Document NG2m9GDLNpNLmE2M0Bm779OM8

Guidance Manual______ _______ Asbestos Operations & Maintenance Work Practices September 1992 The National Institute of Building Sciences (NIBS) is a non-govemmenial, non-profit organization, authorized by Congress to encourage a more rational building regulatory environment and to accelerate the introduction of existing and new technology into the building process. This document was prepared with the support of U.S. Environmental Protection Agency Cooperative Agreement No. CX-817924-01-0 and U.S. General Services Administration No. GS11P91EGD0113. Individual copies or bulk rate orders of this report are available from the National Institute of Building Sciences. For pricing information contact: The National Institute of Building Sciences Publications Department 1201 L Street, N.W., Suite 400 Washington, D.C. 200054014 202/289-7800 FAX 202-289-1092 This report can also be ordered using VISA or Master Card by calling NIBS with the following information: the card account number, the expiration date, the name as it appears on the card. Copyright >. 1992 by the National Institute of Building Sciences All rights reserved. No part of this document may be reproduced or utilized in any form or by any means, by any mechanical, photographic, or electronic process, or in the form of a phonographic or tape recording nor may it be stored in a retrieval system, transmitted, or otherwise copied for public or private use, without written permission from the National Institute of Building Sciences. However, copying relevant portions of this document solely for the purpose of developing and implementing specific operations and maintenance programs, procedures, or work practices for a specific building is permitted. Copyingjill or portions of this document for resale or redistribution is strictly prohibited. NIBS Document Number - 5076-7 'rnina-iM^v-vr-r n- 4s. DISCLAIMER The Guidance Manual: Asbestos Operations & Maintenance Work Practices was developed in response to a pressing national need for guidance on managing in-place asbestos. The Guidance Manual was drafted by a qualified independent contractor, and went through several iterations of review, modification, and refinement by a National Institute of Building Sciences (NIBS), project committee composed of representatives from a broad cross section of knowledgeable professionals from the building and environmental communities. During the review process and the subsequent ballot approval process the project committee followed consensus rules set forth in the Rules and Procedures of the NIBS Consultative Council. The National Institute of Building Sciences, the members of the NIBS Project Committee, the project contractor, the funding agencies, and their employees or representatives make no warranty, guarantee, or representation, expressed, or implied, with respect to the accuracy, effectiveness, or usefulness of any information, method, or material in this document Nor do they assume any liability for the use of any information, methods or materials contained herein, or for damages arising from such use; nor assume any responsibility for any injury to individuals or property, or for any financial loss, sustained as a result of the use or application of the Guidance Manual It should be noted that: Operations and maintenance activities involving asbestos-containing materials may involve health risks to those performing them or in proximity to the location of the work. Experts from the building, scientific, and environmental communities have differing views as to many aspects of proper management in-pla^e asbesi containing materials. The purpose of this document is to bring together, from many sources, information and viewpoints reflecting current knowledge and technology. The Guidance Manual must be considered solely as a resource document representing a consensus of expert opinion. The Manual does not purport to represent the views, policies, or position of the U.S. Environmental Protection Agency, the U.S. General Services Administration, or any other agency of the federal government, or any participant in the development of the document It is intended that the document serve as a guide for building owners, employers, managers, or others in developing asbestos O&M programs and for workers who implement such programs. It is not the purpose or burden of this document to provide all-embracing answers to every problem of managing in-place asbestos. Users bear all risks associated with reliance on these work practices and shall have the sole responsibility to evaluate the information contained herein, to form their own independent judgments on the use of the Guidance Manual, and to modify or adapt it as may be appropriate to specific circumstances. PREFACE The National Institute of Building Sciences (NIBS) is pleased to publish this document Guidance Manual: Asbestos Operations & Maintenance Work Practices for use by those engaged in building operations and maintenance activities involving asbestos. The Institute would like to acknowledge the financial support provided by the U.S. Environmental Protection Agency and the U.S. General Services Administration for the development of this document and to express its appreciation for the continued assistance of these agencies. The NIBS Board of Directors appreciates the outstanding leadership of Mr. William H. Hoffman of Questco, Inc., who served as chairman of the NIBS project committee, Richard Peduto of The Port Authority of New York and New Jersey, who served as vice-chairman, and Roger G. Morse, AIA of ENTEK Environmental & Technical Services, Inc., who served as secretary. The Institute wishes to thank Mr. Peduto, Mr. Morse and Dr. Warren Friedman, CIH of the U.S. General Services Administration who served as chairs of the three project subcommittees. Also, the Institute wishes to acknowledge the excellent professional services provided by the Institute's contractors, Steve M. Hays, PJE., CIH, and Preston H. Quirk, AIA, of Gobbell Hays Partners, Inc. Most importantly, the Institute wishes to acknowledge and thank the members of the project committee for their exceptional and untiring efforts that were necessary to carry out this assignment NIBS* manual was envisioned from the outset as a companion to the F '*A document Managing Asbestos In Place, also known as the "Green Book," which describes the structure of an asbestos O&M program. This manual offers specific, detailed technical guidance to building owners, asbestos program managers, and building workers for activities that involve working near or on asbestos-containing materials. It does not quantify or explain the health risks associated with asbestos but is structured in response to the potential for exposure which might be encountered. Such a guidance manual would not have been contemplated if health risks did not exist It incorporates, not only the collective knowledge and experience of a broad crosssection of experts, but also the value of their unique perspectives in the building and operation management process. The procedures set forth in the manual represent a current characterization of continually evolving practices and technology. Standards and regulations for asbestos activities also continue to evolve and change. The project committee considered a broad range of issues including, compliance with federal, state, and local regulations, varied and evolving standards of care within the industry, and a variety of concerns of building owners and managers relating to economic objectives, company-specific environmental policies, and liability issues. i Preface 1992 NIBS Table of Contents I. Manual Organization Introduction ........................... ................................................................ 3 O&M Work Practices ..................................... ................................................. 6 Design and Validation of an O&M Program....................................................10 Use of O&M Work Practices............................................................................ 13 II. Asbestos Program Manager General Procedures APM Checklist ................................................................................. ................... 20 APM1 Selection of Personal Protective Equipment & Decontamination Procedures.................................................................................................... 22 APM2 Work Scheduling........................................................................................23 APM3 Federal, State and Local Notification..................................................... 23 APM4 Notification of Personnel........................................................................... 24 APM5 Assigning Workers .....................................................................................24 APM6 Developing the Air Monitoring Program and Assigning Air Monitoring Personnel........................................................25 APM7 Recordkeeping.............................................................................................27 APM8 Confined Spaces ........................................................................................28 APM9 Selection of Materials............................................... -............................29 APM10 Emergency Work and Dry Removal....................................................29 III. Worker General Procedures Level 1 Checklist ...................................................... Level 2 Checklist ................................................................ 32 34 Level'3 Checklist .................................................................................................... 35 W1 Tools, Equipment and Materials ..................................................................36 W2 Preparing Amended Water or Removal Encapsulant ..............................36 W3 Shut-off and Lockout of HVAC and Electrical Systems.........................37 W4 Securing Work Area ......................................................................................37 W5 Putting on Respirators and Performing Fit Checks...................................37 W6 Putting on Protective Clothing ........................... ...................................... 38 W7 Beginning and Conducting Air Monitoring................................................. 39 W8 Precleaning Work Areas and Wet Wiping ............... ............................... 40 W9 Setting up Work Areas................................................................................... 41 W10 Packaging and Labeling Waste ..................................................................44 W11 Applying Lockdown Encapsulant............................................................... 45 W12 Geaning Tools, Equipment and Work Area .......................................... 46 W13 Decontaminating Waste .............................................................................. 46 VV14 Worker Decontamination and Removal of Protective Clothing and Respirators .............................................................................................46 W15 Visual Inspection arid Completing Air Monitoring ................................. 47 W16 Waste Transportation, Storage and Disposal ........................................... 48 W17 Glovebag Removal........................................................................................ 48 W18 Disposal of Contaminated Water............................................................... 51* in a Table of Contents a 1992 NIBS * VI. Miscellaneous Materials Work Practices Miscellaneous Materials Location Illustration...............................................142 Code Levels Description Ml 123 Replacement of resilient asbestos floor tiles....................... 146 M2 123 Replacement of vinyl sheet flooring with ACM backing 152 M3 123 Penetrate resilient asbestos flooring and subfloor........... 159 M4 1 Install new resilient flooring or carpet over resilient asbestos flooring...................................................................163 M5 12 Install partition over resilient asbestos flooring................ 165 M6 1 Wet strip floor wax from resilient asbestos flooring ... 168 M7 1 Dry or spray buffing resilient asbestos flowing ................ 170 M8 1 Cleaning resilient asbestos flooring...................................... 172 M9 123 Remove carpet over resilient asbestos flooring...................174 M10 1 2 Clean potentially asbestos-contaminated carpet...................178 Mil 123 Remove asbestos-containing ceiling panels in lay-in ceiling system........................................................... 181 M12 2 3 Remove asbestos-containing ceiling tiles attached with adhesive........................................................................185 M13 123 Remove asbestos-containing ceiling tiles in spline ceiling system........................................................... 188 M14 23 Cut or drill asbestos cement panels..................................... 192 MIS 123 Remove asbestos cement panels........................................... 195 M16 12 Remove asbestos cement cooling tower louvers --------------199 M17 1 2 Remove and replace asbestos cement roof shingles ... 202 M18 1 2 Remove and replace asbestos cement siding...................... 205 M19 123 Remove high-temperature resistant (HTR) asbestos cement panels ........................................................ 208 M20 1 23 Remove asbestos-containing chalk board............................ 212 M21 123 Remove asbestos-containing fire door and/or door hardware ........................ 216 M22 1 2 Remove asbestos-containing built-up roofing.................... 220 M23 1 2 Remove asbestos-containing asphalt shingles.................... 223 M24 2 3 Cut or drill asbestos-containing drywall, plaster or drywall compound ...........................................................228 M25 2 3 Remove section of asbestos-containing drywall ............... 232 M26 1 2 3 Remove asbestos-containing flexible duct connector ... 235 M27 123 Remove asbestos-containing ductwork taping cloth----------239 M28 2 Remove contaminated filters in HVAC unit serving plenum space with exposed ACM........................ 243 M29 1 2 Clean up debris from minor fiber release.............................245 M30 1 2 3 Replace asbestos-containing gaskets.................................... 248 M31 2 3 Emptying and changing filter in HEPA vacuum or changing filler in HEPA fan unit....................................... 252 M32 1 23 Remove asbestos-wrapped wiring.........................................255 M33 12 3 Removing asbestos-containing caulking compound----------259 M34 1 Clean room that has asbestos-containing dust..................... 263 v a Table of Contents 1992 NIBS I. Manual Organization v.i>.-^-o.. *'---~~ "-^- Introduction Genera! This Guidance Manual: Asbestos Operations and Maintenance (O&M) Work Practices has been prepared to provide guidance on worker protection, basic O&M procedures, O&M cleaning practices, and procedures for responding to minor asbestos fiber release episodes in facilities with asbestos-containing material (ACM). This manual has been prepared by a National Institute of Building Sciences' (NIBS) commit tee under an assistance agreement between NIBS and the U.S. Environ mental Protection Agency (EPA) and the General Services Administration (GSA). The project committee has prepared the manual following the rules of the NIBS consensus process. This process provides an opportunity for representatives from all sectors of the building community to participate in the development and approval of the document The NIBS Consultative Council through its Operations Committee has approved the composition of the pro ject committee for balanced representa tion and expertise, and has provided oversight of the project activities to insure conformance with the NIBS Consensus process and has accepted the final report of the project committee. Scope and Flexibility The work practices described in this manual are applicable to projects qualifying as "small scale, short duration" as defined by the Occupational Safety and Health Administration (OSHA) of the U.S. Departments of Labor and EPA. The work practices are intended to assist in meeting the current OSHA regulations applicable to O&M work. The current and proposed EPA and OSHA smallscale, short-duration project definitions are reproduced in Appendix H of this manual. Appendix G of OSHA regula tion 29 CFR 1926.58 discusses work practices and engineering controls for small-scale, short-duration renovation and maintenance activities involving asbestos-containing materials. Appen dix I of this manual describes the spe cific requirements of OSHA Appen dix G. Projects larger than small-scale, shortduration should be performed in accor dance with generally recognized asbes tos control techniques, such as those described in NIBS* Asbestos Abatement and Management in Buildings: Model Guide Specifications. If ACM is in poor condition, O&M might not be appropriate and abatement might be necessary. These O&M work practices are not to be used for activities requir ing abatement of ACM. This manual is intended for use by an Asbestos Program Manager (APM) and trained workers. The title "Asbestos Program Manager" is used throughout; however, other titles can be used by individuals holding similar responsi bilities. The manual provides check lists and step-by-step work practices which might be used by an APM and workers for performing O&M work. Because asbestos in buildings is pres ent under widely varying circumstances including, but not limited to, its condi tion, location, material type, friability, and accessibility, a range of guidance for common operations and mainte nance procedures is offered in this manual. The project committee deter mined that flexibility is crucial to the efficient and cost effective completion of an O&M activity. This leaves the ultimate choice of methods to on-site 3 Introduction 1992 NIBS iiLrf.Cij Related Documents This manual is intended to be used in conjunction with the guide Managing Asbestos in Place ("Green Book") issued by the EPA in July, 1990, and in compliance with all applicable federal, state and local regu lations. The Green Book explains the objectives and administrative proce dures for an O&M Program. This O&M Work Practices Manual provides detailed procedures for conducting O&M work involving ACM, such as maintenance, repair and minor renova tion work. It is expected that many decisions relating to work practice levels might be embodied in the O&M plan for a specific building. In some circumstances, governing regulations may dictate level selection. Informa tion presented in the Green Book is not repeated in this guide but is referenced where appropriate. Additional refer ences might be made to other legal regulations and guidance documents, including: 1 oiaiutory & Regulatory Requirements 1. OSHA's asbestos construction, construction safety, personal pro tection and hazard communication standards 2. National Emission Standards for Hazardous Air Pollutants (NESHAP) 3. Asbestos Hazard Emergency Re sponse Act (AHERA) 4. Asbestos Schools Hazard Abatement Reauthorization Act (ASHARA) 5. EPA Worker Protection Rule (WPR) 6. Department of Transportation's hazardous waste transportation standards EPA Guidance Documents 1. Asbestos in Buildings: Simplified Sampling Scheme for Friable As bestos Materials ("Pink Book") 2. Guidance for Controlling Asbes tos-Containing Materials in Build ings ("Purple Book") 3. A Guide to Respiratory Protection for the Asbestos Abatement Indus try ("White Book") A list of references, including the above listed regulations and guidance documents, is given in Appendix F of this manual. A summary of the above listed OSHA and EPA regulations is included in Appendix I of this manual. State and local regulations, which might be the same as, equivalent to, or more stringent than federal regulations, might also apply. In addition, general ly accepted good construction work practices should be used for all other aspects of O&M activities not specifi cally mentioned in these work practic es. 5 Introduction 1992 NIBS  Occupant notification/communication program O&M worker, supervisor, and competent person assignments and training program Work control/inspection/permit system Periodic surveillance program Recordkeeping program Hazard communication program Worker protection program (per sonal protective equipment) Respiratory protection program Medical surveillance program Asbestos fiber release episode re sponse program Air monitoring program Waste disposal program Historical air monitoring data Confined space program Safety program for other hazards All O&M related programs should be reviewed periodically and revised if necessary. Regulatory and guidance documents should also be reviewed periodi . *; to insure uiat they are current Organization of Work Practices The O&M work practices in this guide are grouped according to the type of asbestos-containing materials (ACM) that will be affected by the work. ACM is classified in this manual ac cording to the three (3) categories used by the EPA. This classification system has been widely used in the asbestos industry since the publication of the Asbestos Hazard Emergency Response Act Rules (AHERA) in 1987. These categories are: 1. Surfacing Materials * materials sprayed or toweled onto building surfaces, such as acoustical materi als or fireproofing. 2. Thermal Systems Insulation (TSI) pipe, boiler, tank, duct and other ' insulation applied to components to reduce heat loss, heat gain or condensation. 3. Miscellaneous Materials - materials such as floor tile, ceiling tile, roof ing, cement asbestos products and other materials that are not includ ed in categories 1 or 2.above. the work practices in this manual are generally designed to address one ma terial at a time. If more than one type of material is involved, work practices should be selected and used in the order in which the materials will be encountered during the work. If two (2) or more materials must be addres sed at one time, the Asbestos Program Manager should develop a combined Work Practice to address the particular work situation. When developing a combined work practice, the APM should consider the following: 1. The checklist for the most precau tionary level of work practice should be used. 2. The work area should be prepared in accordance with the checklist for the mostprecautionary level of work practice being used. 3. Once the work area is prepared and pre-work activities are com plete, the detailed work practices should be performed in the order in which materials are encount ered. 4. Clean up and tear down procedur es should also follow the most precautionary level of work practice being used. 7 O&M Work Practices 1992 NIBS * m nii' Tinn ^"if>n'r-c~irr -Y-'-'-'Tiir -- - n Figure 1: Guidelines for 3 Levels of Work Practices ITEM (General Procedure Reference) Fiber Release Potential Training (APM5)* HVAC System Off (W3) Vacate Area (W4, APM2) Critical Barriers (W4) Delineated WorkArea (W4) Respiratory Protection (W5) Protective Clothing (W8, W14) Initial Monitoring (W7) Periodic Monitoring (W7) Preclean (W8) Use HEPA Vacuum (W8) Wet Methods (W8) Work Area Protection (W9) Local HEPA Exhaust (W9) Lockdown (W10) Area Decontamination (W11) Visual inspection (W12) Air Clearance (W12) Persona1 Decontamination (W15) LEVEL I1 LEVEL 2? Low/Minimal1 Moderate Awareness/O&M3 O&M NO4 YES NO YES NO NO3 NO YES NO6 YES7 NO1 YES NO9'10 YES9'10 NO10 YES NO As Needed" As Needed11 YES As Needed" YES NO12 Drop Cloth, Glovebag NO AS Needed" NO YES" NO YES NO YES NO14 K* TAlS NO14 YES LEVEL 31 High O&M YES YES YES YES YES YES YES9,10 YES As Needed" YES YES Mini-Enclosure, Negative-Pressure System13 As Needed" YES" YES YES YES YES NOTES 1 The exact meaning of these three levels will vary depending upon the exposure objectives which are speci fied in die design of the O&M plan for a specific building (see Design & Validation of An O&M Plan for further explanation). State and local requirements may be more stringent than these guidelines. 2 The general procedures in paren theses provide additional infcona tion on the noted item. 3 Training should be appropriate to the type of ACM, building condi tions, and the work to be performed. If ACM may be or will be disturb ed, O&M training may be necessary. 4 Turn off HVAC if work will be performed on HVAC systemfs). 5 Critical barriers may be necessary or be required for specific cases by the APM. 8 The OSHA asbestos standard. Appendix G, states that maintenance staff employees should be instructed not to remove ceiling riles below ACM without wearing the proper respiratory protection, clearing the area of other people, and observing asbestos waste disposal procedures. Appendix E of the Green Book recommends that respirators be worn for routine maintenance work where there is a reasonable likelihood of ACM dis turbance. For routine maintenance woik where contact with ACM Is unlikely, appen dix E recommends aNo respiratory protection required. (Air-purifying respirators with highefficiency filters should be available if need ed; half-face or full facepiece)." EPA advises building owners that these recommendations go beyond OSHA requirements. 7 Respiratory protection can be deleted if supported by adequate exposure data in accor dance with the OSHA regulations. 8 Protective clothing should be avail able and is required by OSHA if exposure is over permissible exposure limit 9 Monitoring is required by OSHA if ACM is disturbed. 10 Monitoring may be deleted if supported by statistically reliable historical data in accordance with OSHA regulations. 11 May be recommended see work practices. Adequate training is neces sary. 12 Drop cloth optional for dirty tools, equipment and/or waste. 13 Work area protection may be revised if alternate methods are used and historic data are available. 14 Air clearance depends on air mon itoring program requirements. 15 Personal decontamination may be required by APM or O&M program. 9 0 & M Work Practices 1992 NIBS Exposure monitoring will be needed to validate that each work practice level meets the intended exposure goals. To fit within the level definitions,, the fol lowing must hold true: 1. Level 1 (NO Worker or Area Pro tection) work practices should not result in elevated airborne asbestos levels. 2. Level 2 (Worker Protection, with Minimal Area Protection) work practices may result in localized elevations of airborne asbestos levels that will only affect the wor ker, but not the building environ ment 3. Level 3 (Worker and Area Protec tion) work practices may, if uncon trolled, result in elevations of air borne asbestos levels that are suffi cient to require worker protection and isolation of the work area from the rest of the facility. O&M programs should always empha size the use of "pacification" techniques such as wetting, more careful handling, local collection and local exhaust, etc. to avoid unnecessary disturbance of asbestos and die need for work area isolation. Work procedures, or modifi cations to these work practices, should be designed in accordance with the exposure goals of the owner and/or employer, the circumstances of the particular building, and the skill and training of the APM and workers. The only way that a work practice can be validated is to perform the procedure and monitor airborne levels during the work. Personal monitoring is required to determine if work area isolation is needed. If no disturbance of ACM will occur (such as with many Level 1 work practices), monitoring might not be required. Meaningful exposure monitor ing requires sufficiently long sample durations. Readings are not instanta neous. O&M procedures are small in scale and short in duration, requiring that many procedures be repeated a number of times to enable the collection of a sample with sufficient sensitivity. The Air Monitoring Program developed for a specific facility needs to address how exposure monitoring will be con ducted to provide data for use in the design and validation of work practices. The program should define exposure limits for both workers and the building environment The Phase Contrast Microscopy (PCM) air monitoring required by OSHA for exposure monitoring does not distin guish between asbestos and non-asbes tos fibers and cannot measure the short or thin fibers that might be detected using Transmission Electron Microsco py (TEM). Air monitoring data for OSHA exposure might not be an accu rate predictor of TEM results. Some TPM data indicate that workers might be exposed to shoit or thin fibers, which are not regulated by OSHA, when performing O&M activities. O&M activities might create small fibers when work such as cutting or drilling of ACM is performed. TEM analysis of clearance samples is requir ed by the federal government under AHERA for applicable school projects involving ACM which is or becomes friable. Portions of a report published in 1991 by the Health Effects Institute (HEI) Asbestos Research discuss available information regarding asbestos fiber sizes and their effect on asbestos related diseases. This report also discusses die current status of surface dust sampling techniques that are used by portions of the asbestos industry to determine as bestos contamination on surfaces. 