buildings to which you nay wish to refer. D.=U Lift 000194 Suct: Occupational Safety and Health Sprayed-on Asbestos in Conpany-ouned and Leased Buildings SR 3G-0A-CIC nrpitw. a>: Strong Recommendation June 3, 1980 dns.iH.aonlira: d: ST? 108, HRD 020, KRD 057, S?r 102 SR 00-06-010 tti no. ochor: AT&T America*' Te ^r':_ i" j T^'egrao-'' Cw-'Si'r 222 Ml A.*v 8asun<; ^ . Z'~t2 . 3nCn? ^ -;y: : AVP - Support Services Copies to Medical Directors, Safety, and Environmental Coordinators, iron.: AVP - Support Services 0 u dncripuon. Provides guidelines required for CSHA cocpliance in company-owned and leased buildings with sprayed-on asbestos. ** Section 29 CFR 1910.1001 of standards issued by the Occupational Health and Safety Administration (0SHA) requires all employers to establish and maintain an effective program for protecting their employees against asbestos exposures which are above acceptable levels. The major areas of concern for the Bell System in this matter are in automotive operations (brakes and clutches) and in buildings (sprayed-on fire protection and insulation). The attached document considers sprayed-on asbestos in company-owned and leased buildings, and is one of a. series of Bell System guidelines intended to satisfy the requirements of : tandards. Previous documents include: SR 79-05-398 "Occupational Safety and Health - Exposure to Airborne Asbestos Fibers - Request for Survey" - surveys all System-owned and leased buildings to determine if sprayed-on asbestos was used. . RL 79-07-254 "AsbesCos Hazards in Leased Buildings" - recommends chat facilities under consideration for lease, containing sprayed-on asbestos, be reviewed before final decision. CL 73-08-05L "Motor Vehicle Maintenance - Protection Against Exposure to Asbestos Fibers" - provides general procedures for protecting employees against asbestos exposure m garages . CL 77-07-02L '"Motor Vehicle Maintenance - Brakes and Clutcr.es provides specific recommendations for protecting employees against asbestos exposure while performing maintenance operations on brakes and clutches. LLA 000195 In addition, an SR will oe issued shortly encicled "Occupational Safety and Health - Exposure to Airborne Asbestos Fibers" which will provide basic information to establish an overall asbestos control program. The results of the survey of approximately 29,000 owned and leased 3el1 Systen buildings (SR 79-05-398) indicates that thereare less than It or 216 (108 owned and 108 leased) buildings which are suspected to have sprayed-on asbestos. However, bulk sample tests necessary to determine if a substance is asbestos were not performed in all cases during the survey. Concurrent with the building survey, Bell Laboratories was requested to perform tests to determine the possible levels of exposure where asbestos was present. The results of these tests may be summarized as follows: If sprayed-on asbestos is undisturbed, airborne levels of asbestos are well below OSHA standards (typical office or work space environment). biring typical work operations which do not require the removal or displacement of the sprayed-on material, exposure levels are below OSHA standards. . Airing any work operations where there is significant disruption of the sprayed-on material, there may be exposures above the OSHA standard (for example, work in crawl spaces or ceilings or removing ceiling panels). . Airing renovations, ripouts and remodeling activities, airborne asbestos levels are generally above OSHA standards. As a result of the above it is recoomended that: 1. Bulk sample tests be performed to confirm the presence or absence of asbestos in each of che 216 buiLdmgs identified in the survey, and any other building which may have asbestos- 2. Warning signs, labels, or other means of control must be provided for employees who must perform work in an area where sprayed-on material may be disturbed. 3. Methods must be developed to minimize or eliminate the possibility of excessive exposure during renovations or removal activities in the affected buildings. The Environmental Protection Agency (EPA) has specific requirements on these activities. U. A disposal procedure must be established for any collected asbestoscontaminated materials. The EPA also has requirements on this activity. LLA 0001% We recotmnend the primary responsibility for implementation of the required program as detailed in the attached instruction will reside with the Building Engineering Group at BOC Headquarters. As such, a coordin ator in this organization oust be identified. In addition, Building Engineering must work closely with appropriate Medical, Safety, Environ mental end Building Operations Force representatives. The Building Operations Force supervisor responsible for effected buildings will ultimately be responsible