11 Design and Validation of an O&M Program 1992 NIBS Use of O&M Work Practices Lists of Work Practices and Work Practice Summaries Lists of the work practices in this manual are pro vided in the Table of Contents and at the beginning of each section of work practices. The first page of each work practice is a summary of the work practice and lists examples of typical situations, associated general proce dures, related work practices and cer tain basic information about the prac tices. A recommended minimum num ber of workers is listed for each work practice. A further discussion of the number of workers for O&M activities is included later in this section. Selecting Work Practices for a Facility The Asbestos Program Man ager (APM) should select work practic es from this manual that are appropri ate for the facility where the work will be performed. The selection of work practices will be based on a variety of factors, including O&M Plan policies and the selection factors listed in this section. If situations exist that are not covered by this manual, the APM should develop work practices appro priate to the situation based on die guidelines in this manual and other applicable sources. It might be dearable to obtain assistance from sources, such as qualified consultants, legal counsel, risk managers or insurance companies when selecting appropriate work practices. A number of determinations must be made in order to select the appropriate work practice for a given situation. These include:1 1.The level of worker and environ mental protection desired based on the O&M program objectives. 2. Whether O&M work will be perfor med by staff personnel or an outside contractor. The O&M program could specify that some activities or work practice levels be done with inhouse personnel, while other activi ties or levels are done by contrac tors. If O&M work is to be per formed by contractors, the APM's responsibilities and activities might be changed to include contractual obligations, submittal reviews, and verification that O&M work and monitoring is being performed as required. Modifications to the Work Practices, APM Checklist, Worker Checklists and General Procedures might be needed. 3. Regulatory compliance issues for the specific facility .and personnel who will perform the work. These in clude CSHA and ErA requirements for worker protection, work practic es, exposure monitoring, notifica tions and additional state or local requirements. 4. Whether exposure monitoring data and work evaluation forms (see Ap pendix C) from past work indicate that a given work practice or work practice level accomplishes the O&M objectives. Using the Work Practices The APM will select the work practices to be used. A decision tree illustrating this selection process is shown in Fig ure 2. Guidance for selecting the ap propriate work practice level is shown in Figure 1. The process of using work practices from this O&M Work Practices Manu al, or alternatives based on this manual, for a given situation can be summa rized as follows: 13 Use of O&M Work Practices 1992 NIBS Figure 2: Work Practice Selection Asbestos Program Manager Tasks: Work Practice Selection and Use 15 Use of O&M Work Practices 1992 NIBS ^ V" In instances where ACM will be dis turbed, OSHA requires that personal air monitoring be performed for work prac tices unless employee exposures, as indicated by statistically reliable mea surement, are below the OSHA action level and/or permissible exposure limit (see OSHA regulations for details). O&M workers who will disturb ACM should use respiratory protection and other protective measures, unless ade quate data are generated that indicate exposure levels in compliance with the O&M program objectives. Validation of the work practices is necessary to determine if a work prac tice is appropriate for use under the O&M conditions present in a given facility. Data generated can be used by the APM during future selection of work practice levels. If O&M activity data are to be used to qualify for OSHA historical data exemptions or for main taining OSHA exposure records, it is necessary that the information be kept in strict accordance with the require ments of the OSHA construction stan dard (29 CFR 1910.20). The work practice user is responsible for proving compliance with all applicable federal, state and local regulations. Based upon the data obtained, the APM might de cide to use a higher or lower level of work practice for a specific task. Sub stantially more data are required to justify tiie use of lower level work practices. Any data indicating higher exposures than anticipated warrant consideration of moving to higher level work practices. Work practice. levels may be modified as noted in Figure 1 based upon historical air monitoring data (additional information on histori cal data is provided in General Proce dure APM6). Note also that state or local regulations may require more stringent work practices, higher levels of precaution or additional monitoring. Number of Workers Each work practice summary includes a recom mendation on how many workers are needed to perform the work. A number of factors should be considered when determining how many workers are to be assigned to perform an O&M activi ty, such as: Regulatory requirements The amount of woric to be done Accessibility to the work area (height, enclosure) Worker skill, training and experience Weight, size or length of objects in volved in the work Worker safety or degree of risk Work efficiency and cost effective ness One worker is recommended where the work practice can be accomplished safely and effectively with one worker. Two or more workers are recommended for work practices involving enclosures or where special conditions or other factors complicate the work. State or local regulations nay dictate the num ber of workers needed. Gsue/al Proce dure APM5 includes additional informa tion on assigning workers. Work Practice Checklists ihe work practice selection process outlined above and additional information related to the selection and use of the work practices are compiled on the "Asbestos Program Manager Checklist" shown in Figure 3. Checklists to be used by workers for each level of work practice are shown on "Worker Checklists" in Figures 4, 5 & 6. A checklist is to be provided to the worker with each work practice in order to give the worker complete in formation required to perform the work. 17 Use of O&M Work Practices s 1992 NIBS +**A*`*'- ) II. Asbestos Program Manager General Procedures w" * Section li Asbestos Program Manager } General Procedures All references in this manual to Asbestos Program Manager (APM) refer to a person designated to perform die Asbestos Program Manager's duties. This could be the building manager, owner, or another person repenting to die APM. The Asbestos Program Manager or a designee should review work practices with the workers who will perform die work. Workers should be nodded to consult with die APM or designated person if they have any questions during the work, if any problems occur, o^ if it appears to die workers that additional precautions might be necessary to safely perform the work. this section includes detailed proce dures for steps that are common to many of the work practices. These general procedures are referenced in the work practices and in the APM checklist The general procedures should be covered in O&M training related to the use of this manual. Not all of the general procedures are used in every work practice. The work practices and checklists refer the user to applicable general procedures for detailed information on how to perform a certain portion of the work. Once a user is familiar with the general proce dure requirements, it might not be necessary to review die general proce dures each time an O&M activity is performed. However, the general procedures should be reviewed periodi cally by die APM to verify that the proper procedures are being followed. Users of the O&M Work Practices Manual should also review the General Safety Considerations information in Appendix "G". APM Checklist ................................................................................................................20 APM1 Selection of Personal Protective Equipment & Decontamination Procedures........................................................................................................... 22 APM2 Work Scheduling................. 23 APM3 Federal, State and Local Notification.............................................................23 APM4 Notification of Personnel.......................................................... 24 APM5 Assigning Workers.............................................................................................24 APM6 Developing the Air Monitoring Program and Assigning Air Monitoring Personnel........................................................................................25 APM7 Recordkeeping.................................................................................................... 27 APM8 Confined Spaces..................................................................................................28 APM9 Selection of Materials ....................................................................................29 APM10 Emergency Work and Dry Removal .............................................................29 Note: Not all of the general procedures are used in every wort practice. 21 Asbestos Program Manager General Procedures a 1992 NIBS APM l^contirwd The APM might also determine wheth er boots, gloves, hardhats or other prot ective equipment is needed for O&M tasks. Protective clothing selections made by the APM should be recorded on the Maintenance Work Authoriza tion Form. APM 2 Work Scheduling Level 2 and 3 work should be scheduled for a time when the work area will not be in use and can be dosed off to anyone other than trained workers, or other autho rized personnel. If an area is always occupied, plans should be made to isolate the work area from building occupants using visual and/or physical barriers. If a special work area ar rangement is required, it might be beneficial to provide a sketch to the workers showing how the area is to be set up. If respirators are used for Level 1 activities, it might be desirable to vacate the area to avoid concerns resulting from a worker in a respirator working within sight of unprotected workers/occupants. Scheduling of work might be affected by notificadoii requirements. All noti fication requirements should be met before work is scheduled. Under cer tain circumstances, some emergency work can be performed prior to the filing of a notification. Review regula tions and contact federal, state and local regulatory agendes concerning notification requirements for emergen cy work. APM 3 Federal, State and Local Notifica tions The Asbestos Program Manag er, or his designee, should file all notices required by federal, state and local regulations prior to the start of any O&M activities that are governed by these regulations. Federal Notifications Federal require ments for notification are set forth in the National Emission Standards for Hazardous Air Pollutants (NESHAP) rules and the EPA Worker Protection Rule. OSHA is considering adding notification requirements to the OSHA regulations. For demolition and reno vation work, the latest NESHAP revi rions are contained in 40 CFR 61.145 (a) and (b). A ten working day federal notification is required for renovation work if the combined amounts of regulated asbestos-containing material (RACM - see glossary or NESHAP for definition) to be stripped, removed, dislodged, cut, drilled or similarly disturbed is over 260 linear feet (80 linear meters), 160 square feet (15 square meters) or 35 cubic feet (1 cubic meter) for any single project Also, if the combined estimated quanti ties of RACM to be removed or stripped in individual nonscheduled operations during a calendar year (Jan uary 1 through December 31) exceeds the amounts listed above, a NESHAP notice must be submitted ai least ten working days before the end of the calendar year (e.g. December 15) pre ceding die year for which notice is being given. A new written notice must be filed with the EPA if the start date for a project is revised (earlier or later) from the date filed in the original or a previous notice. A notice must be updated if the amount of asbestos affected changes by 20 percent or more. If wetting of RACM during removal would unavoidably damage equipment or present a safety hazard, written approval from the EPA is required for 23 a Asbesios Program Manager General Procedures a 1992 NIBS APM 5~continu*d APM 6 for maintenance workers where the employer does not establish full scale negative pressure enclosures, and does not utilize full scale decontamination. State and local regulations may impose training requirements for O&M activi ties. Verify that state and local requir ements are met before scheduling work. Additional training might be desirable for performing frequent O&M work or certain O&M tasks. Before workers are assigned to O&M work, the APM should verify that their train ing, respirator fit tests and medical sur veillance are current and in compliance with regulations (where applicable) and the requirements of work practices to be used. Appendix F in this manual ,, gives guidance on where to find appli cable regulatory information and Green Book guidance on these topics. Depending upon applicable regulations (such as NESHAP), a designated trained or "competent person" might be required to perform or supervise certain aspects of the work. Section 4 of this manual discusses factors to consider when determining the number of work ers required for an O&M activity. Once workers are selected for 8 task, the APM should review the work prac tice with the workers, if needed. Developing the Air Monitoring Program and Assigning Air Moni toring Personnel Sole: This section is not intended as a substitute for a complete Air Monitoring Program that is neededfor O&M work. This section notes air monitoring issues that the APM needs to addressfor O&M work. Owners might choose to use an outside consultant to perform air monitoring for O&M activities. In certain cases, where frequent O&M activities are performed, the O&M program might include having one or more designated trained workers perform air monitoring during O&M activities. In either case, an Air Monitoring Program should be developed by the air monitoring per sonnel or consultant and the APM for O&M activities. The Air Monitoring Program should specify when air moni toring will be performed, the types of monitoring (personnel, background, area, clearance, periodic, and/or initial), analysis methods, training requirement for monitoring personnel, and proce dures for maintaining data from O&M activities, including any data required for OSHA historical data monitoring exemptions. Air monitoring data should be considered when selecting the type of respirators for activities that use respiratory protection. Training might be required by the Air Monitoring Program or state or local regulations, and could include a NIOSH air monitoring course, industri al hygiene training or other require ments. Training for persons perform ing air monitoring work should include hands-on training with the equipment to be used. Training for air monitoring that is currently available consists primarily of courses meeting the Na tional Institute for Occupational Safety and Health (NIOSH) 582 requirements. Air monitoring exemptions or require ments for a given work practice should be based on the Air Monitoring Pro gram and stated on the Maintenance Work Authorization Form. Exposure monitoring should be addre ssed in the Air Monitoring Program and is required for operations covered by OSHA regulations. Review the ap plicable OSHA standards in detail when developing air monitoring proce dures for O&M work. Sections O&M work include those on initial 25 Asbestos Program Manager Genera! Procedures 1992 NIBS APM S^continued APM 7 samples to obtain an 8 hour timeweighted average (TWA), if possible, and excursion limit (EL) monitoring samples. All analysis for OSHA com pliance should be by phase contrast mi croscopy (PCM). Transmission elec tron microscopy (TEM) analysis will distinguish asbestos fibers from other fibers and might also be used if desi red, although PCM data is required by OSHA. TEM data cannot substitute for OSHA required PCM data unless approved by die local OSHA office. The use of TEM analysis or settled dust sampling to evaluate the need for precleaning prior to an O&M activity might be considered. Neither method is required by current regulations. The project committee did not take a position on the efficacy of settled dust sampling, nor advocate its use. It is presented here as an available analyd- . cal tool that might be used. Settled dust sampling can also be used during O&M activities to document disturban ces during the activity. Settled dust sampling might be used as part of a clearance protocol for O&M work. No regulatory standards for dust sampling exist at this time. The APM might ^ want to consult with an experienced laboratory or consultants regarding die latest settled dust sampling procedures and protocols. Procedures commonly in use include microvacuuming, surface wipe samples, and tape lift methods. Recordkeeping The Green Book recommends that the following records of O&M work be retained in permanent files: Inspection and Assessment Reports A copy of the O&M Program (initial program and all updated versions) The Work Practices Used Respiratory Protection Program Fiber Release Reports Job Request Forms Maintenance Work Authorization Forms Evaluations of Work Affecting ACM Reinspection/Periodic Surveillance Reports For employers with employees engaged in asbestos-related work, federal regulations require that the employer retain: Personal Air Sampling/Exposure Monitoring Records Historical Data (used to qualify for exemptions from GSHA's initial monitoring requirements) Medical Records (for employees subject to a medical surveillance program) Employee Training Records Fit Test Records (for employees that use respirators) This O&M guidance manual also recommends that records be maintained for: Waste Tracking and Disposal See Appendix D. Air Monitoring Data Qualifications and Performance Records for Outside Contractors performing O&M work If settled dust sampling is used it is advisable to maintain these records also. OSHA requires that employers provide to each employee their record of exposure and medical surveillance under the Records Access Standard (29 CFR 1910.20) and the Hazard Communication Standard (29 CFR 1910.1200 & 1926.59). Also see the OSHA Asbestos Construction Rule (29 CFR 1926.58), tile EPA Worker Protection Rule (40 CFR 763 Subpart G) and the Green Book for details on recordkeeping requirements. 27 Asbestos Program Manager General Procedures 1992 NIBS O ) APM 9 APM 10 Selection of Materials The Asbestos Program Manager should be responsible for the selection of certain materials used for O&M activities. This manual will not attempt to give guidance on the selection of all materials needed for O&M work. Information on selection of the following materials is provided: Polyethylene Lockdown encapsulants Guidance on the selection of other mate rials should be obtained in training cour ses, or from reference materials, such as the NIBS Guide Specifications for Asbes tos Abatement polyethylene. However, some tests have shown only minimal differences in flame spread time between standard and fire retardant poly. Anti-static polyeth ylene should be used around equipment sensitive to static electricity. Lockdown Encapsulants Lockdown encapsulants selected should be appro priate for die intended use. Use high temperature rated encapsulants for heating system components such as piping, boilers & flues. Lockdowns should also be compatible with any replace ment materials, such as new flooring adhesive. Compatibility should be verified prior to the start of work. , Polyethylene Various thicknesses, colors and types of polyethylene are available. The most common thicknesses used for asbestos related work are 4 mil and 6 mil (0.10 mm and 0.15 mm). State or local regulations may require that certain thic knesses or types of polyethylene be used. Two mil (0.05 mm) polyethylene is also available, out is not widely used since it w.sfiy. Polyethylene is also avail able in fire retardant and anti-static types. Fire retardant polyethylene does not sup port flame as readily as standard Lockdowns are available in clear or colored mixtures. Clear mixtures should be used where a colored encapsulant would be objectionable for ap pearance reasons. Colored encapsulants should be used (where posable) with a color chosen to indicate that an area has been locked down. The-color also allows a worker to see where encapsulant has been applied during the appli cation. Emergency Work and Dry Removal O&M activities sometimes require that regulated asbestos O&M work be per formed immediately to maintain opera tions and prevent other health or safety hazards. Emergency work is acknow ledged in regulations and is permitted under certain conditions. The NESHAP regulations specify that a notification for ordered emergency renovation operations must be postmarked or delivered "as early as possible before, but not later than, the following working day" (see regulation for foil text). State or local regulations may have additional requirements. Emergency work might involve activi ties (such as work around activated electrical equipment) where the use of wetting would result in equipment dam age or a safety hazard. NESHAP per mits work without wetting regulated ACM under certain conditions (see regulation for details). For facilities where dry removal work might be re quired, the APM should review regula tory requirements in advance with au thorities having jurisdiction over the facility. 29 Asbestos Program Manager General Procedures 1992 NIBS T1 lttr^1-* l-'Titra o III. Worker General Procedures * V" Section ill Worker General Procedures This section includes detailed proce dures for steps that are common to many of the work practices. These general procedures are referenced in the work practices and in worker and APM checklists. The general proce dures should be reviewed in detail by all personnel using this work practices manual. If possible, the general proce dures should be covered in O&M train ing related to die use of this manual. The work practices and checklists refer the user to applicable general proce dures for detailed information on how to perform a certain portion of die work. Once a user is familiar with the general procedure requirements, it might not be necessary to review the general procedures each time an O&M activity is performed. However, the general procedures should be reviewed periodically by all workers and the APM to verify that the proper proce dures are being followed. Workers should report any suggestions or problems regarding these work practices to their supervisor, the Asbes tos Program Manager (APM) or die APM's designee. Users of the O&M Work Practices Manual should also review the General Safety Considerations information in Appendix "G" of this Manual. Level 1 Checklist...........................................................................................................32 Level 2 Checklist......................................................................................... -- ^... 34 Level 3 Checklist................................................................................................ :------- 35 W1 Tools, Equipment and Materials .......................,..................... -................ 36 W2 Preparing Amended Water or Removal Encapsulant................................... 36 W3 Shut-off and Lockout of HVAC and Electrical Systems.............................37 W4 Securing Work Area ........................................................................................37 WS Putting on Respirators and Performing Fit Checks ...................................... 37 W6 Putting on Protective Clothing........................................................... 38 W7 Beginning and Conducting Air Monitoring...................................................39 W8 Precleaning Work Areas and Wet Wiping..................................................... 40 W9 Setting up Work Areas..................................................................................... 41 W10 Packaging and Labeling Waste ....................................... 44 W11 W12 W13 W14 W15 W16 Applying Lockdown Encapsulant.................................................................... 45 Cleaning Tools, Equipment and Work Area ................................................ 46 Decontaminating Waste ...................................................................................46 Worker Decontamination and Removal of Protective Clothing and Respirators.............................................................. 46 Visual Inspection and Completing Air Monitoring...................................... 47 Waste Transportation, Storage and Disposal................................................ 48 W17 Glovebag Removal .......................................................................................... 48 W18 Disposal of Contaminated Water............................................... Note: Not all of the worker general procedures are used in every work practice. 51 33 Worker Genera! Procedures 1992 NIBS mcaa Figure 6: Level 3 Worker Checklist Operations and Maintenance Work Practices Pre-Work Activities G Work Area G G G G G a a a a a D Work Practices Obtain and review copies from Supervisor or Asbestos Program Manager of: Completed Maintenance Work Authorization Form Work practiced) to be used including personal protective equipment options Work Notification^) (as applicable) Schedule for work Review work practices and referenced general procedures used in work practiced). Obtain recommended tools, equipment and materials See General Procedure W1 and work practice(s) item 2. Obtain required respirators as listed on Maintenance Wort: Authorization Form. Move tools, equipment and materials to work area. Shut off and lock out HVAC and electrical systems serving work area See General Procedure W3. Vacate and secure work area, such as by locking doors and/or setting up temporary barriers - See General Procedure W4. Put on respirators and perform fit checks - See General Procedure WS. Put on protective clothing - See General Procedure W6. Air monitoring personnel begins air monitoring work (if required) See General Procedure W7. Preclean work area if visible dust or debris is present - See General Procedure W8. Set up work area and decontamination facilities as required by work practice item 3 - See General Procedure W9. Perform work per steps in work practiced). Cizan-Up O Package aid label asbestos waste for disposal - See General Procedure W10. and O Apply lockdown encapsulant, where required, using garden sprayer, to surfaces Tear-Down where ACM was removed or disturbed - See General Procedure Wll. Perform ceiling panel replacement work or ceiling repair work if needed. G Gean tools, equipment and work area using wet wiping and HEPA vacuuming as appropriate and return tools and equipment to outside work area See General Procedure W12. G Decontaminate packaged waste & move waste to outside work area See General Procedure WI3. G Workers decontaminate and remove protective clothing and respirators. If contaminated, dispose of protective clothing as ACM - See General Procedure W14. G Complete visual inspection. Complete air monitoring work - See General Procedure WI5. G If feasible, get APM or designee to complete Evaluation of Work Form. G Transport waste to designated asbestos waste storage area - See General Procedure W16. G Remove drop cloth and/or mini-enclosure. G Return decontaminated tools, equipment and remaining materials to storage area. G Remove lockout tags and restart HVAC/electrical system(s). G Restore normal accessibility to work area. Q Notify Asbestos Program Manager or Supervisor that work is completed & return documents to APM. .. -- 35 Worker General Procedures 1992 NIBS m W4 W-5 Shut-off and Lockout of HVAC and Electrical Systems Any electrical systems that might be worked on or affected by O&M activities should be shut off, locked and tagged with electrical lockout tags at die circuit breaker panel or disconnect switch. Affected systems include systems that could create electrical hazards during O&M activities that involve wetting. HVAC systems in a work area, systems that serve a work area, or systems that will be worked on should be shut down during O&M activities. Level 1 activities usually do not require HVAC shut down unless a work will occur on a system or a disturbance of asbestos will occur. Any air-handling systems (supply, return and exhaust) required to be shut down should be shut off, locked, and tagged with electrical lockout tags at the circuit breaker panel or disconnect switch. Lockout tags should note when and why power is shut down and the personnel performing the lockout There should only be one key for each lock used on lockout tags to prevent accidental reactivation of equipment Securing Work Area When asbestos fibers might be released, work areas should be vacated and secured (where feasible) by scheduling, locking doors (from inside the area if possible) or other means. Installing polyethylene critical barriers over all openings into the work area. If this is not feasible, access to the work area should be restricted, such as by asbestos barrier tape around the perimeter of the work area. If barrier tape is used to denote a work area, it should be placed 5 to 10 feet (1.5 to 3 meters) outside of any polyethylene protection used in the work area. Install barrier tape by taping or tying it to fixed objects. Do not block access to any emergency exits, and when asbestos fibers might be released, post OSHA required "danger" signs at all entrances to die work area. For such projects, it might be desirable to have a visual barrier installed several feet in front of warning signs to avoid having warning signs readily visible to occupants. A "keep out of construction area" sign should be posted on visual barriers. A visual barrier would be arranged so that a person who goes past the visual barrier will then see required warning signs. Putting on Respirators and Performing Fit Checks The procedures described below are based on the assumption that workers wearing respirators have been trained in the use of respirators and, for negative pressure respirators, fit tested, and enrolled in a medical surveillance program as part of a Respiratory Protection Program. Respirators used should be approved by NIOSH and/or MSHA. These procedures are not a substitute for a Respiratory Protection Program in accordance with OSHA standard 29 CFR 1910.134 or regulatory requirements regarding respirators. 37 Worker Genera! Procedures 1992 NIBS WS^contmued W-7 If street clothes could become contaminated, two coveralls should be worn, or the street clothes should be removed before the start of work. When possible, street clothes should be removed in a changing area before protective clothing is put on. Protective clothing should be put on after respirators. The coverall hood should cover respirator straps. Workers are encouraged to wear protective gloves that are duct taped at the cuffs to the protective coveralls. Eye, hearing, and head protection should also be used where needed. Rubber slip-resistant boots are recommended for work areas where slip hazards might occur (protective booties should cover feet inside the boots). Steel-toed boots should be used in areas where foot hazards exist Do not use coveralls with loose foot coverings for activities that involve climbing ladders or working on scaffold. Beginning & Conducting Air Monitoring Note: This section is not intended as a substitute for a complete Air Monitoring Program and specific protocols neededfor O&M work. This section notes air monitoring issues that need to be addressed by the air monitoring person. Air monitoring during O&M activities can consist of personal monitoring, ?rea monitoring and clearance monitoring. Air monitoring required for the work practice being performed should be listed on the Maintenance Work Authorization Form and be conducted in accordance with applicable regulations (such as 29 CFR 1926.58 Appendix A), the O&M Plan and Air Monitoring Program. All air monitoring work should be conducted by a trained air monitoring person assigned by the APM. The air monitoring person should calibrate, adjust, and record the flow rate of all air monitoring pumps to be used before air monitoring is started for an O&M activity. General procedure W15 covers visual inspections and the completion of air monitoring at the end of the work. Personal Monitoring To perform personal monitoring, attach a personal air monitoring pump to a belt worn by the worker. Attach an air sampling cassette to the hose from the pump. Route the hose up the worker's back and tape the hose to the worker's protective coveralls using duct tape. The cassette should be located with the open end facing downwards at approximately a forty-rive degree angle in the worker's "breathing zone" at about collar level. Turn the pump on and record start time. The air monitoring person will retrieve or change the cassette when necessary, or when work is completed. Area Monitoring Area monitoring is usually performed using high volume air sampling pumps. Place pumps inside the work area and outside the work area in occupied areas or areas where occupants could be exposed if fibers are released from the work area. Pumps should be located where they obtain meaningful measurements of potential worker exposure during monitoring. Attach sampling cassettes to the hoses from the pumps and attach the cassettes to the top of tripod stands or other stable structures (but not the pumps themselves) to locate the sample at four to five feet (1.2 to 1.5 meters) above the floor. These cassettes should be located with the open end facing downwards at approximately a v" * 39 Worker General Procedures 1992 NIBS W-flLconffnuwf Steam Cleaning Carpet The procedures to be used for steam cleaning carpet are as follows: 1. Steam clean carpet using carpet tool. 2. Steam clean all surfaces in parallel passes with each pass overlapping the previous one by one-half die width of the attachment. 3. Once surfaces are cleaned in one direction, clean a second time at right angles to the first cleaning. .4 Water from cleaning process should be treated in accordance with applicable regulations - See WJ8. W~g Setting up Work Areas Note: Polyethylene work area protection is not to be used in place ofother engineering controls and good work practices. Work practices such as wetting ACM, careful handling, local collection by HEPA vacuum and local exhaust ventilation should be the primary means of. fiber control during O&M work. Polyethylene protection, glovebags, and mini-enclosures are intended as a secondary means ofprotection during the work. State or local codes might require that fire retardant polyethylene be usedfor asbestos related work. IN* NIBS Obentos Abatement and ' Management in Buildings: Model Guide Specifications Section 01527 "Regulated Areas" provides information on the preparation of "a regulated area" for small scale, short duration work. Section 01529 "SmallScale Short-Duration Work" of the NIBS specifications provides information on the set up of a mini enclosure. Review of this additional information is encouraged. Preparation of work areas for O&M activities typically involves the use of a polyethylene drop cloth or minienclosure. Other techniques, such as the use of a glovebag taped over a selfsupporting framework might also be used as a substitute for the specified methods where appropriate. For small amounts of removal work (such as several floor tile or a cutting a hole in asbestos-containing drywall) where an enclosure is desired or needed, a glovebag can often be used in lieu of a full mini-enclosure. Polyethylene Drop Cloth Preparing a work area with a drop doth requires that a single layer of polyethylene be spread on the floor of the work area and taped or weighted in place. Do not use more than one layer if ladders ((* similar equipment) will be used, unless a hard surface, such as plywood is laid over the drop cloth. If floor is a soft material, such as carpet, use caution to prevent tearing of polyethylene under equipment The drop cloth should cover an area large enough to catch falling debris. If work is to be performed at an elevated level, the drop cloth should be placed on the work platform, or extended at ground level beyond the immediate work location to catch any debris that might be generated. Note that the use of a drop cloth introduces potential slip hazards in the work area. Non-slip foot coverings are recommended where drop cloths are used. Mini-Enclosure A mini-enclosure is usually a polyethylene enclosure around a work area. Mini-enclosures are sealed enclosures used as a secondary means to help, or attempt to, contain fibers or debris generated during the work. 41 Worker General Procedures 1992 NIBS between the change room and the area outside the change room. A curtain doorway is made of three overlapping sheets of polyethylene. Attach sheets to framework at top and one side. The middle sheet should be attached on one side, and the inner and outer sheets attached on the other side. A sheet of polyethylene approximately 5 feet by 5 feet (1.5 meters by 1.5 meters) or larger should be installed outside die change room for use as a step off area and as a place to put decontaminated materials removed from the work area. Mini-enclosures should be constructed with a ceiling of polyethylene if work will not be performed above the enclosure. If work is to be performed above the enclosure and the ceiling is not ACM, the enclosure should extend to and be sealed to the ceiling or grid system. If the enclosure is below an ACM finished surface, use one of the following methods: 1. If ACM cannot be contacted, iic enclosure Should be separated from the cJUag by a narrow space. 2. If ACM will withstand contact without damage and is in good condition, foam tape (1" (25mm) or thicker) can be placed on the top edge of the enclosure. Gently lift enclosure into place until sufficient contact is made to provide a seal to the surface. After enclosure is in place, check for, and clean up any debris generated by enclosure installation. Mini-enclosures should be set up with a negative pressure system as described below to reduce the possibility of fibers being released from the enclosure and to filter the air inside the enclosure. Negative Pressure System and HEPA Filtered Local Exhaust Ventilation: Note: Certain configurations of negative pressure systems (pressure differential systems) are covered by patents. The APM should review applicable patent information regarding use of these systems. This manual uses the term "negative pressure system" as a synonymfor "pressure differential system". Mini-enclosures Should be provided ^ with a negative pressure system to reduce the possibility of fibers being released from the enclosure during the work, and to filter inside air discharged from the enclosure. Negative pressure inside mini-enclosures is commonly provided by a High Efficiency Particulate Air (HEPA) filtered vacuum or by negative pressure machines, depending upon the size of the enclosure. The NIBS Asbestos Abatement and Management in Buildings: Model Guide Specifications Section 01513 "Temporary Pressure Differential '& Air Circulation System" gives guidance oh pressure differential systems and suggested rates of air circulation in terms of air changes per hour. A HEPA vacuum will usually provide sufficient negative pressure for a small enclosure. Larger enclosures might require a small negative pressure machine (HEPA filtered fan unit) to achieve a negative pressure inside the enclosure. A negative pressure system for a mini enclosure most commonly locates the HEPA vacuum or negative pressure machine outside the enclosure. The intake side of the unit is ducted to the enclosure through the vacuum hose or flexible duct material taped to a hole in the enclosure on the side opposite from the change room or as close as possible to where the work will be performed. The filtered exhaust side of the unit should be ducted to the outside if 43 Worker General Prxedures 1992 NIBS W`1Q~.contJnued W-11 Labels Requirements Include: OSHA 29 CFR l926S8(k)(2) requirement: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD Department of Transportation (DOT) requirement dots shipping paper and marking format, used with some exceptions (see Appendix I) is: RQ, (Reportable Quantity, if over 1 lb (.4 kg) friable asbestos) WASTE (For transportation of waste material, if applicable) WHITE ASBESTOS (or BLUE or BROWN) (Shipping name; asbestos descriptions; see below) MIXTURE (For asbestos mixed with a binder or filler, etc.) 9, (Class 9, Miscellaneous Hazardous Materials, includes asbestos) UN2590 (or UN2212, or UN2212), (United Nations Identification numbers for the 3 ' ">OT asbestos descriptions) PG HI (or II or II), (Packaging Groups for the 3 DOT asbestos descriptions; n and III are medium and minor, use n if mixed shipment) LTD QTY, (limited quantity, if applicable) 20 OZ (.6 kg) (Total quantity of material described; may abbreviate unit) DOT defines chrysotile, actinolite, anthophyllite and tremolite asbestos as "white asbestos," crocidolite asbestos as "blue asbestos," and amosite and mysorite asbestos as "brown asbestos." ~ NESHAP requirement neshap requires that readily visible and legible warning labels as specified by OSHA under 29 CFR 191Q.1001(jX2) or 1926.58 (kX2Xiii) be used on waste containers or wrapped materials (this is the same as the OSHA 29 CFR 1926.58 label listed above). Waste material to be transported off the facility site must also be labeled with the name of the waste generator and the location at which the waste was generated. Applying Lockdown Encapsulant A lockdown encapsulant should be applied to areas where ACM is removed. Lockdown encapsulates used should be tested per 1978 Battelle/EPA. report "Tests for the Evaluation of Encapsulants for Friable AsbestosContaining Materials". Encapsulants should be water resistant after curing and be Class "A" fire rated per ASTM 84-81A "Standard Method for Surface Burning Characteristics of Building Materials. Lockdowns need to be compatible with any materials that will be installed over the encapsulant Note that many lockdown encapsulants will act as an adhesive and could be objectionable on - some surfaces when dry. Care should be taken to avoid getting encapsulant on or in HVAC units, HEPA vacuums, and negative pressure machines. Lockdown is typically applied for O&M work using a garden sprayer. It should be applied in accordance with the manufacturers' recommendations in two light coats sprayed from opposite directions to seal all portions of surfaces including any exposed edges of remaining ACM. 45 Worker General Procedures 1992 NIBS s W-14~continu0d W-15 Place protective clothing, if contaminated, into a disposal bag and label as ACM waste. Wash hands, face and surface of respirator with clean water and disposable towels. Use caution to avoid breaking seal between respirator facepiece and face. Place disposable towels into a disposal bag. Remove respirator and follow procedures specified in Respiratory Protection Program for cleaning and storing respirator. Change respirator filters if needed or required and dispose of used filters as ACM. Put street clothes on and exit change room. Removal of Protective Clothing if a Shower is Available If a shower with waste water filtering for ACM is available, follow the applicable clothing removal procedure described above. Remove protective clothing in work area and put on a clean set of protective coveralls. Proceed to shower with respirator still in place. At shower facility, remove protectivecoveralls, folding inside cut during removal Place clothing, if contaminated, into a disposal bag and label 'as ACM waste. Shower completely, and remove and clean respirator while showering as described below. Street Clothes If street clothes are worn under protective clothing and are contaminated during the work, the street clothes should be HEPA vacuumed, removed during decontamination and placed into a labeled disposal bag. These street clothes should then be disposed of as ACM or taken to a facility that has equipment designed for cleaning asbestos-contaminated clothing. s' Removal of Respirator (if used) The procedures described below are based on the assumption that workers wearing respirators have been traired in the use of respirators and, for negative pressure respirators, fit tested, and enrolled in a medical surveillance program as part of a Respiratory Protection Program. Remove respirator after removing protective clothing (if used). Before removing respirator, wash hands, face and surface of respirator with clean water and disposable towels. Use caution to avoid breaking seal between kcapiraior iacepiece and face. Avoid getting water into filter cartridges of. respirator. Place disposable towels into a disposal bag. Remove respirator and follow procedures specified in Respiratory Protection Program for cleaning and storing respirator. Visual Inspection and Completing Air Monitoring Visual Inspection The apm should develop building-specific protocols for visual inspections following O&M work. A visual inspection should be conducted prior to the completion of air sampling to verify that all visible dust or debris has been cleaned up. The person performing the inspection can be a worker. If the APM or another person makes this inspection, they should wear the same type of personal protective equipment worn by the workers. If visible dust or debris remains, it must be cleaned up using wet wiping and/or HEPA vacuuming before clearance sampling is started. The EPA's Purple Book and the American Society for Testing and Materials (ASTM) "Standard Practice ibr Visual Inspection of Asbestos Abatement Projects" (Document E1368-90) provide visual inspection procedures that might be helpful in developing O&M inspection procedures. 47 Worker General Procedures 1992 NIBS W-17.~contimnd standard glovebags will melt if used on surfaces over 120-150 degrees Fahrenheit (50-65 degrees Celsius), special types of glovebags are available for use on high temperature piping or other surfaces. Other types of prefabricated removal enclosures include "glovebox" type enclosures, multiple glovebag assemblies, glovebags with selfsupporting frames, and glovebags that funnel waste into standard disposal bags. Check with equipment suppliers for information on these enclosures. As discussed in W9, glovebags might be used with a framework for O&M work on flat areas such as surfacing materials. Note that significant asbestos exposures to workers can result from the improper use of glovebags. Workers should obtain information on current regulatory requirements on glovebag use from the APM Procedure A. Glovebag Removal Procedures Check area where the work will be performed. If damaged ACM is present (broken lagging, hanging, etc.), wrap in polyethylene and cover polyethylene with strips of duct tape for reinforcement Place one layer of duct tape around the removal area where the glove bag will be attached. Also protect any damaged ACM outside the glovebag area that could be disturbed during die work. Slit top of the glove bag open (if necessary) and cut down die sides to accommodate the removal area. Place necessary tools into pouch located inride glove bag (or into a steew turned inside out). Tools needed typically include: scraper, bone saw, utility knife, disposable towels, nylon brush, abrasive pads, wire cutters, tin snips and pre-wened lag cloth. Cut lag cloth to sizes needed to cover any ACM that will remain after glovebag work is completed. Place one strip of duct tape along the edge of the open top slit of glove bag for reinforcement Place the glove bag around area to be worked on and staple top together through reinforcing duct tape. Provide 8-12" (200-300 mm) of space inside glovebag between removal surface and glovebag for working room. Secure glovebag to duct tape previously installed around removal area. Use smoke tube and aspirator bulb to test seal Place tube into water sleeve (two-inch [50 mm] opening to glove bag) squeezing bulb and filling bag with visible smoke. Remove smoke tube and twist water sleeve closed. While holding the water sleeve tightly, gently squeeze glove bag and look for smoke leaking out, (especially at the top and ends of the glove bag). If leaks are found, tape closed using duct tape and re-test. If a segodve pressure glovebag with a supporting framework and HEPA filtered makeup air port is being used, attach hose from an operating HEPA vacuum to glovebag to provide negative pressure in glovebag. Follow equipment manufacturer's instructions on use of negative pressure equipment Insert wand from garden sprayer with amended water through water sleeve. Duct tape water sleeve tightly around the wand to prevent leakage. Insert arms into glovebag sleeves. Remove any metal jacketing or covering over the area where removal is required using tin snips and/or wire cutters. Fold in any sharp edges to avoid cutting the bag. Pierce any painted coverings to permit water to soak into the ACM. 49 Worker General Procedures 1992 NIBS W-17.~continued W-18 procedure above) in tool pouch inside glovebag. Place frame and glovebag assembly below work location so that frame is close tot but not touching, ACM. Location and proximity of frame to ACM should allow for some movement without disturbing ACM during the work. Insert wand of garden sprayer with amended water into bag and seal in place. Cut hole in glovebag for negative pressure equipment hose. Negative pressure equipment could be a HEPA vacuum or small negative pressure machine. Install hose and seal in place. A prefilter might be needed to prevent any gross ACM debris from being drawn into the negative pressure device. Install a hose from an operating HEPA vacuum into the bag in a position where it can be used during the work. Turn on negative pressure device and smoke test all sides of glovebag frame unit to verify that negative pressure is present If sufficient negative pressure is not present reduce clearance between ACM and frame (if possible), or add additional negative pressure device(s). Insert hands into glove arms and wet ACM where work is required. Perform work as needed. Caution: If bag is overloaded with tools or other materials, bag might break or release from frame. HEPA vacuum and wet wipe tools and inside of bag. Adequately wet any ACM debris in glovebag. Slowly lower frame to allow tools to be removed from bag. Gently remove glovebag from frame and twist to form a neck. Evacuate air from bag using HEPA vacuum and tape bag closed Remove garden sprayer wand, negative pressure device hose, and HEPA vacuum hose and seal holes with duct tape. Place glovebag into a labeled 6 mil (0.15 mm) asbestos disposal bag and seal bag. Disposal of contaminated water Contaminated water from O&M activities should be disposed of in accordance with all applicable federal, state and local regulations. Filtering might be required If filtering is required water should typically be filtered through a maximum 5 micron (5 pm) water filter before discharging water into a sanitary sewer system, if permitted If a filter unit is not available at the work location, contaminated water can be put into leaktight drums and transported to a location with filtering equipment If a portable shower unit with filtering equipment is available, contaminated water can be emptied into the shower and filtered through the shower filter system. The NIBS Asbestos Abatement and Management in Buildings: Model Guide Specifications Section 01563 "Decontamination Units" includes a specification for filtering equipment. 51 Worker Genera! Procedures 1992 NIBS Si IV. Surfacing Materials Work Practices . +' * Section IV Surfacing Materials Work Practices Surfacing Materials Location Illustration..................................................................... 54 Code Levels Description 51 12 3 Moving one non-asbestos-containing ceiling panel below a plenum space that has exposed surfacing ACM .........................57 52 2 3 Attach component to an ACM finished surface that Is above a non-asbestos-containing ceiling......................................... 61 53 12 3 Work in ceiling plenum space where exposed surfacing ACM is present .................................................................................65 $4 12 3 Install wiring in plenum space where exposed surfacing ACM is present .................................................................................69 55 2 3 Attach item to ceiling finished with ACM......................................73 56 2 3 Repair or replace item In surface finished with ACM.................. 76 57 2 3 Cut or drill hole in surfacing ACM..................................................80 $8 1 Replace bulbs in light fixture attached to or in surface finished with ACM............................................................................ 85 S9 1 Clean room with exposed surfaces finished with ACM..............87 510 12 3 Repair damaged surfacing ACM....................................................... 89 511 12 3 Accessing through an ACM finished surface ....................... 93 512 12 3 Painting surfacing ACM ................................................................... 97 513 2 3 Accessing a contaminated light fixture........................................... 101 The accompanying illustration depicts typical applications of the above work practices. The following general notes should be reviewed by users of the surfacing work practices:1 1. Appendix G of OSHA standard 29 CFR 1926.58 states that "maintenance staff employees should be instructed: Not to remove ceiling tiles below asbestoscontaining materials without wearing the proper respiratory protection, clearing the area of other people, and observing asbestoswaste disposal procedures." 2. Alternative equipment that might be used for certain operations include: A. Self-supporting glovebag/frame assemblies as described in General Procedure W9. These provide additional control for level 2 activities, or might be used instead of a mini-enclo sure for some small level 3 operations. B. A funnel with a HEPA vacuum attached to the small end of the funnel might be used in some cases to contain debris. 55 Surfacing ACM Asbestos 0&M Work Practices 1992 NIBS i Wi iiik^rg^wc^gwos^^ : >.^^; :rv Summary 1 Summary Moving one non-asbestos-containing ceiling panel below a plenum space that has exposed surfacing ACM. This work practice covers situations where you need to look into the plenum above a non-asbestos-containing ceiling which is installed below exposed surfacing ACM or situations where you need to work on a non-ACM celling system below exposed surfacing ACM This is for individual small maintenance activities and should not be used for work such as replacing all ceiling panels in a room. Such ceilings may be contaminated by dust and/or debris from damaged surfacing ACM Note: Appendix G of OSHA standard 29 CFR 1926.58 states that "maintenance staff employees should be instructed: Not to remove ceiling tiles below asbestos-containing materials without wearing the proper respiratory protection, clearing the area ofother people, and observing asbestos waste disposal procedures", Personnel performing this work should be properly trained and protected Examples Level 1: A Move one non-ACM ceiling panel in a lay-in ceiling below exposed surfacing ACM in good condition to make observations. Level 2: A Install or replace an HVAC diffuser in non-ACM ceiling where plenum space contains exposed surfacing ACM in good or fair condition. B. Move or replace non-ACM ceiling panels in a lay-in ceiling below exposed surfacing ACM in good or fair condition. Level 3: A Install or replace light fixture in non-ACM ceiling where plenum space contains exposed surfacing ACM in poor condition. B. Move non-ACM ceiling panels to access plenum area where dust and/or debris from surfacing is present on top of ceiling. Related Work Practices $2 Attach item to an ACM finished surface that is above a ceiling. S3 Work in ceiling plenum space where exposed surfacing ACM is present $4 Install wiring in plenum space where exposed surfacing ACM is present Mil - Remove asbestos-containing ceiling panels in lay-in ceiling system. M13 Remove asbestos-containing ceiling tiles in spline ceiling system. M25 Remove section of asbestos-containing drywall or plaster. Worker One worker for Levels 1 and 2. Two workers for Level 3. A person with air Recommendations moi"tor*ng training might be required. This person can be one of the workers. t 57 Surfacing ACM Asbestos O&M Work Practices a 1992 NIBS SI Level 2 Moving one non-asbestos-containing ceiling panel below a plenum space that has exposed surfacing ACM Examples Level 2: A. Install or replace an HVAC diffuser in non-ACM ceiling where plenum space contains exposed surfacing ACM in good or fair condition. B. Move or replace non-ACM ceiling panels in a lay-in ceiling below exposed surfacing ACM in good or fair condition. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Appendix G o/OSHA standard 29 CFR 1926.58 states that "maintenance staff employees should be instructed: Not to remove ceiling tiles below asbestos-containing materials without wearing the proper respiratory protection, clearing the area of other people, and observing asbestos waste disposal procedures".1 1. Perform Pre-work activities on Level 2 Worker Checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Tools and materials needed for work on ceiling 3. Prepare work area with drop cloth. See General Procedure W9. .4 Place tools, equipment and materials needed onto drop cloth. 5. Carefully lift up ceiling panel while HEPA vacuuming around edges of panel. Keep panel as flat as possible while lifting panel, lift panel slightly above grid system and slowly slide panel to one side, leaving panel on top of an adjacent panel. 6. Lightly mist top side of ceiling where work will occur using garden sprayer with amended water. 7. Pick up any bulk debris on top of ceiling panels where work will occur and place into disposal bags. 8. HEPA vacuum ceiling suspension system and top side of ceiling where work will occur. 