for the day-to-day procedures chac are re quired. It is strongly recoamended Chat implementation of these guidelines be initiated immediately. The resource impact of this letter on the Bell System is estimated as follows: Capital Signage . Air Sample Test Kit Respirators Total Capital $10,000 10,000 (S500 per kit) 10,000 ($ 10 per cartridge evoe) $30,000 Expense . Bulk Sample Analysis by Outside Laboratories . Air Sample Analysis by Outside Laboratories Total Expense $10,000 ($25 to $50 per sample) 50,000 ($300 to $500 per sample) $60,000 Revenue Change No revenue impact Force Changes No additional manpower required, however, certain Building Engineering, Building Operations, Medical and Safety personnel must include this activity with their other responsibilities. In addition to the above impact, there may be situations where the sprayed-on asbestos must be removed, contained or encapsulated. It is anticipated that chis will occur only in areas which are to be renovaced or remodeled. The cost for these activities (based on current prices) per square foot of floor area renovated is estimated as follows: Removal Encapsulation Containment $6 per sq. ft. $4 per sq. ft . $3 per sq. ft. (for painting) $6 per sq . ft. (for structural enclosing) LLA 000197 The name of the BOC coordinator should be forwarded Co M. J. DeCapua, AT&T, 222 Mount Airy Roid, Basking Ridge, NJ by Sept. 1, 1980. In addition, it is recommended that Che coordinator consult with Mr. DeCapua on (201) 221-4984 so chat maximum benefit can be obtained from Che experience gained by AT&T and BTL efforts to date. / S. R. Coliis Assistant Vice President Support Services LLft 00019S Ac Cac timer, c Guidelines for Sprayed-Oa Asbescos In Company-owned and Leased 3uildjn2s Genera l The following guidelines are to be used in conjunction uicii che general program outlined in an SR to be issued shortly, "Occupacional Health and Safecy - Exposure to Airborne Asbestos Fibers," in complying with CSHA standards perCaining to Bell System-owned and leased buildings which have sprayed-on asbestos used for fire protection and/or heac insulation. OHSA Asbestos Standard 1910.1001 (July 1, 1976) The eight hour time weighted average (TWA) airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer chan 5 micrometers, per cubic centimeter of air. In addicion, no employee shall be exposed at ary time to airborne concentrations of asbestos fibers in excess of 10 fibers, longer chan 5 micrometers, per cubic centimeter of air. Medical surveillance is required if employees are exposed to .1 fibers per cubic centimeter (3 hours TWA) or greater. Confirmation of Asbestos SR-79-05-39S requested that the BOCs perform a comprehensive survey to identify all owned and leased buildings which apparently contain sprayed-on asbestos. A summary of the System results is shown as Appendix A. It was not necessary to confirm the asbescos with a bulk sample tesC as part of the survey, however, a number of companies have performed chis cesting. As part of the steps required for compliance with the asbestos standard, ic will be necessary (in each facility identified as apparently having sprayed-on asbescos) to perform a bulk sample cest for confirmation chat the material is or is not asbestos. If the cesc indicates asbestos, then an ambient air test must also be performed. Such ambienc air tests will determine the level of airborne asbestos in the area on an 8-hr TWA basis. The ambient air tests should be made in areas where Che asbestos exists and is in an undisturbed state, i.e., no one is working on che asbestos. If the material exists throughout the building, several typical locations should be identified and an ambienc air test made in each location. It is extremely important thac che ambienc samples as well as the bulk be analyzed ov qualified laboratories approved bv NIOSH. See SR to be issued shortly, "Occupa:iona 1 Health and Safecy Exposure to Airborne Asbescos Fibers," for a discussion of bulk sample and ambient air sample testing. The objectives of Che bulk sample and amaier. t air tests are two-fold. 1. To establish 1 permanent record wnich indicates tr.ac each comps:"' ha; identified too existence of tne material and recorded tne normal siroorne exposure ievels. Tne o.:'.-. and a:r sample results srould also be for- ; rded to AT&T, r.ea. estate ana Prooerty Mans ge-e.-.t C r a-.. 2 22 Mount A.'.