9. Wet wipe or HEPA vacuum'the underside of the panel which was moved. Carefully replace ceiling panel and perform work required and clean-up and tear-down steps on Level 2 Worker Checklist to complete work. * 59 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S2. Summary Attach component to an ACM finished surface that is above a non-asbestos-containing ceiling. Summary this work practice covers die procedures for attaching components to an ACM finished surface (such as spray-applied fireproofing) that is located above a non- asbestos-containing ceiling, this surface can be above an ACM or non-ACM ceiling. Examples Level 2: A. Removing a small area of ACM fireproofing using a negative pressure glovebag frame unit Level 3: K Attaching a pipe, ceiling or duct hanger to a deck or beam covered with ACM fireproofing, insulation or overspray. 8. Attaching a pipe, ceiling or duct hanger to an old acoustical plaster ceiling above a lay-in ceiling system. Related Work Practices $1 * Moving one non-asbestos-containing ceiling panel below a plenum space that has exposed surfacing ACM. S5Attach component to ceiling finished with ACM. $7 - Cut hole surfacing ACM. Worker Recommendations One worker is usually sufficient for Level 2. Two workers for Level 3. More workers may be needed for Level 2 and Level 3 to increase efficiency or for additional health and/or safety considerations. A person with air monitoring training might be required. This person can be a worker. 61 a Surfacing ACM a Asbestos O&M Work Practices a 1992 NIBS S2. Level 3 Attach component to an ACM finished surface that is above a non-asbestos-containing ceiling. Examples Level 3: K Attach a pipe, ceiling or duct hanger to a deck or beam covered with ACM fireproofing or insulation. B. Attach a pipe, ceiling or duct hanger to an old acoustical plaster ceiling above a lay-in ceiling system. Notes This work practice must be used in conjunction with General Procedures Wl, W9 and a herd 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with proper OAM work practicefor accessing type of ceiling present in work area. See Work Practices Mil, M13 or M25.1 Work Practice 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment A materials list). Scraper 2-3** (50-75 mm) wide stiff blade Stiff nylon bristle brushes Maintenance itemts) io be attached to surface N^n-AC?* surftdag repair material 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative pressure system and/or HEPA filtered local exhaust ventilation. See General Procedure W9. 4. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuum inside enclosure for vacuuming areas above ceiling. 5. Enter enclosure and obtain access through ceiling using 0 & M work practice selected (see note above sup 1). 6. HEPA vacuum area above ceiling within reach from access hole. 63 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS iHTaartaswi S3 Summary Work in ceiling plenum space where exposed surfacing ACM is present. Summary This work practice covers situations where work must be performed in a ceiling plenum space that has exposed surfacing ACM. Examples Level 1: (IfworidsUkrtytodistuihACM, use Level 2) A. Open or close one valve above ceiling where exposed fireproofing in good condition is present .8 Inspect HVAC mixing box below asbestos-containing fireproofing in good condition. Level 2: A. Install new conduit (attached to existing supports) in plenum space where exposed fireproofing in good condition is present B. Repair leak in non-ACM insulated water line above ceiling where exposed surfacing ACM is present C. Maintain HVAC mixing box below asbestos-containing fireproofing in good condition. Level 3: A. Replace HVAC mixing box above ceiling where dust or debris from surfacing ACMpresent 8. Repair piping below surfacing ACM in poor condition. Related Work Practices SI * Moving one non-asbestos-containing ceiling panel below a plenum space that has exposed surfacing ACM. S2 Attach component to an ACM finished surface that is above a ceiling. S4 Install wiring in plenum space where ACM is present M28 Remove HVAC filters in unit serving plenum space with exposed ACM. Worker Recommendations One worker is usually sufficient for Level 1 and Level 2. Two workers for Level 3. More workers may be needed to increase efficiency or for additional health andfor safety considerations. A person with air monitoring training might be required. This person can be a worker. 65 Surfacing ACM 1 Asbestos O&M Work Practices 1 1992 NIBS S3 Level 2 Work in ceiling plenum space where exposed surfacing ACM is present. Examples Level 2: A. Install new conduit in plenum space where exposed fireproofing in good condition is present B. Repair leak in water line above ceiling where exposed surfacing ACM is present C. Maintain HVAC mixing box below asbestos-containing fireproofing in good condition. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with proper OAM work practice far accessing type of ceiling present in work area. See Work Practices SI, Mil, M13 or M2S. Appendix G of OSHA standard 29 CFR 1926.58 states thatmmaintenance staff employees should be instructed: Not to remove ceiling tiles below asbestos-containing materials without wearing the proper respiratory protection, clearing the area of other people, and observing asbestos waste disposal procedures'.1 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipn.-ut and material,,, (see Oenerol Procedure W1 for standard tools, equipment and materials list). Maintenance item(s) required to perform work in plenum space. 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Obtain access above ceiling using O & M work practice selected (see note above step 1). 6. Pick up any bulk debris within reach on top of ceiling and place into disposal bags. 7. HEPA vacuum top side of ceiling within reach from access area. 8. HEPA vacuum and wet-wipe surfaces that will be contacted or item to be maintained or repaired. 9. Perform maintenance work required and clean-up and tear-down steps on Level 2 checklist to complete work. v. i 67 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS oass&Gs&LMsat* S4 > Summary Install wiring in plenum space where exposed surfacing ACM is present Summary This work practice covers situations where small amounts of wiring and/or conduit are being installed in a ceiling plenum space that has exposed surfacing ACM The procedures assume that the ACM wili not intentionally be disturbed during the work. Examples Level 1: A Installing new wiring in existing conduit that does not have overspray ACM on conduit Movement in conduit should not disturb ACM Level 2: A Install new conduit attached to existing support brackets. B. Reroute conduit that can be attached to existing support brackets. Level 3.* A Installing new plenum rated computer or telephone cables that will lay on top of ceiling. Related Work Practices si Moving one oon>asbestos-containing ceiling pane! below a plenum space that ^ exPse<^ surfacing acm $2 Attach component to an ACM finished surface that is above a ceiling S3 - Work in ceiling plenum space where exposed surfacing ACM is present Worker One worker for Level 1 and Level 2. Two workers may facilitate pulling wires Recommendations between two locations. Two workers for Level 3. A person with air monitoring training might be required. This person can be one of the workers. . *'* * 69 Surfacing ACM i Asbestos O&M Work Practices i 1992 NIBS S4. Level 2 Install wiring in plenum space where exposed surfacing ACM is present. Examples Level 2: A. Install new conduit attached to existing support brackets. B. Reroute conduit that can be attached to existing support brackets. C. Install new cables that will lay on top of ceiling where no dust or debris is present Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with proper O & M work practice for accessing type of ceiling present in work area. See Work Practices SI, MU, M13 or M2S.1 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Wiring and related tools 3. Prepare work area with drop cloth. See General Procedure W9. Set up multiple work areas if needed .4 Place tools, equipment and materials needed onto Vop clo'h. 5. Obtain access through ceiling using 0 & M work practice selected (see note above step 1). HEPA vacuum top side of ceiling within reach from access area. 6. Run wiring as required. Do not contact exposed ACM surfacing and minimize disturbance Of ceiling system and other components above ceiling while running wiring. 7. Perform clean-up and tear-down steps on Level 2 checklist to complete work. 71 Surfacing ACM i Asbestos O&M Work Practices 1992 NIBS S5 Summary Attach item to ceiling finished with ACM Summary This work practice describes die work required to attach an item to a ceiling finished with surfacing ACM, such as acoustical plaster or a decorative sprayed-on surface texture material. Examples Level 2: A. Attach a battery-powered smoke detector to acoustical plaster. B. Attach track lighting to an ACM finished ceiling where experience has proven a minimal disturbance will occur. Level 3: A Attach track lighting system to ACM finished ceiling. B. Install exposed conduit, junction boxes and light fixtures to ACM finished ceiling. C. Attach new folding door to acoustical piaster where structural modifications are not needed for support Related Work Practices $1 * Move one non-a$bestoscontaining ceiling panel below a plenum space that has exposed surfacing ACM. S2 - Attach component to an ACM finished surface that is above a ceiling. $7 Cut or drill hole in Surfacing ACM. S8 - Replace bulbs in light fixture attached to or in surface finished with ACM. Worker One worker for Level 2. Two workers for Level 3. More workers may be i -"ded Recommendations for certain Level 3 tasks. A person with air monitoring training might be required. This person can be one of the workers. 73 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS 9 5 Level 3 Attach item to ceiling finished with ACM Examples Lave! 3: A. Attach track lighting system to ACM finished ceiling. B. Install exposed conduit, junction boxes and light fixtures to ACM finished ceiling. C. Attach new folding door to acoustical plaster where structural modifications are not needed for support Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Appendix G to OSHA regulation 29 CFR 1926.58 states: 'The training program for the maintenance engineering staff should describe methods of handling asbestos-containing materials as well as routine maintenance activities that are prohibited when asbestoscontaining materials are involved. For example, maintenance staffemployees should be instructedNot to hang plants or pictures on structures covered with asbestos-containing materials."1 1. Perform Pre-work activities on Level 3 checklist 2. Special tools, equipment and materials: (See General Procedure W1 for standard tools, equipment and materials list). Item to be attached to ceiling and related tools 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative pressure system and/or HEPA filtered local exhaust ventilation. See General Procedure W9. 4. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuum inride enclosure for vacuuming areas above ceiling. 5. Enter enclosure and wet area on ceiling where item will be attached using garden sprayer with amended water. 6. Using hand tools (or power tools with attached HEPA vacuum) attach item to ceiling. If small holes are being drilled, they can be drilled through a wet sponge or shaving cream to control fiber release. If a wet sponge or shaving cream is not appropriate or adequate, scrape away surfacing to at least 1/2** [13 mm] beyond where hole is needed. Keep the hose of an operating HEPA vacuum within 6" [150 mm] of where scraping is occurring. Adequately wet scraping area and any dust or debris generated. Drill hole through substrate after ACM is removed. Adequately wet any dust or debris that is generated. Place all debris and sponges into ACM disposal bags. 7. Perform clean-up and tear-down steps on Level 3 checklist to complete work. 75 s Surfacing ACM i Asbestos 0&M Work Practices 1992 NIBS S6 Level 1 Repair or replace item in surface finished with ACM Examples Level 11 A. Replace light fixture in ceiling finished with ACM where a disturbance of ACM is not expected .8 Replace Venetian blinds attached to a surface finished with ACM. Notes This work practice must be used in conjunction with General Procedures Wl, W9 and a herd 1 Worker Checklist, The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with proper OAM work practice for accessing type ofceiling present in work area. See Work Practices MU, M13 or M2S.1 Work Practice 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Repair and/or replacement parts and tools as needed 3. Prepare work area with drop cloth, Of desired). See General Procedure W9. .4 Place tools, equipment and materials needed in work area or on drop cloth. 5. lightly mist area of surfacing within 6" [150 mm] of item to be repaired or replaced using garden sprayer containing amended water and allow water to soak in for several minutes. 6. Wet wipe exposed surfaces of maintenance item to be repaired or replaced. 7. Carefully perform repair work or remove and replace maintenance item. If item is to be removed, repaired, and then reinstalled, clean item with HEPA vacuum and/or wet wiping before reinstalling. If item will be disposed of, clean Of possible) using HEPA vacuum and/or wet wiping and dispose of as non-ACM waste. If visible debris is not removed, dispose of as ACM or as required by applicable regulations. 8. Collect any surfacing debris from repair/replacement work using HEPA vacuum. .9 Perform clean-up and tear-down steps on Level 1 checklist to complete work. %* 77 Surfacing ACM Asbestos 0&M Work Practices a @ 1992 NIBS S6. Level 3 Repair or replace item in surface finished with ACM Examples Level 3: A. Replace electrical panel attached to fireproofed column. 6. Replace access panel in ceiling finished with ACM. C. Replace HVAC unit attached to poor condition acoustical plaster ceiling. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate this work with proper OAM work practice for accessing type ofceiling present in work area. See Work Practices Mil, M13 or M2S.1 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools* equipment and materials: {See General Procedure Wl for standard tools, equipment and materials list). Repair and/or replacement parts and tools as needed 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative pressure system and/or HEPA filtered local exhaust ventilation. See General Procedure W9. .4 Place tools, equipment and materials needed into enclosure. Include a HEPA vacuum inside enclosure for use during the work. 5. Enter enclosure and lightly mist area of surfacing within 6" [150 mm] of item to be replaced using garden sprayer containing amended water and allow water to soak in for several minutes. 6. Wet wipe exposed surfaces of maintenance item to be repaired or replaced. 7. Carefully perform repair work or remove and replace maintenance item. If item is to be removed, repaired, and then reinstalled, clean item with HEPA vacuum and/or wet wiping before reinstalling. If item will be disposed of, clean Of possible) using HEPA vacuum and/or wet wiping and dispose of as non-ACM waste. If visible debris is not removed, dispose of as ACM or as required by applicable regulations. 8. Collect any surfacing debris from rcpair/replacement work using HEPA vacuum. 9. Perform clean-up and tear-down steps on Level 3 checklist to complete work. 79 i Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S7. Level 2 Cut or drill hole in surfacing ACM Examples Level 2: A. Install a few new conduits through fireproofed metal deck. B. Drill a bole through asbestos-containing decorative texture finish. C. Drill a bole using a drill with HEPA filtered dust collection. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Lerd 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun Coordinate work with proper OAM work practice for accessing type of ceiling present in work area. See Work Practices Si, Mil, M13. Appendix G to OSHA regulation 29 CFR 1926.58 states: "The training program for the maintenance engineering staff should describe methods of handling asbestos-containing materials as well as routine maintenance activities that are prohibited when asbestos-containing materials are involved. For example, maintenance stiff employees should be instructed: Not to drill holes in asbestoscontaining materials*1 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Scraper (if used) Hand tools, or power tools with HEPA filtered dust collection as required to cut bole. Wet sponge or shaving cream (if used) 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. If access above ceiling is required, obtain access using O & M work practice selected (see note above step 1). 5. If hole is being drilled through a surface, such as acoustical plaster, where back < side is inaccessible, use die procedures in step 6. If hole is being drilled through a surface, such as a fireproofed metal deck, where both sides are accessible, use the procedures in step 7. 6. A Install polyethylene sheet below removal location to catch any falling debris. B. Adequately wet area where hole is to be drilled. . 81 a Surfacing ACM s Asbestos O&M Work Practices 1992 NIBS S7 Level 3 Cut or drill hole in surfacing ACM Example Level 3: A. Drill or cut hole for pipe or duct chase using tools with or without HEPA filtered dust collection in an enclosure. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a herd 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate this work with proper 0 SlM work practice for accessing type ofceiling present in work area. See Work Practices SI, Mil, M13 or M2S. Appendix G to OSHA regulation 29 CFR 1926.58 states: 'The training program for the maintenance engineering staff should describe methods of handling asbestos-containing materials as well as routine maintenance activities that are prohibited when asbestos-containing materials are involved For example, maintenance staffemployees should be instructed Not to drill holes in asbestos-containing materials".1 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See General Procedure Wl for standard tools, equipment and materials list). Saaper Hand or power drill or saw. Power tools shall have HEPA vacuum attachment 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative pressure system and/or HEPA filtered local exhaust ventilation. See General Procedure W9. 4. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuum inside enclosure for use during the work. IF access above is required, obtain access using 0 & M work practice selected (see note above step 1). If surface to be drilled is above a ceiling, extend enclosure (if feasible) to within approximately 1/2" [13 mm] of surfacing ACM. 5. Enter enclosure. If hole is being drilled through a surface, such as acoustical plaster where back side is inaccessible, use the procedures in step 6. If hole is being drilled through a surface, such as a fireproofed metal deck, where both sides are accessible, use the procedures in step 7. 6. A. Inside enclosure, install polyethylene sheet below removal location to catch any falling debris. B. Adequately wet area where hole is to be drilled. 83 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S8 Summary Replace bulbs in light fixture attached to or in surface finished with ACM Summary This work practice covers procedures for replacing light bulbs in a fixture attached to a surface finished with ACM. Light fixtures attached to or in surfaces finished with ACM can cause damage to ACM if the fixtures are moved during maintenance work. Examples Level 1: A. Replace bulbs in recessed or pendant mount light fixtures attached to an asbestos-containing decorative texture finish or acoustical plaster ceiling where disturbance of ACM is unlikely. B. Replace bulbs in fixtures mounted on fireproofed surface where disturbance of ACM is unlikely. Related Work Practices $5 - Attach item to ceiling finished with ACM S10 - Repair damaged surfacing ACM S13 Access into contaminated light fixture. Worker One worker is usually sufficient Two or more workers may be needed to increase Recommendations efficiency or for additional health and/or safety considerations. A person with air monitoring training might be required. This person can be a worker. 85 Surfacing ACM Asbestos O&M Work Practices a 1992 NIBS S9. Summary Clean room with exposed surfaces finished with ACM Summary This work practice covers the procedures for cleaning a room with exposed surfaces finished with ACM. This room has been predetermined to not be contaminated or has previously been cleaned. This is not the procedure to use if a fiber release has occurred. See related work practices below. Examples Level 1: A. Routine cleaning in room with spray-applied acoustical plaster on walls or ceilings where there is no visible dust or debris. .8 Routine cleaning in mechanical room with exposed fireproofing in good condition where there is no visible dust or debris. Related Work Practices SIO - Repair damaged surfacing ACM. T6 Repair damaged thermal system insulation on a pipe. M8 Clean resilient asbestos flooring. M29 - Dean up debris from minor fiber release. Worker One worker. Recommendations ** i 87 a Surfacing ACM a Asbestos O&M Work Practices a 1992 NIBS S10 Summary Repair damaged surfacing ACM Summary This work practice covers the procedures for repairing small amounts of damaged surfacing ACM, such as acoustical plaster or fireproofing. The procedure assumes that the damage is in isolated areas not greater in size than the OSHA small scale, short duration project limits. Examples Level 1: A. Repair small hole in acoustical plaster ceiling or wall without disturbing surrounding plaster. 6. Repair small gouged area in asbestos-containing decorative texture finish without disturbing surrounding finish. Level 2: A Repair gouge marts in acoustical plaster ceiling where a small amount of damaged ACM is present B. Repair small area of delaminated acoustical plaster in good condition. Level 3: A Install fire rated enclosure over small area of damaged fireproofing. B. Trowel-on fireproofing to repair small water damaged area. C. Repair delaminated plaster in fair condition. Related Work Practices $2 Attach component to an ACT ' Sashed surface that is above a ceiling. 5 Attach item to ceiling finished with ACM. Worker Recommendations One worker is usually sufficient for Level 1 and Level 2. Two workers for Level 3. More workers may be needed to increase efficiency or for additional health and/or safety considerations. A person with air monitoring training might be required. This person can be a worker. 89 Surfacing ACM s Asbestos O&M Work Practices 1992 NIBS * S10 Level 2 Repair damaged surfacing ACM Examples Level 2: A. Repair gouge marks in acoustical plaster ceiling where a small amount of damaged ACM is present B. Repair small area of delaminated acoustical plaster in good condition. Notes This work practice must be used in conjunction with General Procedures WJt W9 and a Level 2 Worker Checklist, The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice 1. Perform pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Small stiff-bladed scraper Non-ACM repair materials & tools 3. Prepare work area with drop Cloth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Mist any damaged surfacing using garden sprayer containing amended water and allow water to soak in for several minutes. 6. With HEPA vacuum within several inches of damaged wca, remove any loose material by hand or wit t scraper. Cdll<** materia! disposal bags as it is removed. Remove material around edges of damaged area until well-adhered material is found, but do not remove beyond area protected by drop cloth. Mist removal area during removal of damaged material. 7. Repair damaged area using non-ACM and perform clean-up and tear-down steps on Level 2 checklist to complete work. . 91 Surfacing ACM a Asbestos O&M Work Practices 1992 NIBS S11 Summary Accessing through an ACM finished surface Summary This work practice covers the procedures for opening access doors (such as those used in a wall or ceiling to access valves or dampers) in ACM finished surfaces such as acoustical plaster or fireproofing. Examples Level 1: k Open access door in acoustical plaster ceiling that has been opened before. Ceiling or wall is in good condition and debris is not likely on door. Level 2: k Open access door in acoustical plaster ceiling where ACM is in fair condition and may be disturbed. Level 3: k Open access door that has surfacing material on flanges that will be disturbed when door is opened. B. Open access door in acoustical plaster or fireproofed surface where ACM is in poor condition or a significant amount of ACM debris may be present on back side of door. Related Work Practices $5 Attach item to ceiling finished with ACM. 36 Repair or replace item in surface finished with ACM. 87 Cut or drill hole in Surfacing ACM.. Worker One worker for Level 1 work. One or two workers for Level 2 depending upon Recommendations safety and efficiency considerations. Two workers for Level 3. A person with air monitoring training might be required. This person can be a worker. . 93 a Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S11 Level 2 Accessing through an ACM finished surface Example Level 2: A. Open access door in acoustical plaster ceiling where ACM is in fair condition and may be disturbed. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist, The worker checklist includes tasks that must be performed before these work practices are begun.1 1. Perform pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Sponge 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Using sponge or sprayer, wet any ACM on access door flanges that may be disturbed and allow water to soak in for several minutes. 6. Unlatch door and open door 1/4" to 1/2" [6mm to 13mm]. HEPA vacuum around edges of door. Slowly open door and HEPA vacuum any debris on door or any ACM disturbed while opening door. 7. Perform maintenance work required above or behind 'ccess door and then slowly close door until it is secured in place. .8 Perform clean-up and tear-down steps on Level 2 checklist to complete work. 95 Surfacing ACM Asbestos O&M Work Practices a 1992 NIBS S12. Summary Painting surfacing ACM. Summary This work practice describes the work required to paint small amounts of surfacing ACM, such as acoustical plaster or a decorative texture finish. Paint coats should be as thin as possible to prevent delamination of surfacing that may be caused by painting. This work may need to be treated as abatement work depending upon the type and condition of the surfacing. Depending upon the type, condition and inability of the ACM, this work may need to be treated as an abatement activity instead of O & M work. Examples Level 1: A. Repaint previously painted asbestos-containing acoustical plaster in good condition. No preparation of the surface is required. Level Z a. Paint asbestos-containing decorative texture finish that has not been previously painted. Level 3: A. Paint asbestos-containing acoustical plaster that has not been previously painted. B. Paint asbestos-containing fireproofing. Refated Work Practices Sto Repair damaged surfacing ACM. Worker One worker for Level 1 and Level 2. Two workers for Level 3. A person with Recommendations air monitoring training might be required. This person can be the worker. 97 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S12. Level 2 Painting surfacing ACM Example Level 2: A. Paint asbestos-containing decorative texture finish that has not been previously painted Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Paint tollers or low pressure airless sprayer, and other painting equipment 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Paint ceiling using sprayer or rollers. If rollers are used, try to contact each area of the ceiling only once to avoid damage to ACM. 6. When painting is completed, clean up any loose debris using wet-wiping andfar HEPA vacuuming and roll up drop cloth. Dispose of paint rollers as ACM. 7. Perform clean-up and tear-down steps on Level 2 checklist to complete work. .. 99 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS SI 3 - Summary Accessing a contaminated light fixture Summary Hus work practice covers procedures for accessing into a contaminated light fixture. The fixture might be attached to or in a surface finished with ACM* or be installed below surfacing ACM. Light fixtures attached to or in surfaces finished with ACM can cause damage to ACM if the fixtures are moved during maintenance work. Examples Level 2: K Replace bulbs In recessed fixtures where ACM surfacing material debris is visible inside fixture. B. Replace bulbs In pendant mount fixture where ACM debris is present inside or on top of fixture. Level 3: A Replace bulbs in fixtures where surfacing ACM will be disturbed. B. Replace bulbs in fixtures recessed in acoustical plaster ceiling located in a high ceiling public space. Related Work Practices 85 Attach item to ceiling finished with ACM. S8 Replace bulbs in light fixture attached to or in surface finished with ACM. S10 Repair damaged surfacing ACM. Worker One worker is usually sufficient. Two or more workers may be needed to increase Recommendations efficiency or for additional health and/or safety considerations. A person with air monitoring training might be required. This person can be a worker. . _ 101 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS SI 3 - Level 3 Accessing a contaminated light fixture Examples Level 3: A. Replace bulbs in recessed fixtures where surfacing ACM will be disturbed B. Replace bulbs in fixtures recessed in acoustical plaster ceiling located in a high ceiling public space. Notes Work Practice This work practice must be used in conjunction with General Procedures Wlr W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. 1. Perform Pre-work activities on Level 3 checklist. 2. Additional tools, equipment and materials: (See General Procedure W1 for standard tools, equipment and materials list). Replacement bulbs 3. Prepare work area with drop cloth and set up HEPA filtered local exhaust ventilation. See General Procedure W9. 4. Place tools, equipment and materials needed into work area. 5. Wet wipe the exposed surfaces of the fixture. 6. With HEPA filtered local exhaust ventilation operating, carefully replace light bulbs without jarring fixture. Gean up any dust or debris generated using HEPA vacuum and/or wet wiping. 7. Perform clean-up and tear-down steps on Level 3 checklist to complete work. w*' 103 Surfacing ACM a Asbestos O&M Work Practices a 1992 NIBS V. Thermal Systems Insulation (TSI) Work Practices .-.*** M33 i Level 1 Remove asbestos-containing caulking compound Example Level 1: A. Remove a small amount of pliable caulking compound No sanding will be performed Notes Work Practice This work practice must be used in conjunction with General Procedure W1 and a Level 1 Worker Checklist., The worker checklist includes tasks that must be performed before these work practices are begun. Use Work Practice M31 if HEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced. 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Scraper 2-3" (50-75 mm) wide stiff blade 3. Place tools, equipment and materials needed in work area. 4. Using utility knife or edge of scraper, cut away caulking and place into disposal bags. 5. Remove any residual caulking using scraper and knife and place caulking into disposal bags. 6. HEPA vacuum and/or wet wipe areas where caulking was removed 7. Pcucrm maintenance work and clean-up and tear-down steps on Level 1 checklist to complete work. . "*/ 260 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M33. Level 2 Remove asbestos-containing caulking compound Examples Level 2: A. Reglaze several small window panes. No sanding will be performed. B. Remove small amount of dry caulking compound. Notes This work practice must be used in conjunction with General Procedures W1, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 Work Practice 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Scraper 2-3" (50-75 mm) wide stiff blade Stiff nylon bristle brushes 3. Prepare work area with drop Cloth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Enter work area and adequately wet caulking to be removed using garden sprayer with amended water. $. Using utility knife or edge of scraper, cut away caulking and place into disposal bags. 7 Remove any residual caulking using scraper, knife and nylon brushes and piavc cauiking into disposal bags. 8. HEPA vacuum and wet wipe areas where caulking was removed. 9. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. t 261 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M34 Level 1 Clean room that has asbestos-containing dust Examples Level 1; A. Clean an office area where asbestos-containing dust has settled on furniture due to air distribution from a supply air plenum with fireproofing ACM B. Dean a mechanical room where dust is assumed to contain ACM from thermal systems insulation present in room. Notes Work Practice This work practice must be used in conjunction with General Procedures W2, W8 and a Level 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Use Work Practice M31 if HEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced.1 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Dusting materials (cloths, dusters, mops) that are damp or are treated with catatonic or anti-static dust attractant preparations. Furniture polish 3. Place Tools, equipment and materials needed in work area. 4. Using damp or treated dusting materials, clean surfaces beginning from die top of the room and working towards die floor. HEPA vacuum surfaces that are not easily cleaned with dusting materials. Surfaces that are not routinely cV?ioaI (such as blinds) shall be wet wiped or washed with disposable cloths, folding the cloth inward until it is dirty on all surfaces and a new cloth is needed Dispose of all dirty cloths and soiled dusting materials while still damp in ACM disposal bags. 5. Clean floor with HEPA vacuum. See General Procedure WS. 6. Apply new polish where needed using standard procedures. 7. Perform clean-up and tear-down steps on Level 1 checklist to complete work. 264 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M32 Level 3 Remove asbestos-wrapped wiring Examples Level 3: A. Remove damaged wiring in poor condition. 8. Remove asbestos wrapped wiring located in underground electrical vaults where wrapping is in poor condition. See APM8 regarding confined space precautions. Not$S This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 3 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Verify that approval has been receivedfrom the EPA ifwetting will not be used on electrical wiring to be removed.1 Work Practice 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (Set General Procedure W1 for standard tools, equipment and materials list). Electricians insulated gloves Screwdrivers Wire cutters Voltmeter 3. Prepare wo.* rrea *vjth drop clnth. met mini-enclosure and set up negative pressure system and/or HEPA filtered local exhaust ventilation. See General Procedure W9. Verify that electrical power to wiring is shut off and locked out. Test circuits using voltmeter. 4. Place tools, equipment and materials needed into enclosure. 5. Enter enclosure, put on insulated gloves and cut out exposed wiring to be removed. Roll up wiring and place into disposal bags. 6. Open any junction boxes or equipment as needed to remove wiring back to screw terminals or soldered connections. 7. Cut or disconnect wiring from terminals or connections. Place wiring into disposal bags. 8. HEPA vacuum any surfaces that were in contact with wiring and any suspect visible debris. 9. Perform maintenance work and'clean-up and tear-down steps on Level 3 checklist to complete work. 258 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M32 Summary Remove asbestos-wrapped wiring Summary This work practice covers the work required to remove small amounts of asbestoswrapped electrical wiring for O&M work. Examples Level 1: A. Remove wiring in good condition on single stage spotlight Level 2: A. Remove wiring in good condition on several stage spotlights. 6. Remove asbestos wrapped wiring located in underground electrical vaults where wrapping is in good condition. See APM8 regarding confined space precautions. Level 3: A. Remove damaged wiring in poor condition. 8. Remove asbestos wrapped wiring located in underground electrical vaults where wrapping is in poor condition. See APM8 regarding confined space precautions. Related Work Practices None Worker Recommendations One worker for Level 1 and Level 2. Two workers are recommended for Level 3 aiuVor if work occurs in a i .ufined space. Workers tv sained electricians with asbestos training to perform work. A person with air monitoring training might be required. This person can be the worker. w*' t 255 a Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M31 Level 2 Emptying and changing filter in HEPA vacuum or changing filter in HEPA fan unit Examples Level 2l A. Empty HEPA vacuum bag using localized engineering controls. B. Change filter in HEPA fan unit C. Change filter or bag in HEPA vacuum using a glovebag. N0t6$ Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Manufacturer's instructions for unit having filter or bag replaced Tools as needed to remove filter or bag Replacement filters or bags Glovebag and hand operated spray bottle 3. Prepare work area with drop doth and HEPA filtered local exhaust ventilation. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth, includiug HEPA vacuum or fan unit with filter or bag to be dunged. If wsitoble, Include an operable HEPA vacuum for deaning up any dost or debris from the filter change operation. If filter or bag will be changed using a glovebag, follow step 5A procedures. If a glovebag will not be used, follow step 5B procedures. 5. A Insert new bag or filter, wet wiping doths, and a hand-operated spray bottle into glovebag. Seal glovebag to unit to permit access to filter or bag inside glovebag. Open unit and adequately wet filter or bag. Remove filter or bag and place in corner of glovebag. Wet wipe inside of unit Install new filter or bag. Close unit and wet wipe inside of glovebag. Put wet wipes in corner of glovebag. Twist and tape glovebag to seal bag/filter/rags from spray bottle. Cut and remove glovebag from unit Place glovebag into a disposal bag. B. Carefully disassemble unit as needed to access filter and/or bag. Adequately wet filter and/or bag, remove from unit and place into disposal bag. Using operable HEPA vacuum or wet wiping, clean area where filter or bag was installed. 6. Install new filter and/or bag in unit, reassemble unit and perform clean-up and tear-down steps on Level 2 checklist to complete work. n* t 253 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M30 Level 3 Replace asbestos-containing gaskets Examples Level 3: A. Replace large pipe flange gasket 6. Replace gasket on boiler door. C. Replace well-adhered gasket Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9, W17 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with proper O &M work practice ifother ACM must be removed prior to gasket replacement. If active electrical equipment is in work area, delete wetting (if permitted by EPA)for this work.1 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See General Procedure Wl for standard toots, equipment and materials list). Scraper 2-3" (50-75 mm) wide stiff blade Stiff nylon bristle brushes Tools required to access or remove gasket Non-ACM replacement materials Glovebag 3. Prepare work -area with drop cloth, erect mini-enclosiv - and sa.t up teg?.ti"? pressure system and/or HEPA filtered local exhaust ventilatio ~ See General Procedure W9. 4. Place tools, equipment and materials needed into enclosure. 5. Enter enclosure and disassemble equipment as needed to expose entire gasket 6. A. If entire gasket can be contained in a glovebag, install glovebag over gasket Adequately wet gasket and remove gasket and debris using glovebag procedures. See General Procedure W17. B. If gasket cannot be contained in a glovebag, adequately wet gasket, set up HEPA filtered local exhaust ventilation, and remove gasket and debris. Use nylon brushes and scraper to clean surfaces to which gasket was attached. 7. HEPA vacuum and/or wet wipe surfaces to which gasket was attached. 8. Install new gasket, reassemble equipment and: perform maintenance work required and clean-up and tear-down steps on Level 3 checklist to complete work. . *'*' 251 Miscellaneous ACM Asbestos 0&M Work Practices i 1992 NIBS M30 - Level 1 Replace asbestos-containing gaskets Example Level 1: A. Replace small Dos-adhered gasket that can be removed intact Notes Work Practice This work practice must be used in conjunction with General Procedure W1 and a Level 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with proper O A.M work practice ifother ACM must be removed prior to gasket replacement.1 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Tools required to access gasket Non-ACM replacement materials 3. Place tools, equipment and materials needed in work area. .4 Disassemble equipment as seeded to expose entire gasket 5. Remove gasket and place into disposal bag. Wet-wipe flange where gasket was installed. 6. Install new gasket reassemble equipment and perform applicable steps on Level 1 checklist to complete work. 249 Miscellaneous ACM Asbestos O&M Work Practices 01992 NIBS M29. Level 2 Clean up debris from minor fiber release Examples Level 2: A. Clean up a small amount of debris from delaminated, abraded or damaged surfacing. B. Clean up a small amount of debris from damaged pipe insulation. C. Clean up a small amount of debris from damaged drywall. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W4 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with proper O &.M work practice to repair cause offiber release. t. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Scraper 2-3" (50-75 mm) wide stiff blade . Stiff nylon bristle brushes 3. Prepare work area with critical barriers. See General Procedure W4. 4. Place tools, equipment and materials needed into work area. 5. Adequately wet debris to be cleaned up using amended water. 6. Pick up any large pieces of debris and place into disposal bags. Use HEPA vacuum and wet wiping to clean up small debris and dust. 7. Wet wipe and HEPA vacuum all surfaces in contaminated area. 8. Perform any required repair work using appropriate work practice. Perform clean-up and tear-down steps on Level 2 checklist to complete work. 247 a Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS M29 Summary Clean up debris from minor fiber release Summary This work practice describes die procedures to be used to clean up a minor fiber release generated by surfacing, TSI or miscellaneous ACM. If a major fiber release occurs, the APM or an asbestos designer should develop cleanup procedures for the particular location and circumstances. Some regulations, such as AHERA, define maximum quantities for this activity. Regulations may also require that a fiber release report be prepared and made available to affected personnel. If fiber release needs Level 3 work practices, it should be treated as an abatement project, not as O&M work. Examples Level 1; A. Pick up small amount of ACM debris that will stick to a small piece of duct tape. Level 2: A Clean up a small amount of debris from delaminated, abraded or damaged surfacing. B. Clean up a small amount of debris from damaged pipe insulation. C. Dean up a small amount of debris from damaged diywall. Related Work Practices S10 Repair damaged surfacing ACM. T7 Repair damaged thermal system insulation on a boiler, duct or flue. Worker One worker. A person with air monitoring training might be required This Recommendations person can be the worker. ,* 245 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M28 Summary Remove contaminated filters in HVAC unit serving plenum space with exposed ACM Summary This work practice covers the procedures for removing asbestos contaminated filters in HVAC unit serving plenum space with exposed ACM. Examples Laval 2: A. Remove prefabricated sllp-in type filters from HVAC unit in mechanical room. B. Replace filters in HVAC unit in mechanical room with roll-type filters. Related Work Practices None Worker One worker. A second worker may be needed for large, roll-type filters. A Recommendations person with air monitoring training might be required. This person can be a worker. 243 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M27. Level 2 Remove asbestos-containing ductwork taping cloth Example Level 2l A. Remove a small amount of ductwork taping cloth in good condition to install new duct attached to existing ducts. Notes Work Practice \ This work practice must be used in conjunction with General Procedures Wl, W9, W17 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 11 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Tools and materials needed for duct work Glovebags Scraper 2-3" (50-75 mm) wide stiff blade Stiff nylon bristle brushes 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Insert tools needed into glovebag. Install glovebag over taping cloth to be removed. 6. Insert wand of garden sprayer with amended water or removal encapsulant into glovebag and adequately wet taping doth to be removed. 7. Using scraper inside glovebag, remove taping doth using glovebag procedures. See General Procedure W17. Wet removal area during removal. 8. Clean remaining visible debris off ductwork using scraper and nylon brushes. 9. HEPA vacuum and wet wipe area where tape was removed. 10. Seal and remove glovebags from ductwork and dispose ofas ACM waste. 11. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. 241 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M27 Summary Remove asbestos-containing ductwork taping cloth Summary This work practice covers the steps required to remove small amounts of asbestoscontaining duct tape from ductwork for maintenance work. Examples Level 1: A. Remove ductwork taping cloth with duct section. B. Remove loose pieces of ductwork taping cloth. Level 2: A. Remove a small amount of ductwork taping cloth in good condition to install new duct attached to existing ducts. Level 3l A. Replace damaged section of ductwork. B. Remove asbestos-containing paper-type duct wrap in poor condition. Related Work Practices M26 - Remove asbestos-containing flexible duct connector. Worker One worker is usually sufficient for Level 1 and Level 2. Two workers for Level Recommendations 3. Two or more workers may be needed to increase efficiency or for additional health and/or safety considerations. A person with air monitoring training might be required. This person can be a worker. 239 i Miscellaneous ACM Asbestos O&M Work Practices a ^ 1992 NIBS M26. Level 2 Remove asbestos-containing flexible duct connector Example Level 2: A. Remove flexible duct connector where it may be damaged during removal. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with proper 0 &M work practice for removing duct insulation ifneeded to accessfasteners attaching flexible connector in place.1 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure WJ for standard tools, equipment and materials list). Scraper 2-3" (50-75 mm) wide stiff blade Stiff nylon bristle brushes Manual or power screwdriver with screwdriver bits and hex head sockets 3. Prepare work area with drop cloth. See General Procedure W9. Also, install critical barriers in ductwork or HVAC unit adjacent to both sides of flexible connector (if possible). i. Place tools, equipment and materials needed into work area. 5. Adequately wet flexible connector with amended water or removal encapsulant 6. Unscrew all screws holding flexible connector in place. Place screws into disposal bag if they will not be reused. If screws are to be reused, dean with water and nylon brushes. 7. Rewet connector and metal flanges of flexible connector and slide off of ductwork. Pull connector out of space and package for disposal as ACM. 8. HEPA vacuum surfaces where flanges were attached and interior of ducts accessible at both sides where connector was installed. 9. Remove critical barriers if installed inride ductwork or HVAC unit 10. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. 237 Miscellaneous ACM i Asbestos 0&M Work Practices 1992 NIBS M26 Summary Remove asbestos-containing flexible duct connector Summary This work describes the work required to remove an asbestos-containing fabric flexible duct connector. Examples Level 1: A. Remove flexible duct connector with duct work. B. Remove flexible duct connector in good condition where connector will not be damaged. Level 2: A, Remove flexible duct connector where it may be damaged during removal. Level 3: A. Remove flexible duct connector in poor condition. Related Work Practices TIO Remove duct insulation above lay-in ceiling for maintenance work. Til Remove duct insulation above plaster or drywall ceiling for maintenance work. M28 * Remove contaminated filters in HVAC unit serving plenum space with exposed ACM. Worker One worker for Level 1 and Level 2. Two workers for Level 3. A second worker Recommendations may be needed for large connectors. A person with air monitoring training might bo required. This oerson ran be a worker. t 235 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M25. Level 2 Remove section of asbestos-containing drywall Example Level 2: A. Remove small area of asbestos-containing drywall in good condition using non-powered hand tools. Low dust Level expected Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 11 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list)* Hand tools as needed Pry bars 3. Prepare work area with drop Cloth. See General Procedure W9. .4 Place tools, equipment and materials needed onto drop cloth. 5. Adequately wet entire area of drywall to be removed using garden sprayer with amended water. 6. Cut around perimeter of area to be removed using hand tools. Wet cutting area with amended water during cutting. 7. If drywall remains attached to studs or subsu-ate, use pry bar to pull sheet out enough so ecr*. can t-e gripped handi 'fist cavity behind drywall and back side of drywall to oe removed with amended water. 8. Pull sheet out so sheet folds at fastener line or sheet is pulled away from fasteners. Adequately wet fold or holes from fasteners. 9. Repeat step 8 at other attachment points, remove drywall piece, and package for disposal. 10. Remove fasteners from studs or substrate and place into disposal bags. Clean any debris left on studs or substrate using amended water and nylon brush. 11. Pick up any debris and place into disposal bags. HEPA vacuum and wet wipe up any dust generated. 12. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. $ 233 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M24. Level 3 Cut or drill asbestos-containing drywall, plaster or drywall compound Example Level 3: A. Install conduit or ductwork through asbestos-containing drywall or plaster using power tools. NOt$S Work Practice This work practice must be used in conjunction with General Procedures W1, W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Appendix G to OSHA regulation 29 CFR 1926.58 states: The training program for the maintenance engineering staffshould describe methods ofhandling asbestoscontaining materials as well as routine maintenance activities that are prohibited when asbestos-containing materials are involved. For example, maintenance staff employees should be instructedNot to drill holes in asbestos-containing materials."1 11 1. Perform Pre-work activities on Level 3 checklist. 2. Additional tools, equipment and materials: (See General Procedure W1 for standard tools, equipment and materials list). Drill or saw (as needed) with HEPA filtered dust collection attachment Maintenance work materials. 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative pressure system and/or HEPA filtered locrj exhaust ventilation. See General Procedure W9. If back side of dryw 'll is acc enclose area if hole(s) will penetrate through wall. Provide negative air in backside enclosure if possible. A glovebag may be used as an enclosure for small work areas. .4 Place tools, equipment and materials needed into enclosure. Include a second HEPA vacuum for any power tools to be used for cutting or drilling. 5. Enter enclosure and mark area to be cut or drilled. 6. Adequately wet area to be cut using garden sprayer with amended water. 7. Cut new hole using utility knife, hole saw or drill. Power tools must have an operating HEPA vacuum attached during cutting. Wet the Cutting area using amended water during cutting or drilling. 8. Remove piece of cut drywall and place into disposal bag. 9. HEPA vacuum removal area and areas accessible from hole. 10. If dust or debris is generated op back side, insert wand of garden sprayer into back side of enclosure and adequately wet any dust or debris present Remove back-side enclosure, place into disposal bags, and wet wipe surfaces that were exposed inside enclosure. 11. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist to complete work. 231 a Miscellaneous ACM Asbestos O&M Work Practices a 1992 NIBS M24. Level 2 Cut or drill asbestos-containing drywall, plaster or drywall compound Examples Level 2: A. Install new electrical receptacle or ceiling junction box in asbestos-containing drywall or plaster using hand tools. B. Drill holes to attach conduit to asbestos-containing drywall or plaster using non-powered hand tools. C. Drill holes in asbestos-containing joint compound where drywall or plaster is non-asbestos. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. It is important that this work practice be validated to determine ifit provides the desired degree of worker and environmental protection. Level 3 might be necessary to perform this activity. Appendix G to OSHA regulation 29 CFR 1926.58 states: "The training programfor the maintenance engineering staffshould describe methods of handling asbestos-containing materials as well as routine maintenance activities that are prohibited when asbestos-containing materials are involved. For example, maintenance staff employees should be instructed: Not to drill holes in asbestos-containing materials*1 1. Perform Pre-work activities on Level 2 checklist. 2. Additional tools, equipment and materials: ;se General Proc dure Wl for standard tools, equipment and materials list). Hand drill or hole saw (as needed). Power tools should have HEPA filtered dust collection Maintenance work materials Wet sponges or shaving cream (if used) 3. Prepare work area with drop cloth. See General Procedure W9. If accessible, also install a drop cloth on back side of drywall if hole(s) will penetrate through wall. .4 Place tools, equipment and materials needed onto drop cloth. 5. Mark area to be cut or drilled. 6. Adequately wet area to be cut using garden sprayer with amended water. As alternate methods, holes can be drilled/cut through a wet sponge or shaving cream on both sides. 7. Cut new hole using utility knife, hand tools or power tools with HEPA filtered dust collection. Wet the cutting area using amended water during cutting or drilling. 8. Remove piece of cut drywall and place into disposal bag. If wet sponges were used, place sponges into disposal bag. .* 229 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M23 Level LconHnwd 7. Continue removing shingles one at a time following the steps used for the first shingle until area needed is removed. Place all shingles into disposal bags. 8. Pry up tabs on shingles immediately above removal area to facilitate installing new shingles. 9. HEPA vacuum or wet wipe removal area. Use HEPA vacuum where needed to clean up ACM. It may not be appropriate or necessary to use HEPA vacuum on non-ACM. 10. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. Use roofing cement on tabs of existing shingles to seal diem to new shingles. .# 227 Miscellaneous ACM ' Asbestos O&M Work Practices 1992 NIBS NI23 Level 1 -continued 7. HEPA vacuum or wet wipe removal area. Use HEPA vacuum where needed to clean up ACM. Do not use HEPA vacuum on fibrous non-asbestos containing materials (such as fiberglass roof insulation) unless necessary. 8. Perform maintenance work and clean-up and tear-down steps on Level 1 checklist to complete work. Use roofing cement on tabs of existing shingles to seal them to new shingles. * 225 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M23 Summary Remove asbestos-containing asphalt shingles Summary This work practice describes die work required to remove a small number of asbestos-containing shingles for maintenance or repair work. Examples Level 1: A. Remove asbestos-containing asphalt shingles to install a new vent stack. Level 2: A. Remove asbestos-containing asphalt shingles in poor condition to repair roof leak. Shingles are damaged to die extent that they have become friable. Related Work Practices M17 Remove and replace asbestos cement roof shingles. M22 - Remove asbestos-containing built-up roofing. Worker One worker is usually sufficient Two or more workers may be needed to increase Recommendations efficiency or for additional health and/or safety considerations. A person with air monitoring training might be required. This person can be a worker. 223 Miscellaneous ACM Asbestos O&M Work Practices a 1992 NIBS M22 Level 1 Remove asbestos-containing built-up roofing Example Level 1: A. Remove small section of damaged asbestos-containing built-up roofing to perform patching, repair or install equipment Notes Work Practice This work practice must be used in conjunction with General Procedure WJ and a Level 1 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Use fall prevention measures (including safety harnesses, a warning line system with safety monitor, and/or a motion stopping system) as required by OSHA for roofing work. Roofing removal work shall be completed before any penetrations through the roof deck are made. Coordinate work with OAM Work Practice S7 ifsurfacing is present on underside of deck. Use Work Practice M31 ifHEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced. 1. Perform fire-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure WJ for standard tools, equipment and materials list). Safety harness/warning line system and/or motion stopping system Hook knife Garden sprayer with amended water Scraper 2-3" (50-75 mm) wide stiff blade Replacement roofing materials and tools Rope for lowering bags 3. Place tools, equipment and materials needed in work area. If feasible and safe, adequately wet roofing to be removed. The use of wetting and amended water for roofing work should limited for the following reasons: A Wet roofing can create slip hazards B. Roofing mastic/cool tar/bitumen will not adhere to wet surfaces. C. Water can damage materials below the roof membrane. However, regulations (such as NESHAP) require that RACM be adequately wet in disposal bags or containers. 4. Cut around area to be removed using hand tools. Note that several layers may be present 5. Scrape up roofing and place into disposal bags. Remove any remaining roofing debris in removal area using scraper and place into disposed bags. Lower bags to ground. 