- Road, Basking R: dae , New Jersey 0 7 R 20 . LLA 000199 2. To confirm that ambient levels are not above Che OS HA standard. Numerous STL tests have indicated chat this will be the normaL case. If, however, a situation occurs where ambient levels in an undisturbed environment are above OSHA standards, and this is corroborated with additional testing, then it is necessary Co implement some type of engineering controls. These .controls cay be one of the following: . Enclosure of Che material - this may be achieved with a dropped ceiling. Sealing of the material - this can be achieved by spraying an additional material over Che sprayed-on asbestos. Presently, chere are a number of different types of sealants available for this purpose including latex paints, vinyl or butyl polymers, plaster emulsions, epoxy materials and inorganic silicates. Removal of che material - this activity should be avoided, if at all possible, due to the disturbance of work activity as a result of che extremely high levels of airborne asbestos that are generated in the removal, and the need to replace the material with ocher building products to achieve che original objective of Che asbestos. If it is not possible to avoid removal then Che appropriate procedures outlined below muse be followed. Before any of che above engineering controls are implemented, a case by case feasibility study muse be made and individual situations discussed with Che Real Estace Management Group at AT&T. Follow-up Measurements It is recoaaended that follow-up ambient air cests be performed every five years to assure thac asbestos deterioration has not occurred Co che point where levels are above OSHA standards. Labe 1ing/Identification of Areas with Sprayed-on Asbestos Compliance with Che OSHA standard also requires that either Caution labels be employed Co identify the sprayed-on asbestos material or engineering controls be employed as described above under Objective 2. The label should be approximately 6" x 3" vich red lettering and shall scate Caution This Area Contains Asbestos Materials Avoid Creating Dust Breathing Asbestos May Cause Serious Bodily Harm LLA 000200 Ac lease one label shall be prc31.ner.ely located in each area where exposed sprayed-on asbescos exiscs so thac anyone working in Che srea will be alerted Co che poCencial hazard. For unexposed areas, such as hung ceilings, che label should be locaced in a central concrol poinc so chac Che people who would have che need Co enCer chese areas would be made aware of che asbescos and its location. This area may be the building maintenance office or a similar location. It may also be desirable to provide a wal1-Bounced drawing in che building manager's office illustrating asbestos covered areas in che building. Work Procedures In all buildings idencified as having sprayed-on asbescos every effort should be made to avoid work procedures which resulc in disruption of che asbescos nacerial and che resultant release of fibers inco Che air. Pre liminary data has indicated that for routine work operations which do no: require che removal or displacement of any sprayed-on asbestos, exposure levels are well below chose permitted by the current OSHA standard. in chose cases where some handling of che material is necessary che sprayed-on asbestos should be worked in a -ipiscened state, if possible. If it is not possible to avoid vor* procedures which resulc in a significant disruption of che sprayed-on material Cher, protective eloebing and respiracors must be employed during che work procedures. See SR Co oe issued shortly "Occupational Health and Safety - Exposure to Airborne Asbescos Fibers" for a discussion of protective cloching and che OSHA requirements for respirator protection. Of particular concern are exposures to employees who work within hung ceilings, doing such work operations as installing or removing telephone cables and electrical wiring, or working on building equipment. The above work procedure modification must be achieved through meecings with employees in che building and by posting such a policy in appropriate central work locations in the building. Before engaging in any work procedures which may disturb sprayed-on asbestos, employees must contact the Building Operations Control Center IBOCC), if implemented in chat Company, or the individual in that building who is responsible for implementing these guidelines. In addition to employee accivity, it is also important thac any contractor engaged in work activities which mighc disrupc che asbestos material be informed thac they must comply with these procedures. Remodeling or Renovacion Activices Remodeling or renovation work in areas with sprayed-on asbestos poses che greacest asbescos hazard in bell System buildings ar.d may require .the removal, sealing or enclosure of the asbestos. As such it will be necessary to fully procect all employees by isolating the work area from che resc of che facility, ana monitoring both inside and outside the worn LLA 000201 areas. Workers should wear appropriate protective clothing and respirators, and the area should be cleaned after the renovations with wet methods. Remeasurement of ambient levels should be performed