6. HEPA vacuum or wet wipe removal area. Use HEPA vacuum where needed to clean up ACM. It may not be appropriate or necessary to use HEPA vacuum on non-ACM. 7. Perform maintenance/repair work and clean-up and tear-down steps on Level 1 checklist to complete work. 221 a Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS M21 . Level 3 Remove asbestos-containing fire door and/or door hardware Examples Level 31 A. Cut a door to install new window. B. Drill hole for new lockset through asbestos core of door. Notes Work Practice This work practice must be used in conjunction with General Procedures W1, W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment aod materials: (see General Procedure Wlfor standard tools, equipment and materials list). Tools needed to cut or drill door, with HEPA filtered dust collection attachment if possible. New lockset or window 3. Prepare work area with drop, erect mini-enclosure and set up negative pressure system and/or HEPA filtered local exhaust ventilation. See General Procedure W9. Enclosures can be installed at door location, or door can be removed and taken into an enclosure. 4. Place tools, equipment and materials needed into enclosure. 5. Wet area where hole will be cut or drilled. 6. Cut or drill door as required. Wet cutting or drilling location during work. 7. Place cut piece of door or debris from drilling into ACM disposal bags. HEPA vacuum or wet wipe new hole area and clean up any debris. 8. Install window or lockset and perform clean-up and tear-down steps on Level 3 checklist to complete work. 219 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M21 . Level 1 Remove asbestos-containing fire door and/or door hardware Examples Level 1: K Remove asbestos-containing fire door that is in good condition for replacement B. Replace lockset or closer on asbestos-containing fire door in good condition. Lockset does not penetrate asbestos core of door. Notes Work Practice This work practice must be used in conjunction with General Procedure W1 and a Level 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Use Work Practice M31 if HEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced.1 1. Perform Pre-work activities on Level 1 checklist Z Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Screwdriver and tools needed for hardware or door removal 3. Place tools, equipment and materials needed in work area. 4. If door is equipped with a closer, detach closer arm from door frame. Remove screws attaching closer to door. HEPA vacuum or wet clean screws, closer, and area where closer was attached to door. Thoroughly clean closer and parts if they will be re-used. If closer will not be re-used, dispose of as ACM waste. 5. Remove lockset from door using procedures used for closer. HEPA or wet wipe vacuum lockset if it will be re-used or dispose of as ACM waste. 6. Lay two layers of polyethylene sheet on floor for wrapping door. 7. Remove hinge pins or screws attaching hinges to door frame. Lay door on polyethylene. 8. If hinges are to be re-used, remove from door following procedures used for closer. If hinges are to be disposed of, leave hinges attached to door. 9. Wrap door for disposal. 10. Perform clean-up and tear-down steps on Level 1 checklist to complete work. 217 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M20 - Level 3 Remove asbestos-containing chalk board Example Level 3: A. Remove asbestos-containing chalkboard that is in poor condition or strongly adhered to wall. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See General Procedure Wl for standard tools, equipment and materials list). Scraper 2-3" (50-75 mm) wide stiff blade Stiff nylon bristle brushes Crow bar and screwdrivers 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative pressure system. See Gerund Procedure W9. Enclosure must be large enough to lay board on floor and wrap for disposal. 4. Place tools, equipment and materials needed into enclosure. 5. Enter enclosure and adequately wet chalkboard unit using garden sprayer with amended water. Spray water around sides of board and at joint between wall and top of board to wet any debris behind board. T Remove any fasteners or moldings attaching board to wall and remove board. Some boards lift up out of a supporting tray or off of supporting clips to remove. If board is adhered to wall use screwdrivers or crow bar to remove board. Wet adhesive using amended water while {Hying board off walL Wrap board in two layers of polyethylene sheet for disposal. 7. If board was attached with adhesive, wet and scrape remaining adhesive off wall. 8. Wet wipe and HEPA vacuum surface that board was attached to. 9. Perform clean-up and tear-down steps on Level 3 checklist to complete work. * 215 Miscellaneous ACM a Asbestos O&M Work Practices 1992 NIBS M20 Level 1 Remove asbestos-containing chalk board Example Level 1: A. Remove asbestos-containing chalkboard that is son-adhered and easily removed. Notes This work practice must be used in conjunction with General Procedure W1 and a Level 1 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Use Work Practice M31 tfHEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced. Work Practice 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Scraper 2-3" (50-75 mm) wide stiff blade Stiff nylon bristle brushes 3. Place tools, equipment and materials needed in work area. 4. Adequately wet chalkboard unit using garden sprayer with amended water. Spray water around sides of board and at joint between wall and top of board to wet any debris behind board. 5. Remove any fasteners or moldings attaching board to wall and remove board Some boards lift up out of a supporting tray or off of supporting clips to ... remove. '.Viap board in two layers of polyethylene sheet for disposal. If board is adhered to wall, a Level 2 or 3 procedure should be performed 6. HEPA vacuum surface that board was attached to. 7. Perform clean-up and tear-down steps on Level 1 checklist to complete work. * 213 Miscellaneous ACM Asbestos O&M Work Practices a 1992 NIBS Ml9 Level 3 Remove high temperature resistant (HTR) asbestos cement panels Example Level 3: A. Remove HTR asbestos cement panels in poor and friable condition inside a mini-enclosure. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See General Procedure Wlfor standard tools, equipment and materials list). Tools needed to remove panels and fasteners Spray encapsulant Of used) 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative pressure system. See General Procedure W9. 4. Place tools, equipment and materials needed into enclosure. Set up ladder or scaffold if needed. 5. Enter enclosure and adequately wet panels to be removed using spray mcapsulant or amended water. 6. Aenove ^ener$ iug panels in place. Wet or HEPA vacuum fasteners during removal. Pull panel away slightly, spray amended water on back of panel, remove panel and place into disposal bags or polyethylene lined cardboard boxes. Spray any loose or broken panel pieces with amended water and place into disposal bags. 7. Clean up any debris or dust using HEPA vacuuming and wet wiping. 8. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist to complete work. 211 a Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS Ml 9 Level 1 Remove high temperature resistant (HTR> asbestos cement panels. Example Level 1l A. Remove HTR asbestos cement panels in good condition that can be removed with minimal breakage. Notes Work Practice This work practice must be used in conjunction with General Procedure W1 and a Level l Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Use Work Practice M31 if HEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced.1 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Tools needed to remove panels and fasteners Spray encapsulant (if used) 3. Place tools, equipment and materials needed in work area and set up ladder or scaffold if needed. If desired, spray amended water or encapsulant on panels before starting removal. 4. Remove fasteners securing panels in place. Wet fasteners during removal. Remove panels and place icto disposal bags or wrap in polyethylene. 5. Clean up any debris a ^st using wet wiping or HEPA vacuum. 6. Perform maintenance work and clean-up and tear-down steps on Level 1 checklist to complete work. 209 a Miscellaneous ACM a Asbestos O&M Work Practices 1992 NIBS Ml 8 - Level 2 Remove and replace asbestos cement siding shingles Example Level A. Replace or remove asbestos cement siding shingles that are sufficiently damaged and may become friable during removal. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a herd 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 1. Perform Re-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials lid). Pry bars, slatter's ripper and/or nail clipper Replacement siding, if required Spray encapsulant Of used) 3. Prepare work area with drop cloth. See General Procedure W9. Drop cloth should be below removal area to catch any debris generated during removal. Set up ladder or scaffold if needed. Seal over any penetrations, air intakes or windows in work area with polyethylene. Do not cover over exhaust vents. 4. Place tools, equipment and materials needed onto drop cloth. 5. Apply spray encapsulant, to r adequately wet sidmo to to removed. 6. Starting at top of removal area, nails, cut nails or pry up edge of first panel until edges can be gripped by hand. Spray amended water on back of panel. Remove panel and place into disposal bags or polyethylene lined cardboard boxes and lower to ground level. 7. Continue removing panels using procedures in step 6. 8. Clean up any debris or dust using HEPA vacuuming and wet wiping. 9. Perform maintenance work and clean-up and tear-down steps on Level 2 . .checklist to complete work. .. i 207 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS - Ml 8 Summary Remove and replace asbestos-cement siding shingles Summary This work practice covers the procedures for removing small amounts of asbestos cement siding shingles from the exterior of a building to support O&M work. Examples Level 1: A. Replace or remove a small number of asbestos cement siding shingles in good condition that are loose or can be removed with minimal breakage to perform patching, repair work, or to install a new window or door. Level 2i A. Replace or remove asbestos cement siding shingles that are sufficiently damaged and may become friable during removal. Related Work Practices M14 - Cut or drill asbestos cement panels. M15 Remove cement asbestos panels. M17 Remove and replace asbestos cement shingles. M22 Remove asbestos-containing built-up roofing. Worker One worker is usually sufficient Two or more workers may be needed to increase Recommendations efficiency or for additional health and/or safety considerations. A person with air monitoring training might be required. This person can be a worker. .. -O' # 205 Miscellaneous ACM Asbestos O&M Work Practices 01992 NI68 T10 Level 2 Clean up asbestos-containing debris in crawispace or tunnel Examples Level Z* A. Clean up several pieces of pipe insulation debris in crawispace B. Clean up small amount of insulation debris in tunnel Notes Work Practice This work practice must be used in conjunction with General Procedures W1 and a LeveP 2 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Review confined space requirements with APM before start of work. See general procedure APM &1 1. Perform Pre-work activities on Level 2 checklist Z See general procedure W1 for standard tools, equipment and materials list. 3. Place tools, equipment and materials needed into work area. One worker should remain outside to communicate with inside worker and handle rescue arrangements, if needed. 4. Adequately wet floor area and debris in work area. 5. Starting near entry to area and working toward rear of area, pick up pieces of debris and place into disposal bags. 6. Adequately wet areas where debris was removed. Ur*: HEPA vacuum to remove any remaining debris. Place debris into disposal bg*. HEPA vacuum floor after gross debris is removed. 7. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. .w*- * 139 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T9 Level 3 Remove asbestos-containing insulation inside HVAC unit for maintenance work Note: tf a flexible connector must be removed, see Work Practice U26. Examples Level 3: A. Remove ACM pipe insulation in poor condition inside HVAC unit B. Remove duct insulation required to replace flexible connector. Notes This work practice must be used in conjunction with General Procedures Wl, W9, and W17 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 Work Practice 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See general procedure Wl for standard tools, equipment and materials list). Scraper (2-3" [50-75 mm] wide stiff blade) Stiff nylon bristle brushes Non-ACM replacement duct insulation Glovebags 3. Prepare work area with drop cloth, erect mini-enclosure and set up negativepressure system where feasible. See generalprocedure W9. 4. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuum inside enclosure for use during the work. 5. If work can be done with a glovebag method, follow procedures below: A. Enter enclosure and install duct tape around area to be removed. B. Place tools, equipment and other materials into glove bag. Attach glovebag to duct tape using more duct tape. C. Remove all loose or damaged insulation using glovebag procedures. See general procedure W17. D. Remove glovebag leaving duct tape from step 5b above. 6. If a glovebag method cannot be effectively utilized, follow procedures below: A. Install duct tape around insulation to be removed. B. Adequately wet insulation to be removed. C. Remove ACM while wetting removal area frequently with amended water. Keep hose of an operating HEPA vacuum adjacent to the removal area to capture any debris or fibers generated. 7. Perform clean-up and tear-down steps on Level 3 checklist to complete work. Leave duct tape installed in step 5 or 6 in place. 137 Thermal Systems insulation Asbestos O&M Work Practices 1992 NIBS T9 Summary Remove asbestos-containing insulation inside HVAC unit for maintenance work Summary This work practice describes the procedures to be used to remove small amounts off asbestos-containing duct or pipe insulation inside an HVAC unit Note: Ifa flexible connector must be removed, see Work Practice M26. Examples Level 2: A. Remove small amount of pipe insulation in .good condition using glovebag procedures to replace cooling or heating coil. Level 3: A. Remove ACM pipe insulation in poor condition inside HVAC unit B. Remove small amount of duct insulation as required to replace flexible connector. Related Work Practices T3 Remove asbestos-containing insulation on exposed pipe in elevated location for maintenance work T4 - Remove asbestos-containing insulation on pipe in occupied area for maintenance work T5 Repair damaged asbestos-containing insulation on a pipe T6 Repair damaged asbestos-containing insulation on a boiler, duct or flue 26 - Remove asbestos-containing flexible duct connector Worker Two workers. A person with air monitoring training might be required. This Recommendations Person can be a worker. 135 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T8- Level 2 Remove asbestos-containing duct insulation above ceiling for maintenance work Examples Level 2: A. Remove small amount of damaged insulation around damper control to permit insulation repair. - B. Replace Variable Air Volume (VAV) box on ACM insulated duct Notes This work practice mast be used in conjunction with General Procedures Wi, W9, and W17 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with proper O & M work practice for accessing type of ceiling present in work area. See work practices Mil, M12, M13 and M25.1 11 Work Practice 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see general procedure Wl for standard tools, equipment and materials list). Scraper (2-3" [50-75 mm] wide stiff blade) Stiff nylon bristle brushes Non-acm replacement duct insulation x Glovebags 3. Prepare work area with drop cloth. See generalprocedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Obtain access above ceiling using 0 & M work practice selected (see note above step 1). 6. Pick up any bulk debris within reach on top of ceiling and place into disposal bag. 7. HEPA vacuum top side of ceiling within reach from access hole. 8. Install duct tape around area to be removed. 9. Place all tools needed inside glovebag and attach glovebag to duct tape around area of duct insulation to be removed. 10. Remove ACM using glovebag procedures. See general procedure W17. Adequately wet removal area frequently during removal of bulk material. 11. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist and ceiling access work practice to complete work. Leave duct tape installed in step 9 in place. 133 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T7 Level 3~contimjed 7. If a glovebag method cannot be effectively utilized, follow procedures below: A. Adequately wet material at area to be penetrated or removed. B. Carefully remove or penetrate ACM. This procedure must only be performed on adequately wet material, and with a HEPA vacuum nozzle adjacent to die removal or penetrating tool so that any debris or fibers are captured by the HEPA vacuum. 8. Install device and perform clean-up and tear-down steps on Level 3 checklist to complete work. Leave duct tape installed in step 6 in place. .. W" # 131 Thermal Systems insulation Asbestos O&M Work Practices a 1992 NIBS T7 Level 2 Install device in, or access surface of, asbestoscontaining insulation on a pipe, insulated boiler, duct or flue Example Level 2l A. Remove ACM in good condition in order to install energy management system sensors and controls. Notes This work practice must be used in conjunction with General Procedures WJ, W9, and W17 and a Level 2 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Ifaccess above ceiling is needed, coordinate work with proper O & M work practice for accessing type of ceiling present in work area. See Work Practices MJJ, M13 or M25.1 Work Practice 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see generalprocedure Wlfor standard tools, equipment and materials list). Scraper (2-3" [50-75 mm] wide stiff blade) Stiff nylon bristle brushes Hand drill and drill bits or hole saw Non-ACM replacement insulation or patching material (if required) Device to be installed and related tools Glovebags 3. Prepare work area with drop cloth. See generalprocedure W9. 4. Place tools, equipment and materials needed onto drop cloth. If access above ceiling is required, obtain access using O & M work practice selected (See note above step l). 5. Attach duct tape around area where device will be installed. 6. Place tools needed into glovebag and attach glovebag to duct tape. 7. Remove or penetrate ACM as required using glovebag procedures. See general procedure W17. Adequately wet removal area frequently during removal of the bulk material. 8. Install device or perform maintenance. Perform clean-up and tear-down steps on Level 2 checklist to complete work. Leave duct tape installed in step 5 inplace. 129 Thermal Systems Insulation s Asbestos O&M Work Practices 1992 NIBS T6 L6V6I 3...continued 7. If a glovebag method cannot be effectively utilized, follow procedures below: A. Adequately wet material at area to be repaired. B. Cut out damaged TSI, trimming edges so straight square clean edges remain. This procedure must only be performed on adequately wet material, and with a HEPA vacuum nozzle adjacent to the cutting tool so that any debris or fibers are captured by the HEPA vacuum. C. Place ACM debris into disposal bags. 8. Remove glovebag and fill in repair area with non-ACM patching material. 9. Dip lag doth into water and squeeze out excess water. Apply lag cloth to area of insulation being repaired and smooth out using a wet sponge. 10. Perform clean-up and tear-down steps on Level 3 checklist to complete work. Leave duct tape installed in step 6 in place. 127 Thermal Systems insulation Asbestos O&M Work Practices 1992 NIBS T6 Level 2 Repair damaged asbestos-containing insulation on a boiler, duct or flue Examples Level 2: A. Repair small area of impact damaged insulation on duct or flue in good condition. B. Repair minor damage to boiler insulation around access hatch. Notes This work practice must be used in conjunction with General Procedures Wl and W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Ifaccess above ceiling is needed, coordinate work with proper O & M work practice for accessing type of ceiling present in work area. See Work Practices MU, M13 orM25.1 Work Practice 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see generalprocedure Wl for standard tools, equipment and materials list). Sponge Non-ACM insulation patching material Putty Knife Lag doth 3. Prepare work area with drop cloth. See general procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. If access above tciiing is required, obtain access above cdling using O & M work practice selected (see note above step 1). 5. Adequately wet area of insulation to be repaired where appropriate. 'HEPA vacuum damaged area to be repaired and any loose debris. 6. Fill in repair area with non-ACM patching material. 7. Dip lag cloth into water and squeeze out excess water. Apply lag cloth to area of insulation being repaired and smooth out using a wet sponge. 8. Perform clean-up and tear-down steps on Level 2 checklist to complete work. 125 Thermal Systems Insulation Asbestos O&M Work Practices a 1992 NIBS T5 Level 3 ..continued 7. If a glovebag method cannot be effectively utilized, follow procedures below: A. Adequately wet material at area to be repaired. B, Cut out damaged TSI, trimming edges so straight square clean edges remain. This procedure must only be performed on adequately wet material, and with a HEPA vacuum nozzle adjacent to the cutting tool so that any debris or fibers are captured by the HEPA vacuum. 8. Fill In repair area with non-ACM patching material. Dip lag cloth into water and squeeze out excess water. Apply lag cloth to area of insulation being repaired and smooth out using a wet sponge. 9. Perform clean-up and tear-down steps on Level 3 checklist to complete work. 123 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T5 Level 2 Repair damaged asbestos-containing insulation on a P|pe Examples Level 2: A. Repair small area of impact damage on pipe insulation in good condition. B. Repair minor damage to insulation on a pipe fitting. Notes This work practice must be used in conjunction with General Procedures W1 and W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Ifaccess above ceiling is needed, coordinate work with proper O &.M work practice for accessing type of ceiling present in work area. See Work Practices Mil, M13 or M2S.1 Work Practice 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see generalprocedure W1 for standard tools, equipment and materials list). Sponge Non-ACM insulation patching material Putty Knife Lag cloth 3. Prepare work area with drop cloth. See general procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. If access above ceiling is repaired, obtain act' above ceiling using 0 & M work practice selected (see note aboie step 1). 5. Adequately wet area of insulation to be repaired where appropriate. HEPA vacuum damaged area to be repaired and any loose debris. 6. Fill in repair area with non-ACM patching material. Dip lag cloth into water and squeeze out excess water. Apply lag cloth to area of insulation being repaired and smooth out using a wet sponge. 7. Perform clean-up and tear-down steps on Level 2 checklist to complete work. V*- * 121 Thermal Systems Insulation Asbestos O&M Work Practices i 1992 NIBS T4. Level 3 Remove asbestos-containing insulation on pipe in occupied area for maintenance work Examples Level 3: A. Repair leak In pipe riser of occupied computer room. B. Replace damaged insulation on piping in manufacturing plant during working hours. Notes This work practice must be used in conjunction with General Procedures Wl, W9, W17 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice If access above ceiling is needed, coordinate this work with proper O&M workpractice for accessing type of ceiling present in work area. See Work Practices MU, M13 or M25.1 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools* equipment and materials: (See generalprocedure Wl for standard tools, equipment and materials list). Scraper (2-3" [50-75 mm] wide stiff blade) Stiff nylon bristle brushes Replacement non-ACM insulation if required Pipe repair materials and tools Glovebags 3. Prepare work area with drop cloth, ciect mini-enclosure and set up negative pressure system. See generalprocedure W9. 4. Place tools, equipment and materials needed into enclosure. If work must occur above ceiling, include a HEPA vacuum inside enclosure for vacuuming areas above ceiling. 5. Enter enclosure and place all tools needed inside glovebag. If access above ceiling is required, obtain access above ceiling using O&M work practice selected (see note above step 1). Attach glovebag to area where pipe insulation will be removed. See general procedure W17. 6. Remove ACM using glovebag procedures. Adequately wet removal area frequently during removal of the bulk material. 7. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist to complete work. V** 119 a Thermal Systems Insulation Asbestos O&M Work Practices a 1992 NIBS T3 Level 3 Remove asbestos-containing insulation on exposed pipe in elevated location for maintenance work Examples Level 3: A. Remove insulation on 12" (305 mm) fitting in poor condition, 15 feet (4.5 m) above floor level to repair leak in steam line. B. Remove insulation on pipe adjacent to steel grate catwalk 30 feet (9 m) above floor in boiler room. C. Work practice may be reduced to Level 2 if fitted or specialty glovebags are used. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9, W17 and a Level $ Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See generalprocedure Wl for standard tools, equipment and materials list). Scraper (2-3" [50-75 mm] wide stiff blade) Stiff nylon bristle brushes Replacement non-ACM insulation if required Pipe repair materials and tools Glovebags Non-slip drop cloth 3. Prepare work area with drop cloth. Erect scaffold system using proper OSHA procedures. Care should be taken not to disturb the ACM. Erect mini enclosure on top of scaffold system and set up negative pressure system. See general procedure W9. The top floor layer in enclosure should be a non-slip drop cloth material. 4. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuum inside enclosure for vacuuming areas above ceiling. 5. Enter enclosure, place all tools needed inside glovebag and attach glovebag to area where pipe insulation will be removed. See general procedure W17. 6. Remove ACM using glovebag procedures. Adequately wet removal area frequently during removal of the bulk material. 7. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist to complete work. 117 Thermal Systems Insulation Asbestos 0&M Work Practices 1992 NIBS T3 Summary Remove asbestos-containing insulation on exposed pipe in elevated location for maintenance work Summary This work practice covers the procedures for removing small amounts of asbestoscontaining insulation on exposed piping in elevated locations (approximately 10 feet [3 m] or more above floor level). This procedure uses a scaffold as a work platform to reduce the safety hazards from working from a tall ladder. Examples Level 2: A. Repair small pipe leak in boiler room B. Install new ceiling mounted hot water heating unit in warehouse space fed . from existing piping. Level 3l A. Remove insulation on 12" (305 mm) fitting in poor condition, 15 feet (4.5 m) above floor level to repair leak in steam line. B. Remove insulation on pipe adjacent to steel grate catwalk 30 feet (9 m) above floor in boiler room. C. Work practice may be Level 2 if fitted or specialty glovebags are used. Related Work Practices T2 - Remove asbestos-containing insulation on pipe above panel ceiling for maintenance work. T4 - Remove asbestos-containing insulation on pipe in occupied area foi maintenance work. Worker Two workers. A person with air monitoring training might be required. This Recommendations person can be a worker. ^I 115 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS 12. Level 2 Remove asbestos-containing insulation on pipe above !ay-in panel ceiling for maintenance work Example Level 2l A. Remove pipe insulation above lay-in panel ceiling where insulation is in good condition, e.g., pipe leak. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9, W17 ^ and a Level 2 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with proper O &M work practice for accessing type ofceiling present in work area. See Work Practice Milt M13, or M25.1 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see general procedure Wl for standard tools, equipment and materials list). Scraper (2-3" [50-75 mm] wide stiff blade) Stiff nylon bristle brushes Replacement non-ACM insulation if required Pipe repair materials and tools Glovebags 3. Prepare work area with drop cloth. See generalprocedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Obtain access above ceiling using O & M work practice selected (see note above step 1). 6. Pick up any bulk debris within reach on top of ceiling and place into disposal bag. HEPA vacuum top side of ceiling within reach from access hole. 7. Place all tools needed inside glovebag and attach glovebag to area where pipe insulation will be removed. See generalprocedure W17. 8. Remove ACM using glovebag procedures. Adequately wet removal area frequently during removal of the bulk material. 9. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. /* 113 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T1 Level 3 Remove asbestos-containing insulation on exposed pipe for maintenance work. Examples Level 3: A. Removal of pipe insulation in poor condition, or metal or waterproofed jacketed insulation. B. Removal of pipe insulation that will not fit in a glovebag, or removal work on hot piping (>120). C. Work on hot piping may be reduced to Level 2 with the use of specialized or high-temperature glovebags or chambers. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9, W17 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See general procedure Wl for standard tools, equipment and materials list). Glovebags Replacement non-ACM insulation, if required Pipe repair materials and tools 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative pressure system. See generalprocedure W9. 4. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuum inside enclosure for vacuuming areas above ceiling. 5. Enter enclosure and place all needed tools inside of glovebag, (if pipe will fit in a glovebag) and attach glovebag to area of pipe insulation to be removed. Remove ACM using glovebag procedures. See generalprocedure W17. If pipe is hot or will not fit in a glovebag, set up HEPA filtered local exhaust ventilation and fellow glovebag removal sequence inside of mini-enclosure. 6. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist to complete work. 111 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T1 Summary Remove asbestos-containing insulation on exposed pipe for maintenance work. Summary This work practice covers the procedures for removing small amounts of asbestoscontaining insulation on an exposed pipe in an unoccupied area such as a boiler or mechanical room. The procedure assumes that the pipe insulation is accessible from a ladder or scaffold less than 10 feet (3 m) in height Examples Level 2: A. Removal of 1 standard glovebag of insulation in good condition to make a new connection to an existing pipe. B. Removal of insulation in good condition to replace a valve. Level 3: A. Removal of pipe insulation in poor condition, or metal or waterproofed jacketed insulation. B. Removal of pipe insulation that will not fit in a glovebag, or removal work on hot piping (>120). C. Work on hot piping may be reduced to Level 2 with the use of specialized or high-temperature glovebags or chambers. Related Work Practices T2- Remove asbestos-containing insulation on pipe above panel ceiling for maintenance work T3 - Remove asbestos-containing insulation on exposed pipe in elevated location for maintenance work T4 - Remove asbestos-containing insulation on pipe in occupied area for maintenance work T5 - Repair damaged system insulation on a pipe T7 - Install device in asbestos-containing insulation on a or excess surface of, pipe, boiler, duct or flue Worker Two workers. A person with air monitoring training might be required. This Recommendations person can be a worker. -O' * 109 a Thermal Systems Insulation a Asbestos O&M Work Practices a 1992 NIBS Section V. Thermal Systems Insulation (TSI) Work Practices Work Practices Location Illustration ..................................................................106 Code Leeds Description T1 2 3 Remove asbestos-containing insulation on exposed pipe for maintenance work................................................... 109 T2 2 3 Remove asbestos-containing insulation on pipe above ceiling for maintenance work............................ 112 T3 2 3 Remove asbestos-containing insulation on exposed pipe in elevated location for maintenance work..................... 115 T4 3 Remove asbestos-containing insulation on pipe in occupied area for maintenance wort:.................................... 118 T5 2 3 Repair damaged asbestos-containing insulation on a pipe............................................................................ 120 T6 2 3 Repair damaged asbestos-containing insulation on a boiler, duct or flue................................................................124 T7 2 3 Install device in or access surface of asbestos-containing insulation on a pipe, boiler, duct or flue............... .............. 128 T8 2 3 Remove asbestos-containing duct insulation above ceiling for maintenance work....................... 132 T9 2 3 Remove asbestos-containing insulation inside HVAC unit for maintenance work..............................:.................135 T10 23 Clean up asbestos-containing debris in crawlspace or tunnel.............................................................................. 138 Hie accompanying diagram illustrates typical applications of these work practices. The following general notes should be reviewed by users of the TSI work practices: , 1. ,Users should review General Procedure W17 (glovebag removal procedures) and be properly trained in the use of glovebags. Glovebags are used in most of the TSI work practices. Glovebags used should be tiie appropriate type for the size of tiie task, orientation of piping (or other materials), temperature of surface and other relevant factors. Other types of prefabricated contaminant devices that may be used in place of glovebags are briefly discussed in W17. 2. Materials that have had TSI removed should be sprayed with a lockdown encapsulant in accordance with General Procedure WU. 3. Many of the TSI work practices recommend the use of two workers. Safety considerations for many activities, as well as efficiency considerations will often necessitate the use of two workers. Two workers are recommended for work practices using mini-enclosures. Hie O & M program may also require that two workers be used for glovebag removal work. 107 Thermal Systems Insulation Asbestos O&M Work Practices a 1992 NIBS VI. Miscellaneous Materials Work Practices . *'*' * Section VI. Miscellaneous Materials Work Practices Work Practices Location Illustration..................................................................142 Code Levels Description Ml 12 3 Replacement of resilient asbestos floor tiles .............................146 M2 12 3 Replacement of vinyl sheet flooring with ACM backing..........152 M3 12 3 Penetrate resilient asbestos flooring and subfloor...................... 159 M4 1 Install new resilient flooring or carpet over resilient asbestos flooring............. ...................................... 163 M5 12 Install partition over resilient asbestos flooring ........................ 165 M6 1 Wet strip flow wax from resilient asbestos flooring..................168 M7 1 Dry or spray buffing resilient asbestos flooring........................ 170 M8 1 Cleaning resilient asbestos flooring .............................. 172 M9 12 3 Remove carpet over resilient asbestos flooring ........................ 174 M10 1 2 Clean potentially asbestos-contaminated carpet ........................ 178 Mil 12 3 Remove asbestos-containing ceiling panels in lay-in ceiling system ........................................ 181 M12 2 3 Remove asbestos-containing ceiling tiles attached with adhesive........................................................... 185 M13 12 3 Remove asbestos-containing ceiling tiles in spline ceiling system ..............................................................188 M14 2 3 Cut or drill asbestos cement panels ......................................... 192 M15 12 3 Remove asbestos cement panels................................................195 M16 1 2 Remove asbestos cement cooling tower louvers........................ 199 M17 1 2 Remove and replace asbestos cement roof shingles............ 202 M18 12 Remove and replace asbestos cement siding ............. ,...........205 M19 12 3 Remove high-temperature resistant (HTR) asbestos cement panels......................................................... M20 1 2 3 Remove asbestos-containing chalk board .................................212 M21 12 3 Remove asbestos-containing fire door and/or door hardware........................................................................ 216 M22 1 2 Remove asbestos-containing built-up roofing............................ 220 M23 1 2 Remove asbestos-containing asphalt shingles............................ 223 M24 2 3 Cut or drill asbestos-containing drywall, plaster or drywall compound............................................ 228 M25 2 3 Remove section of asbestos-containing drywall........................ 232 M26 12 3 Remove asbestos-containing flexible duct connector..................235 M27 1 2 3 Remove asbestos-containing ductwork taping cloth ..................239 M28 2 Remove contaminated filters in HVAC unit serving plenum space withexposed ACM.................................243 M29 1 2 Clean up debris from minor fiber release .......................... 245 M30 1 2 3 Replace asbestos-containing gaskets......................................... 248 M31 2 3 Emptying and changing filter in HEPA vacuum or changing filter in HEPA fan unit............................................ 252 M32 1 2 3 Remove asbestos-wrapped wiring..............................................255 M33 1 2 3 Removing asbestos-containing caulking compound ..................259 M34 1 Clean room that has asbestos-containing dust .......................... 263 The accompanying diagram illustrates typical applications of the above work practices. 143 Miscellaneous ACM Asbestos 0&M Work Practices 1992 NIBS Tnrunnri i i i rin [ The following dust suppression tools & techniques should be used where appropriate for work on miscellaneous ACM: A. A wet sponge can be used where small holes must be drilled in ACM. The sponge can be held over the location where the hole is needed and the hole can be drilled through the wet sponge. The sponge should help to keep any dust or debris wet B. The hose of an operating HEPA vacuum can be placed near the cutting point of a drill bit or other tools. C. Shaving cream can be sprayed over an area where ACM will be cut or drilled to contain dust or debris. Any shaving cream used in this manner should be disposed of as ACM after use. D. Tools with HEPA filtered dust collection attachments. 3. Glovebag removal procedures as described in General Procedure W17 may be appropriate for use in certain small O&M tasks involving miscellaneous ACM, such as the removal of a small area of floor tile where an enclosure is desired, changing the bag in a HEPA vacuum or removing a small amount of ductwork taping cloth. 4. If the O&M activity involves work on materials (such as asbestos cement board) that might have chemical residue present, any residue should be properly removed prior to the start of the O&M work. Cleaning might be necessary to reduce die possibility of a chemical reaction that could be caused by water, surfactants and/or other substances mixing with chemical residues during O&M vxA . # 145 Miscellaneous ACM Asbestos O&M Work Practices s 1992 NIBS Ml Level 1 Replacement of resilient asbestos floor tiles Examples Level 1: (RFCM Procedures see page 144) A. Replacement of several floor tiles that are loose or can be removed with minimal or no breakage, and tile and/or mastic does not become friable. B. Remove well-adhered tile and/or mastic that is not likely to become friable. Notes Work Practice This work practice must be used in conjunction with General Procedure W1 and a Level 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Use Work Practice MSI ifHEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced. Warning: Do not sandflooring or backing. 1. Perform Pre-work activities on level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Weighted scraper with long handle Wall scraper 2-3" (50-75 mm) wide stiff blade w/short handle Commerdal-type hand-held hot air blower or radiant heat source Safety glasses Weighted scraper with long handle Wet/dry type HEPA vacuum with hose and attachments with metal floor tool Garden sprayer with amended water Hammer Crushed dry ice (for procedure 5B) - approximately 1 lb (0.5 kg) per sq.ft (0.1 m2) 3. Place tools, equipment and materials needed in work area. 4. RFCM removal procedure is described in step 5A. An alternative non-RFCM procedure using dry ice is described in step 5B. 5. Clean the affected floor area with a wet/dry type HEPA vacuum and a metal floor attachment (no brush). Do not sweep. 6. A. Start the removal by carefully wedging the scraper in the seam of two adjoining tiles and gradually lifting the edge of the tile up and away from the floor. Try not to break pieces of the tile but continue to work the balance of the tile up by working the scraper beneath the tile and exerting both a forward pressure and a twisting action on the blade to promote release of the tile from the adhesive and the floor. Some tiles will release quite easily while others require varying degrees of force. When the adhesive is spread heavily or the tile is bonded tightly, it may easier to force the scraper through the tightly adhered areas by striking the scraper 147 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS Ml Level 2 Replacement of resilient asbestos floor tiles Example Level 2: A. Replacement of an area of badly damaged tiles that are sufficiently damaged that the tile and/or mastic will become friable during removal. Notes This work practice must be used in conjunction with General Procedures Wl, W4 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Use caution to prevent afire in the work area if heat sources are used.1 Work Practice 1. Perform Pre-work activities on Level 2 checklist 2. Special tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Commercial-type hand-held hot air blower or radiant heat source Safety glasses Heavy duty scraper with 4" (100 mm) blade and 6*-8**"(2 m) handle Weighted scrapper with long handle Wet/dry type HEPA vacuum with hose and attachments Hammer 3. Establish work area with banier tape. See General Procedure W4. A plastic drop cloth may be used for dirty tools and bagged waste, if desired. 4. Place tools, equipment and materials needed in work area. 5. Clean the affected floor area with a wet/dry type HEPA vacuum and a metal floor attachment (no brush). Do not sweep. 6. Start the removal by carefully wedging the scraper in the seam of two adjoining tiles and gradually forcing the edge of the tile up and away from the floor. Try not to break off pieces of the tile but continue to force the balance of the tile up while working the scraper beneath the tile and.exerting both a . forward pressure and a twisting action on the blade to promote release of the tile from the adhesive and the floor. Some tiles will release quite easily while others require varying degrees of force. When the adhesive is spread heavily or the tile is bonded tightly, it may prove easier to focce the scraper through the tightly adhered areas by striking the scraper handle with a hammer, using blows of moderate force while maintaining the scraper at a 25 to 30 degree angle to the floor. If you encounter areas where even the above methods will not remove the tiles, the removal procedure can be simplified by thoroughly heating the tiles with a hot-air blower or a radiant heat source until the heat penetrates through the tile and softens the adhesive. Caution: Heating resilient tile or mastic might produce toxic vapors and a respirator with organic vapor cartridges might be needed. 149 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS Ml Level 3 Replacement of resilient asbestos floor tiles Example Level 3 A. Remove tile and mastic with an aggressive mechanical method which renders it friable. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. t. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See General Procedure Wl for standard tools, equipment and materials list). Safety glasses Heavy duty scraper with 4" (100 mm) blade and 6'-8' (2m) handle Weighted scraper with long handle Wet/dry type HEPA vacuum with hose and attachments Low speed floor grinder (190 RPM or less) 3. Prepare work area with mini-enclosure (without floor ) and set up negative pressure system. See General Procedure W9. A glovebag may be used as an enclosure for small areas. 4. Place tools, equipment and materials needed into enclosure. 5. Adequately wet floor areas where tile and/or mastic will be removed. 6. Grind down high spots with floor grinder. Adequately wet any dust or debris generated by grinding. 7. HEPA vacuum affected floor area and wet wipe smooth portions of floor. Place disposable towels and debris into ACM disposal bags. 8. Perform clean-up and tear-down steps on Level 3 checklist to complete work. t 151 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M2. Level 1 Replacement of vinyl sheet flooring with ACM backing Examples Level 1: (RFCM Procedures see page 144)' A. Replacement of loose or perimeter-adhered vinyl sheet flooring with ACM backing. B. Replacement of adhered vinyl sheet flooring with ACM backing that can be removed using non-aggressive, primarily manual methods. Some separation of backing and wear layer will occur. Notes This work practice must be used in conjunction with General Procedure W1 and a Level 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Warning: Do not sandflooring or backing. Use Work Practice M31 ifHEPA vacuum needs maintenance, or ifbag orfilter needs so be replaced.1 Work Practice 1. Perform Pre-work activities on Level 1 checklist. 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Garden sprayer with amended water Stiff bladed wall or floor scraper Hook knife Wet/dry type HEPA vacuum with hose and attachments with metal floor tool 3. Place tools, equipment and materials needed in work area. 4. Removal Procedure: A. Remove any binding strips or other restrictive moldings from affected area. B. Clean the affected floor area with the HEPA vacuum cleaner using the metal floor tool. C. Make a series of parallel slices 4" to 8" (100-200 mm) apart through the flooring to be removed. D. Removal: Pry up the comer of a strip of flooring. As the strip is being removed, adequately wet (using amended water) the removal point to minimize any airborne dust particles. When done properly, the floor and tite back of die strip should be adequately wet. Do only one three-strip area at a time. Stand on the remaining floor covering or clean floor (do not stand on the felt). The sliced strip should be rolled around a core which will control the stripping angle to create a uniform tension. He or tape the removed material securely and place in disposal bags or containers for disposal. 153 Miscellaneous ACM Asbestos 0&M Work Practices 1992 NIBS M2. Level 2 Replacement of vinyl sheet flooring with ACM backing Example Level 2: A. Replacement of vinyl sheet flooring with ACM backing which is sufficiently damaged to be finable. Notes This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Warning: Do not sandflooring or backing.1 Work Practice 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Stiff bladed wall or floor scraper Hook knife Wet/dry type HEPA vacuum with hose and attachments 3. Install drop cloth if desired for dirty tools and bagged waste. See General Procedure W9. .4 Place tools, equipment and materials needed into work area. 5. Removal Procedure, Adhered Resilient Sheet Flooring: ru Remove any binding strips or other restrictive moldings from affected area. B. Clean the affected floor area with the HEPA vacuum cleaner using the metal floor tool. C. Make a series of parallel slices 4" to 8" (100-200 mm) apart through die flooring to be removed. D. Removal: Pry up the comer of a strip of flooring. As the strip is being removed, adequately wet (using amended water) the removal point to mlnimlTft any airborne dust particles. When done properly, the floor and the back of the strip should be adequately wet Do only one three-strip area at a time. Stand on the remaining floor covering or clean floor (do not stand on thefelt). The sliced strip should be rolled around a core which will control the stripping angle to create a uniform tensioa Tie or tape the removed material securely and place in disposal bags or containers for disposal. E. Remove and dispose of each strip in the above manner. Avoid walking on die exposed felt as much as possible. F. Occasionally, parts of the flooring will stick to die subfloor. This can often be eliminated by peeling in die opposite directioa The stiff-bladed scraper may aid in the removal or peeling of die flooring. If any residual felt backing remains on the subfloor, remove it in accordance with step 6G. # 155 Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS V M2 . Level 3 Replacement of vinyl sheet flooring with ACM backing Example Level 3: A. Removal of vinyl flooring with ACM backing using an aggressive mechanical method which renders the material friable. Notes This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Warning: Do not sandflooring or backing.1 Work Practice 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See General Procedure Wl for standard tools, equipment and materials list). Stiff bladed wall or flow scraper Hook knife Wet/dry type HEPA vacuum with hose and attachments 3. Prepare regulated area with mini-enclosure (or by enclosing room) and set up negative pressure system. See General procedure W9. 4. Place tools, equipment and materials needed into enclosure. x 5. Enter enclosure and remove flooring per procedures under step 6. 6. ^Removal rioceuure, Fully Adhered Resilient Sheet Flooring: A. Remove any binding strips or other restrictive moldings from affected area. B. Clean the affected floor area with the HEPA vacuum cleaner using the metal floor tool. C. Make a series of parallel slices 4" to 8M (100-200 mm) apart through the flooring to be removed. D. Wear layer removal: Pry up the comer of a strip of flooring, separating the backing from the wear layer. As the strip is being removed, adequately wet (using amended water) die delamination point to minimize any airborne dust particles. When done properly, the felt remaining on the floor and on the back of the strip should be thoroughly wet Stand on the remaining floor covering or clean floor (do not stand on the felt). The sliced strip should be peeled from the.backing by pulling or rolling around a core which will control the stripping angle to create a uniform tension (some resilient flooring wear layers might not be readily strippable and might require wet-scraping). lie or tape the removed material securely .and place in disposal bags or containers for disposal. E. Remove and dispose of each succeeding strip in die above manner. Avoid walking on the exposed felt as much as possible. 157 Miscellaneous ACM Asbestos O&M Work Practices > 1992 NIBS Summary M3 Summary Penetrate resilient asbestos flooring and subfloor This work practice covers the procedures for drilling or cutting boles in resilient asbestos flooring and the subfloor below. If die flooring is badly damaged it may be advisable to remove it, rather than drilling holes in it Note: AHEJRA states that maintenance staffemployees should be instructed not to drill holes in ACM. Only property trained employees should undertake such activities. Examples Level 1: A. Remove small amounts of resilient asbestos flooring covering to drill hole(s) in subfloor to attach object to floor or install a pipe or conduit Level 2: A. Drill or cut a few hole(s) in resilient asbestos flooring to install pipe or conduit Level 3: A. Drill or cut multiple holes in badly damaged resilient asbestos flooring. B. Cut hole in resilient asbestos flooring with power saw for square duct Related Work Practices mi Replacement of resilient asbestos floor tiles. M2 - Replacement of vinyl sheet flooring with ACM backing. M9 * Removal carpet over resilient asbestos flooring. Worker One worker for Level 1 work. One or Two workers for Level 2 depending upon Recommendations safety and efficiency considerations. Two workers for Level 3. A person with air monitoring training might be required. This person can be a worker. 159 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M3 Level 2 Penetrate resilient asbestos flooring and subfloor Example Level 2: A. Drill or cut a few hole(s) in resilient asbestos flooring to install pipe or conduit Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with proper OAM work practice for accessing type of ceiling present in work area ifdebrisfrom work may fall on ceiling below. See work practices SI, MU, M23 or M24.1 1. Perform Pre-work activities on Level 2 checklist. 2. Additional tools, equipment and materials: (See General Procedure Wl for standard tools, equipment and materials list). Drill or bole saw with HEPA vacuum attachment Small stiff-bladed scraper 3. Prepare work area with drop cloth covering work area except where holes are being drilled See General Procedure W9. If hole being drilled or cut is to penetrate through floor, an enclosure will be needed on the underside to catch any dust or debris *hat may fall to floor below. 4. Place tools, equipment anc -nateriais needed onto drop cloth. 5. Adequately wet area where penetration must be made using amended water and, if desired, cut out a piece of flooring larger than the hole to be made using utility knife and scraper. 6. Using drill or hole saw with wetting or attached HEPA vacuum, perform drilling or cutting operation. Wet all dust or debris generated using amended water. 7. Clean up dust and debris using HEPA vacuum and/or wet wiping and place disposable towels into disposal bags. 8. If hole was drilled through floor, wet any debris or dust in enclosure and underride. Package debris or dust as ACM waste. 9. Perform maintenance work required and clean-up and tear-down steps on Level 2 checklist to complete work. 161 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M4 Summary Install new resilient flooring or carpet over resilient asbestos flooring Summary This procedure covers the work required to prepare resilient asbestos flooring for the installation of new resilient flooring or carpet This procedure works with work practice M6 for stripping asbestos flooring and assumes that any damaged flooring has been repaired or replaced using applicable work practices such as Ml and M2. Example Level 1: A. New carpet being installed over well-adhered resilient asbestos floor tile or vinyl sheet flooring with ACM backing in good condition. Related Work Practices Ml - Replacement of resilient asbestos floor tiles. M2 - Replacement of vinyl sheet flooring with ACM backing. M6 - Wet strip floor wax from resilient asbestos flooring. M7 Buffing resilient asbestos flooring. M8 - Cleaning resilient asbestos flooring. Worker One worker is usually sufficient. Two or more workers may be needed to increase Recommendations efficiency or for additional health and/or safety considerations. A person with air monitoring training might be required. This person can be a worker. 163 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M5 Summary Install partition over resilient asbestos flooring Summary This work practice describe die procedures for installing a wall over resilient asbestos flooring that will remain in place. If flooring will be removed for wall installation, use work practice Ml or M2. Note: It may be more efficient to removeflooring using Ml or M2 and then install partition. Examples Level 1: A. Install partition over resilient asbestos flooring that is well adhered and in good condition. Level 2: A. Install partition over resilient asbestos flooring that becomes friable during die partition installation. Related Work Practices Ml * Replacement of resilient asbestos floor tiles. M2 * Replacement of vinyl asbestos sheet flooring with ACM backing. M3 Penetrate resilient asbestos flooring and subfloor. M4 - Install new resilient flooring or carpet over resilient asbestos flooring. Worker One worker. Two workers may be beneficial for erecting paction. A person Recommendations with air monitoring training might be required. Tltis person can be a worker .. ** * 165 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M5 Level 2 Install Partition over resilient asbestos flooring Example Level 2: A. Install partition over resilient asbestos flooring that becomes friable during die partition installation. Notes This work practice must be used in conjunction with General Procedures WJ, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice It might be more efficient to remove flooring using Ml or M2 and then install partition. 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure WJ for standard tools, equipment and materials list). Anchoring devices/equipment Non-asbestos adhesive 3. Prepare work area with drop cloth. Do not install drop doth where wall will attach to floor. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Using garden sprayer with amended water, adequately wet flooring area where work is to be done. 6. Level off any minor high spots on floor using scraper. Do sand or grind flooring. 7. Remove any damaged vinyl asbestos flooring in area of work using 0 & M work practice Ml or M2. 8. Fill any low areas using manufacturers recommended Leveling compound. 9. Install base plate of wall on full bed of adhesive and attach to floor using appropriate anchoring devices. 10. HEPA vacuum any chips or dust generated during fastening operation. 