to ascertain that they are below OS HA standards. In contracting remodeling and renovation work, specific guidelines muse be established and included in Che specification for bidding by outside contractors. It is extremely important Co recognise that asbestos removal activities are complex and not routine Co most building contractors. As such the SOCs must be assured that any contractor who will perform this work has experience in asbestos removal. Section 61.22(d) "Demolition and Renovation" of the EPA's National Emission Standard for Asbestos details federal requirements for these activities and is attached as Appendix B. Waste Disposal All asbestos scrap and debris must be collected and disposed of in accordance with EPA requirements. Section 6l.22{j) of Che EPA's National Emission Standard for Asbestos details the federal requirements for asbestos waste disposal and is attached as Appendix C. However, sooe states may have their own laws regarding disposal and Companies are advised to check with Che EPA State Wasce Management Agencies for compliance with local disposal regulations. LLA PNB Wisconsin NJ NY SouChern Ohio NWB SNET Michigan Mountain Southwestern New England C&P Pacific I llinois South Central* Cincinnati Bell of Pa. Indiana Long Lines BTL 195 Broadway BSCTE TOTALS RESULTS OF ASBESTOS SURVEY Owed Tocal W/Asbestos 696 320 383 1001 1302 404 2469 200 483 1868 4458 312 839 1020 240 1284 70 6 74 298 4300 26 19 0 4 8 13 15 3 0 6 1 3 4 4 3 8 9 3 l 0 6 0 2 3 12 0 23,199 108 Leased Tocal W/Asbes 254 1 72 0 223 6 357 26 622 5 231 4 303 0 54 4 317 0 438 5 568 l 347 8 363 8 649 9 195 0 561 0 19 0 325 3 64 0 100 7 2l 41 19 21 6108 108 * Not including Louisiana \JJ\ 000203 ENVIRONMENTAL PROTECTION AGENCIES REQUIREMENTS NATIONAL EMISSION STANDARD FOR ASBESTOS 61.22(d) - "DemoI ition and Renovation1' The requirements of this paragraph shall apply to any owner or operator of a demolition or renovation operation who intends to demolish any institutional, commercial, or industrial building (including apartment buildings having more than four duelling units), structure, facility, installation, or portion thereof which contains any pipe, duct, boiler, tank, reactor, turbine, furnace, or structural member that is covered or coated with friable asbestos materials, except as provided in paragraph (d)(1) of this section; or who intends to renovate any institutional, commercial, or industrial building, structure, facility, installation, or portion thereof where more than 80 meters (ca. 260 feet) of pipe covered or coated with friable asbestos materials are stripped or removed, or more than 15 square meters, (ca. 160 square feet) of friable asbestos materials used to cover or coat any duct, boiler, tank, reactor, turbine, furnace, or structural member are stripped or removed. (1) (i) The owner or operator of a demo 1ition operation is exempted from the requirements of this paragraph: Provided, (A) The amount o: friable asbescos materials in the building or portion thereof to be demolished is less than 80 meters (ca. 260 feet) used on pipes, and less than 15 square mecers (ca. 160 square feet) used on any duct, boiler, tank, reactor, turbine, furnace, or structural member, and (B) the notification requirements of paragraph (d)(L)(Li) are met. (ii) Written notification shall be postmarked or delivered to the Administrator at least 20 days prior to commencement of demolition and shall include the information required by paragraphs (d)(2) of this section, with the exception of the information required by paragraphs (d)(2) (iii), (vi), (vii), (vui), and (ix) of this section, and shall state the measured or estimated amount of friable asbestos materials which is present. Techniques of estimation shall be explained. L3 ER 26372, June 19, 1978 (2) Written notice of intention to demolish or renovate shall be provided to the Administrator by the owner or operator of the demolition or renovation operation. Such notice shall be postmarked or delivered to the Administrator at least 10 days prior to commencement of demolition, or as early as possible prior to commencement of emergency demolition subject to paragraph (d)(6) of this section, and as early as possible prto to commencement of renovation. Such notice shall include cne following information: LLA (i) Name of owner or operator. (ii) Address of owner or operacor. (iii) Description of Che building, structure, facility, or installation to be demolished or renovated, including the size, age, and prior use of che structure, and the approxiaace amount of friable asbestos materials present. 43 FR 26372, June 19, 1978 (iv) Address or location of the building, structure, facility, or installation. (v) Scheduled starting and completion dates of demolition or renova Cion. (vi) Nature of planned demolition or renovation and cethod(s) to be employed. (vii) Procedures to be employed to meet the requirements of this paragraph and paragraph (j) of this section. -4 M - > The name and address or location of the waste disposal site where the friable asbestos waste will be deposited. (ix) Name, title, and authority of the State or local governmental representative who has ordered a demolition which is subject to paragraph (d)(6) of this section. (3) (c) For purposes of determining whether a planned renovating operation constitutes a renovacion within the meaning of this paragraph, the amount of friable asbestos material to be removed or stripped shall be: (A) For planned renovating operations involving individually non-scheduled operations, Che additive amounc of friable asbestos material that can be predicted will be removed or stripped at a source over the maximum period of time for which a prediction can be made. The period shall be not less than 30 days and not longer Chan one year. (3) For each planned renovating operation not covered by paragraph (d )(3) (i) (A), the total amount of friable asbestos material chat can be predicted will be removed or stripped at a source. (Li) For purposes of determining whether an emergency renovating operation constitutes a renovacion within the meaning of this paragraph, the amount of friable asbestos material to be removed or stripped shall be Che total amount of friable asbestos material that will be removed or stripped as a result of the sudden, unexpected event that necessitated the renovacion. 4 LLA 000205 (i) The following procedures shell be used Co prevenc emissions of particulate asbestos material to outside air: (i) Friable asbestos materials, used on any pipe, duct, boiler, tank, reactor, turbine, furnace, or structural member, shall be removed from any building, structure, facility or installation subject to this paragraph. Such removal shall occur before wrecking or dismantling of any portion of such building, structure, facility, or installation that would break up the friable asbestos materials and before wrecking or dismantling of any ocher portion of such building, structure, facility, or in stallation, that would preclude access Co such materials for subsequent removal. Removal of friable asbestos materials used on any pipe, duct, or structural member which are encased in concrete or other similar structural material is not required prior to demolition, but such materials shall be adequately wetted whenever exposed during demolition. (ii) Friable asbestos materials used on pipes, ducts, boilers, canks , reactors, turbines, furnaces, or structural members shall be adequately wetted during stripping except as provided in paragraphs (d)(4)(iv), (d)(4)(vi), or (d)(vii) of this section. (iii) Pipes, ducts, boilers, canks, reactors, turbines, furnaces, or structural members chat are covered or coated with triable asbestos materials oay be taken out of any building, structure, facility, or installation subject to this paragraph as units or in sections provided the friable asbestos materials exposed during cutting or disjoining are adequately wetted during the cutting or disjoining operation. Such units shall not be dropped or thrown to the ground, but shall be carefully lowered to ground level. (iv) The stripping of friable asbestos materials used on any pipe, duct, boiler, tank, reactor, turbine, furnace, or structural member that has been removed as a unit or in sections as provided in paragraph (d)(4)(iii) of this section shall be performed in accordance with paragraph (d)(4)(ii) of this section. Rather than comply with the wetting requirement, a local exhaust ventilation and coll'ection system may be used to prevenc emissions to the outside air. Such local exhaust ventilation systems shall be designed and operated to capcure the asbestos particulate matter produced by the stripping of friable asbestos materials. There shall be no visible emissions to Che outside air from such local exhaust ventilation and collection systems except as provided in paragraph (f) of this section. 43FR 26372, June 19, 1978 lla qo (v) All friable asbestos materials chat have been removed or stripped shall be adequately vetced to ensure chat such materials remain wet during all remaining stages of demolition or renovacion and related handling operations. Such materials shall not be dropped or thrown to the ground or a lower floor. Such materials that have been removed or stripped more chan 50 feet above ground level, except those materials removed as units or in sections, shall be transported Co the ground via dust-tight chutes or containers. (vi) Except as specified below, the wetting requirements of this paragraph are suspended when the temperature at the point of wetting is below 0C (32F). When friable asbescos materials are not wetted due to freezing temperatures, such materials on pipes, ducts, boilers, tanks, reactors, turbines, furnaces, or structural members shall, to the maximum extent possible, be removed as units or in sections prior Co wrecking. In no case shall Che requirements of paragraphs (d)(4)(iv) or (d)(i)(v) be suspended due to freezing temperatures. (vii) For renovacion operations, local exhaust ventilation and collection systems may be used instead of wetting as specified in paragraph (d)(4)(ii), to prevent emissions of particulate asbescos material to outside air when damage co equipment resulting from the wetting would be unavoidable. Upon request and supply of adequace information, Che Administrator will determine whether damage to equipment resulting from wetting to comply wich the provisions of this paragraph would be unavoidable. Such Local exhaust vencilacion systems shall be designed and operated to capture the asbestos parciculace matter produced by Che stripping and removal of friable asbestos material. There shalL be no visible emissions to the outside air from such local exhaust ventilation and collection systems, except as provided in paragraph (f) of this section. (5) Sources subject to this paragraph are exempt from the requirements of 61.05(a), 61.07, and 61.09. (6) The demolition of a building, structure, facility, or installation, pursuant to an order of an authorized representative of a State or local governmental agency, issued because that building is structurally unsound and in danger of imminent collapse is exempt from all but the following requirements of paragraph (d) of this section: (i) The notification requirements specified by paragraph (d)(2) of this sect ion; (ii) The requirements ar. stripping of friable asbestos materials fro: previously removed units or sections as specified in paragraph (d)( t)( ivj of this section, LLA 000207 ENVIRONMENTAL PROTECTION AGENCY REQUIREMENTS NATIONAL EMISSIONS STANDARD FOR ASBESTOS 61.22(j) WASTE OISPOSAL Waste disposal for manufacturing, fabricating, demolition, renovation and spraying operations: The owner or operator of any source covered under the provisions of paragraphs (c), Cd), (e), or (h) of this section shall meet the following standards: (1) There shall be no visible emissions to the outside air except as provided in paragraph (j)(3) of this section, during the collection; processing, including incineration; packaging; transporting; or deposition of any asbestos-concaining waste material which is generated by such source. (2) All asbestos-containing waste material shall be deposited at waste disposal sites which are operated in accordance with the provisions of 61.25. (3) Rather than meet the requirement of paragraph (j)(l) of this section, an owner or operator may elect to use either of the disposal methods specified under (j)(3)(i) and (ii) of this seccion, or an alternative disposal method which has received prior approval by the Administrator: (i) Treatment of abestos-cont.iining waste material with water: (A) Control device asbestos waste shall be thoroughly mixed with water into a slurry and other asbestos-containing waste material shall be adequately wetted. There shall be no visible emissions to the outside air from the collection, mixing and wetting operations, except as provided in paragraph (:) of this section. (B) After wetting, all asbestos-containing waste material shall be sealed into leak-tight containers while wet, and such containers shall be deposited at waste disposal sites which are operated ir. accordance with the provisions of 61.25. [\J\ 000208 (C) The container* specified under paragraph (j)(3)(i)(B) of Chia aection shall be labeled vich a warning label that states: Caution Contain* Asbestos Avoid Opening or Breaking Container Breathing Asbestos is Hasardous to Your Health Alternatively, warning labels specified by Occupational Safety and Health Standards of the Department of Labor, Occupational Safety and Health Administration (OSHA} under 29 CFR 1910-93a(g)(2)(ii) aay be used. (ii) Processing of asbestos-containing waste material into non-friable forms: (A) All asbestos-containing waste material shall be formed into non-friable pellets or other shapes and deposited at waste disposal sites which are operated in accordance with the provisions of 61.25. (3) There shall be no visible emissions to the outside air from the collection and processing of asbestos-containing waste material, except as specified in paragraph (f) of this sect ion. (4) For the purpose of this paragraph (j), the term all asbestos-containing waste material as applied to demolition and renovation operations covered by paragraph (d) of this section includes only friable asbestos waste and control device asbestos waste. LLA 000209