11. Complete installation of wall. 12. Perform cleanup and tear down steps on Level 2 checklist to complete work. 167 a Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS M6 Level 1 Wet strip floor wax from resilient asbestos flooring Example Level 1: A. Strip floor wax or finish coat from resilient asbestos flooring that is well- adhered and in good condition. Notes This work practice must be used in conjunction with General Procedure Wl and a Level 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice Stripping pads should be kept wet during use and rinsed thoroughly immediately after use and prior to storage. Dispose ofpads, ifcontaminated, as ACM waste in labeled disposal bags.1 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). "Caution - Wet Floor" signs Floor stripping machine Stripping Pads (least Abrasive pad possible) Buckets with water for rinsing Mops (for stripping, rinsing and polishing) Chemical stripper - recommended amount for area to be stripped Floor wax or finish Walk-off mats 3. Place tools, equipment and materials needed in work area. Place walk-off mats where required to prevent tracking of stripping solution to other areas. Position "Caution - Wet Floor" signs. 4. After proper mixing of stripping chemical, adequately wet floor by mop applying liberal amounts of the solution. Allow chemical to soak for amount of time recommended by manufacturer. If areas become dry, reapply solution to keep floor adequately wet 5. After wax or finish has softened, strip flooring using least abrasive pad and low speed setting (175-190 RPM maximum). Keep floor adequately wet during machine operation. Do not overstrip. Stop stripping when the old wax or finish is removed. Work small areas at a time. 6. Remove dirty stripping solution with wet vacuum or "strip" mop. 7. With "rinse" mop, apply liberal amount of clean water to area stripped and remove water with wet vacuum or mop. Repeat rinse procedures. 3. If some spots of wax or finish remain, restrip those areas. 9. If new flooring will be installed over the stripped floor, do not apply wax or finish. When applying new wax or finish, do so according to manufacturer's recommendations. 10. Perform clean-up and tear-down steps on Level 1 checklist to complete work. .. * * 169 a Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS M7 Level 1 Dry or spray buffing resilient asbestos flooring Example Level 1: (RFCM Procedures see page 144) A. Dry or spray buff the polish on resilient asbestos flooring to remove minor surface imperfections and restore gloss. Notes This work practice must be used in conjunction with General Procedure W1 and a Level 1 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice Dispose ofpads, ifcontaminated, as ACM waste in labeled disposal bags.1 1. Perform applicable pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list,% "Caution - Wet Floor" signs Floor buffing machine Buffing Pads (least abrasive - tan, red, or equivalent) Buckets with mop wringer Mops (for damp or spot mopping) Chemical cleaner Hand-held scraper Spray buffing compound, appropriately diluted, compatible polish and restorer chemical 3. Place tools, equipment and materials needed in work area. Position "CautionWet Floor" signs. 4. Pick up any large loose debris and place into disposal bags. Using scraper and water, remove all foreign matter from the finished surface (gum, tar, stickers, etc.). 5. Spot or damp mop to remove stains and spills. Mix chemical cleaner or restorer with water and apply according to manufacturers recommendations. Spot or damp mop to remove stains and spills. If dry buffing will be performed, apply restorer chemical as required. 6. Allow floor to dry thoroughly. 7. A. To spray-buff, spray small area wife spray-buff solution and buff using manufacturer's recommended pad or brush at recommended RPM. Repeat procedure until entire area is spray-buffed. B. To dry buff, buff or dry burnish wife manufacturer's recommended pad or brush at recommended RPM. 8. Perform applicable steps on Level 1 Checklist to complete work. * 171 a Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS M8 Level 1 Cleaning resilient asbestos flooring Example Level 1: A. Dean or scrub resilient asbestos flooring with adequate coats of floor polish on flooring before buffing or application of additional polish. Notes Work Practice This work practice must be used in conjunction with General Procedure W1 and a Level 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun.1 2 3 4 5 6 7 8 9 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). "Caution - Wet Floor" signs Floor scrubbing machine, Pads (least abrasive) Buckets with mop wringer Scraper 2-3" (50-75 mm) wide stiff blade Mops (for scrubbing, rinsing) Measuring device for mixing chemical cleaner Walk-off mats Chemical cleaner 3. Place tools, equipment and materials needed in work area. Place walk-off mats to prevent tracking of scrubbing solution to other areas. Position "Caution - Wet Floor" signs. 4. Install polyethylene sheet on adjoining floors for protection from any spilled cleaning solution. 5. Mix scrubbing chemical with water as recommended by manufacturer and apply liberal amount (do not flood) using mop. Allow to soak for amount of time recommended by manufacturer. Keep floor adequately wet by reapplying 0 cleaning solution if drying occurs. Work small areas at a time. 6. Using floor scrubbing machine, manufacturer's recommended pads and operating speed, clean floor to remove embedded dirt and surface marks. 7. Remove spent scrubbing solution with wet vacuum or mop. 8. Rinse area using clean mop and clean rinse water. Remove water with wet vacuum or mop. Damp mop area to clean up any remaining water or streaks. 9. Perform applicable steps on Level 1 checklist to complete work. 173 Miscellaneous ACM Asbestos 0&M Work Practices 1992 NIBS M9 i Level 1 Remove carpet over resilient asbestos flooring Example Level 1: A. Remove carpet that is non-adhered or weakly adhered to resilient asbestos flooring. Notes This work practice must be used in conjunction with General Procedure WJ and a Level 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice Review manufacturer's recommendation concerning installation ofnew carpet over old flooring and/or adhesive before proceeding with this work. Ifasbestos-containing adhesive must be removed, refer to weUscraping procedures in Work Practice ML Use Work Practice M31 ifHEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced.1 2 3 4 5 6 7 8 9 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Metal straightedge for use when cutting carpet Scraper 2-3" (50-75 mm)1 wide stiff blade 3. Place tools, equipment and materials needed in work area. 4. Find a seam or corner where carpet removal can begin. If no seams or comers exist make a cut around the piece to be removed Cut carpet using utility knife with a new blade. 5. Pry up comer or seam of carpet using scraper. Pull back a section large enough (approximately one square foot [0.1 m2]) to hang onto while removing carpet HEPA vacuum exposed flooring and back of carpet 6. Pull carpeting back slowly and HEPA vacuum exposed flooring & back of carpet Remove carpet in pieces no larger than 200 square feet (18.6 m2). 7. If carpet and adhesive are non-ACM, roll up carpet and dispose of as nonACM waste. If portions of asbestos-containing flooring remain attached to carpet backing, dispose of carpet as ACM or in accordance with applicable regulations. 8. HEPA vacuum surface of flooring after carpet is removed If residual asbestos-containing adhesive or residual felt backing needs to be removed follow wet-scraping procedures in work practice Ml or M2, respectively. Allow substrate to dry before installing new flooring. 9. Perform clean-up and tear-down steps on Level 1 checklist to complete work. # 175 i Miscellaneous ACM Asbestos 0&M Work Practices 1992 NIBS VLea^S^i&!buJu:.si.iXT*^ Aa&H - ^ ^Baato u.-ux^^ *-* M9. Level 3 Remove carpet over resilient asbestos flooring Example Level 3: A. Remove carpet adhered to poor condition or loose resilient asbestos flooring and/or mastic that will break, tear or become friable during removal. Notes This work practice must be used in conjunction with General Procedures Wlt W9 and a Level 3 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Review manufacturer's recommendation concerning installation ofnew carpet over oldflooring and/or adhesive before proceeding with this work. Ifasbestos-containing resilientflooring adhesive must be removed refer to wet-scraping procedures in Work Practice Ml. Avoidfoot traffic on any exposed mastic.1 2 3 4 5 6 7 8 9 10 11 Work Practice 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See General Procedure Wl for standard tools, equipment and materials list). Scraper 2-3" (50-75 mm) wide stiff blade Metal straightedge for use when cutting carpet Latex paint in airless sprayer 3. Prepare work area with erect mini-enclosure and set up negative pressure system. See General Procedure W9. 4. Place tools, equipment and materials needed into enclosure. 5. If carpet is, or will be contaminated after removal, spray with latex paint to encapsulate and discourage reuse. 6. Enter enclosure and find a seam or comer where carpet removal can begin. If no seams or comers exist, make a cut around the piece to be removed. *Wet the areas that need to be cut using amended water. Cut carpet using utility knife with a new blade. 7. Pry up comer or seam of carpet using scraper. Pull back a section large enough (approximately one square foot [0.1 m1]) to hang onto while removing carpet Adequately wet flooring and adhesive exposed. 8. Pull carpeting back slowly and spray amended water on flooring and adhesive as they are exposed. Remove carpet in pieces no larger than area inside mini enclosure. 9. If carpet and adhesive are non-ACM, roll up carpet and dispose of as non- ACM waste. If portions of asbestos-containing flooring remain attached to carpet backing, dispose of carpet as ACM. Loose vinyl asbestos flooring shall be disposed of in disposal bags or containers. 10. HEPA vacuum surface of flooring after carpet is removed. If residual asbestos-containing adhesive or residual felt backing needs to be removed, follow wet-scraping procedures in work practice Ml or M2, respectively. Allow substrate to dry before installing new flooring. 11. Perform clean-up and tear-down steps on Level 3 checklist to complete work. 177 Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS M10 Level 1 Clean potentially asbestos-contaminated carpet Example Level 1: A. Clean potentially asbestos-contaminated carpet that has do viable contamination or analytical confirmation of asbestos contamination. ACM in room is in good conditioa Notes This work practice must be used in conjunction with General Procedure W1 and a Level 1 Worker Checklist, The worker checklist includes tasks that must be performed before these work practices are begun. EPA's Green Book indicates that routine use of a special cleaning work practice is not required & asbestos-containing dust or debris is not present and deterioration or damage to ACM is unlikely. While NIBS is not recommending its use as a routine mandatory asbestos control procedure in this case, the Level 1 work practice is being providedfor those operations and maintenance programs which choose to use it. Work Practice Use Work Practice M31 ifHEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced.1 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure WI for standard tools, equipment and materials list). Carpet attachment for HEPA vacuum 3. Place tools, equipment and materials needed in work area. 4. HEPA vacuum carpet using carpet attachment 5. Perform applicable steps on Level 1 checklist to complete work. 179 a Miscellaneous ACM a Asbestos O&M Work Practices a <3 1992 NIBS Mil Summary Remove asbestos-containing ceiling panels in lay-in ceiling system Summary This work practice covers the procedure for removing a small number of asbestoscontaining ceiling panels in a lay-in ceiling system, such as a 2* x 4* or 2" x 2' (600 x 1200 mm or 600 x 600 mm) suspended ceiling for O&M work. The practices assume that surfacing ACM is not present above the ceiling. If surfacing is present, see work practice SI. Examples Level 1; A. Move one or several panels in good condition that do not offer resistance to being moved, and where edges do not abrade. Level 2l A. Remove several asbestos-containing ceiling panels to perform maintenance work on or above ceiling where the panel(s) offer resistance to being moved and/or die edges are or will be abraded. Level 3: A. Remove damaged, broken, or soiled asbestos-containing ceiling panels alone or in conjunction with maintenance work above ceiling. Related Work Practices si Move one non-asbestos-containing ceiling panel below a plenum space that has exposed surfacing ACM. M12 - Replace **jg*2 ^niaining ceiling tiles attached with adhesive. MU - Replace asbestos-containing ceiling tiles in spline ceiling system. Worker One worker for Level 1 wort One or two workers for Level 2 depending upon Recommendations safety and efficiency considerations. Two workers for Level 3. A person with air monitoring training might be required. This person can be a worker. 181 Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS Mil .Level2 Remove asbestos-containing ceiling panels in lay-in ceiling system Example Level 2: K Remove several asbestos-containing ceiling panels to perform maintenance work on or above ceiling where the panel(s) offer resistance to being moved andtor the edges are or will be abraded. Notes This work practice must be used in conjunction with General Procedures Wl, W9 and a herd 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice Coordinate work with 0 AM Work Practice SI ifsurfacing ACM is present above ceiling. 1. Perform Pre-work activities on Level 2 checklist 2. Additional special tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Stiff nylon bristle brushes Non-asbestos replacement ceiling panels, if needed 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. Set up ladder or scaffold and rdequaely wet ceiling panei($), if panel(s) will be replaced. 5. If panel(s) will le replaced, remove ceiling panel(s) and place into disposal bag. If panel(s) will be reinstalled, remove carefully and store for reinstallation. 6. HEPA vacuum area where panel(s) were installed. Wet wipe any suspension system components exposed where panel(s) were removed. Use brushes to remove any debris that is not removed by wet wiping. Place wet wipes and any debris into disposal bags. 7. Perform clean-up and tear-down steps on Level 2 checklist to complete work. 183 a Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS Ml 2 Summary Remove asbestos-containing ceiling tiles attached with adhesive Summary This work practice covers,the O&M procedures for removing a small number of asbestos-containing ceiling tiles attached with adhesive. These most commonly are 12" (13 mm) tiles glued to a substrate such as gypsum board or plaster. The procedures assume that the tile adhesive does not contain asbestos. Examples Level 2: A. Remove ceiling tiles that can be removed as whole dies without breakage. Small pieces of tile may remain attached to adhesive on ceiling. Level 3: A. Remove ceiling tiles that will break during removal. B. Remove badly damaged ceiling tiles. Related Work Practices Mil - Remove asbestos-containing ceiling panels in lay-in ceiling system. M13 Remove asbestos-containing ceiling tiles in spline ceiling system. M24 Remove section of asbestos-containing drywall. Worker One or two workers for Level 2 depending upon safety and efficiency Recommendations considerations. Two workers for Level 3. A person with air monitoring training might be required This person can be a worker. .r' 185 Miscellaneous ACM a Asbestos O&M Work Practices 1992 NIBS ite rn~MMfcimynn I , I i j Ml2 Level 3 Remove asbestos-containing ceiling tiles attached with adhesive Examples Level 3l A. Remove ceiling tiles that will break during removal. B. Remove badly damaged ceiling dies. Notes This work practice must be used in conjunction General Procedures W1 and W9 and a Level 3 Worker Checklist. The checklist includes tasks that must be performed before these work practices are used. Work Practice 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See General Procedure Wl for standard tools, equipment and materials list). Non-asbestos replacement ceiling panels and adhesive Scraper or other tools as needed to remove tiles 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative pressure system and/or HEPA filtered local exhaust ventilation. See General Procedure W9. 4. Place tools, equipment and materials needed into enclosure. Enter enclosure and set up ladder or scaffold inside enclosure. 5. Adequately wet ceiling tiles to be removed 6. Cut away outer 1/2" (13 mm) of tile on tongue and grove edges. Pry tile away from substrate to break adhesive bond, remove ceiling tiles and place into disposal bags. 7. HEPA vacuum area where tiles were installed. Wet wipe any smooth finished components exposed where tiles were removed. Use scraper to remove any remaining adhesive or debris. Place wet wipes and debris into ACM disposal bags. 8. Install new ceiling tiles and perform clean-up and tear-down steps on Level 3 checklist to complete work. ,* 187 Miscellaneous ACM Asbestos O&M Work Practices a 1992 NIBS Ml 3 Level 1 Remove asbestos-containing ceiling tiles in spline ceiling system Example Level 1: A. Remove one or several tiles that are designed for easy removal or have been previously removed Tiles come out whole and edges will not be abraded Notes This work practice must be used in conjunction with General Procedure W1 and a Level 1 Worker Checklist, The checklist includes tasks that must be performed before these work practices are used. Work Practice Coordinate work with O & M Work Practice SI ifsurfacing ACM is present above ceiling. Use Work Practice M31 ifHEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced. 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Non-asbestos replacement ceiling panels and straight pins 3. Place tools, equipment and materials needed in work area. 4. Set up ladder or scaffold 5. Remove ceiling tiles and place into disposal bags. 6. HEPA vacuum or wet wipe area where tiles were instalica and suspension system components exposed where tiles were removed 7. Perform clean-up and tear-down steps on Level 1 checklist to complete work. 189 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS Ml3 Level 3 Remove asbestos-containing ceiling tiles in spline ceiling system Examples Level 3: A. Remove ceiling tiles that will break during removal. B. Remove badly damaged ceiling tiles. Notes This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate work with OAM Work Practice SI ifsurfacing ACM is present above ceiling. Work Practice 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See General Procedure Wl for standard tools, equipment and materials list). Non-asbestos replacement ceiling panels and straight pins 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative pressure system and/or HEPA filtered local exhaust ventilation. See General Procedure W9. 4. Place tools, equipment and materials needed into enclosure. Enter enclosure 'em* and set up ladder or scaffold inside enclosure. 5. Adequately wet ceiling tiles to be removed. 6. Cut away outer 1/2" (13 mm) of tiles on edges set on spline. Remove ceiling tiles and place into disposal bags. 7. HEPA vacuum area where tiles were installed. Wet wipe any smooth finished components exposed where dies were removed. 8. Install new dies using pins into adjacent dies to secure in place. 9. Perform clean-up and tear-down steps on Level 3 checklist to complete work. 191 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS Ml 4 . Level 2 Cut or drill asbestos cement panels Example Level 2: A. Drill asbestos cement board to install a new electrical panel Notes This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Hand or power drill as needed (power tools should have a HEPA vacuum attachment) 3. Prepare work area with drop cloth. See General Procedure W9. If accessible, install a drop cloth on the back side of the panel below where hole will penetrate through panel. 4. Place tools, equipment and materials needed onto drop cloth. 5. Adequately wet both sides of area to be drilled using garden sprayer with amended water. Keep water away from any electrical cords or equipment 6. Drill hole using hand drill or power drill with operating HEPA vacuum attached. Wet drilling area using amended water. As options, the following wetting methods/controls may be used: A. For small holes, a wet sponge can be placed on both sides of die surface and the hole drilled through the sponges. B. A HEPA vacuum hose may be used near the bit of a non-HEPA equipped drill, and on the back side if accessible. C. Shaving cream can be sprayed on both sides of the drilling area to control dust and debris. Shaving cream must be wiped up and disposed of as ACM. 7. Wipe debris off drill using wet disposable towels and place towels into disposal bag. 8. If back side was enclosed, insert wand of garden sprayer with amended water into back side enclosure and wet dust or debris. Remove back side enclosure and place into disposal bag. Wet wipe surfaces that were exposed inside back side enclosure. 9. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. *** 193 Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS Ml 5 Summary Remove asbestos cement panels Summary This work practice covers the procedures for removing a small number of asbestos cement panels to support O&M work. This procedure can be used for asbestos cement range hoods. Examples Level 1: A. Remove corrugated or flat asbestos cement panels that are painted or in good condition, and have fasteners that can be easily removed. Level 2: A. Remove corrugated or flat asbestos cement panels in fair conditioa Level 3: A. Remove corrugated or flat asbestos cement panels in poor condition which have become friable and where dust or powder may be generated during removal. Related Work Practices M14 - Cut or drill asbestos cement panels. M18 - Remove asbestos-containing fire door. Worker One worker for Level 1 and Level 2. Two workers for Level 3. Panel size may Recommendations necessitate two or more workers. A person with air monitoring training might be required. This person can be a worker. 195 a Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS Ml 5 . Level 2 Remove asbestos cement panels Example Level 2: A. Remove corrugated or flat cement asbestos panels in fair condition. Notes This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice If activated electrical equipment is in work area, delete wetting (ifpermitted by EPA) for this work. 1. Perform Pre-work activities on Level 2 checklist2. Additional tools* equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Tools as needed to remove panel fasteners (slatter's ripper* nail clipper, screwdriver) 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools* equipment and materials needed onto drop cloth. 5. Adequately wet panel(s) to be removed using garden sprayer with amended water. 6. Remove fasteners holding panel in place. HEPA vacuum and wet fasteners as they are removed. Clean fasteners using water if they are to be reused. Dispose of fasteners as ACM if not being reused. 7. Remove panel and wrap in two (2) layers of polyethylene sheet for disposal as ACM. 8. HEPA vacuum and wet wipe surfaces to which panel was attached. HEPA vacuum and wet wipe up any dust or debris from panel removal. 9. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. 197 a Miscellaneous ACM a Asbestos O&M Work Practices 1992 NIBS Ml6 Summary Remove cement asbestos cooling towers louvers Summary This work practice covers the procedures for asbestos cement cooling tower louvers. Examples Level 1: A. Remove asbestos cement cooling tower louvers in good conditioa Level 2: A. Remove asbestos cement cooling tower louvers in poor condition, abraded or severely weathered. Related Work Practices mis Remove asbestos cement panels. Worker One worker. Two or more for large panels or elevated work areas. A person with Recommendations ^ monitoring training might be required. This person may be a worker. 199 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS Ml 6 Level 2 Remove asbestos cement cooling tower louvers Example Level 2l A. Remove asbestos cement cooling tower louvers in poor condition. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Tools as needed to remove louvers Non-asbestos replacement louvers 3. Prepare work area with drop cloth. Verify that cooling tower is shut off and locked out See General Procedure W9. .4 Place tools, equipment and materials needed onto drop cloth. 5. Adequately wet louvers to be removed. 6. Remove any fasteners bolding louvers in place. HEPA vacuum axxi wet fasteners during removal. Clean fasteners for reuse or dispose of as ACM. 7. Remove louvers and place into disposal bags or wrap in polyethylene sheet for disposal. Collect any large broken pieces or chips and place into disposal bags. 8. HEPA vacuum and wet wipe surfaces that louvers were contacting. HEPA vacuum and wet wipe up any debris or dust from louver removal. 9. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. I 201 Miscellaneous ACM a Asbestos O&M Work Practices a 01992 NIBS [V ) Ml7 Level 1 Remove or replace asbestos cement roof shingles Example Level 1.* A. Replace or remove a small number of asbestos cement roof shingles in good condition that are loose or can be removed with minimal breakage to perform patching, repair work, or install new vent or stack. Notes This work practice must be used in conjunction with General Procedure W1 and a Level 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice Use ofa safety harness is strongly recommendedfor working on sloped roofs. Roofing removal work shall be completed before any penetrations are made in the roofdeck. Use Work Practice M31 ifHEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced. 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment and materials list). Pry bars, slarter's ripper and/or nail clipper Non-slip boots for roofing work Safety harness Replacement roofing Frsrstr:r Spray encapsulant (if used) 3. Place tools, equipment and materials needed in work area. If desired, spray encapsulant on shingles prior to start of removal. 4. Starting at top of removal area, remove nails, cut nails or pry up edge of first shingle until edges can be gripped by hand. Remove shingle and place into disposal bags or polyethylene lined cardboard boxes and lower to ground level. 5. Continue removing shingles using procedures in step 4. 6. Clean up any debris or dust using wet wiping or HEPA vacuum. 7. Perform maintenance work and clean-up and tear-down steps on Level 1 checklist to complete work. 203 Miscellaneous ACM ii Asbestos O&M Work Practices 1992 NIBS gBCsAitdiiil'iyrrtS-frS'Ta'Mtt Appendices t Appendix A Job Request Form for Maintenance Work (from EPA Green Book) 267 Appendices 1992 NIBS Appendix B______________________ Maintenance Work Authorization Form (from EPA Green Book) 269 Appendices 1992 NIBS Moot; Appendix C Evaluation of Work Affecting Asbestos-Containing Materials (from EPA Green Book) 271 Appendices 1992 NIBS Appendix D________ Waste Tracking Form 273 Appendices ^ 1992 NIBS Appendix E Glossary Acoustical Piaster Sound absorbing finishing material mill-formulated for application in areas where a reduction in sound reverberation or noise intensity is desired. These materials usually are applied in a minimum thickness of 1/2" (13 mm). The finish material is applied over gypsum plaster, plaster brown coat or other base plaster. The surface material is usually friable and has a rough surface appearance. Acoustic Tile Tile-shaped blocks of sound absorbent material used for ceilings or as wall facing. May be glued to substrate or laid in a rigid grid work. ACM (ACBM) Asbestos-Comainms Materia] (Asbestos-containing Building Material). Any material containing more than one percent asbestos. Adequately Wet Adequately Wet means sufficiently mix or penetrate with liquid to prevent the release of particulates. If visible emissions are observed coming from asbestoscontaining material, then that material has not been adequately wetted. However, the absence of visible emissions is not sufficient evidence of being adequately wet Air Monitoring The process of measuring the fiber content of a specific volume of air. Amended Water Water to which a surfactant has been added for use in wetting ACM to control asbestos fibers. Asbestos Chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos and any of these minerals that has been chemically treated and/or altered. Asbestos-Containing Waste Material Mill tailings or any waste that contains commercial asbestos and is generated by a source regulated under NESHAP. This term includes filters from control devices, friable asbestos waste material, and bags or other similar packaging contaminated with commercial asbestos. As applied to demolition and renovation operations, this term also includes regulated asbestos-containing w**!* zr4 trials contaminated with asbestos including disposable equipment and clothing. Asbestos debris Pieces of ACBM that can be identified by color, texture, or composition, or means dust, if the dust is determined by an accredited inspector to be ACNt Asbestos Hazard Emergency Response Act (AHERA) AnEPA regulation published in die October 30, 1987 Federal Register covering asbestos-containing materials in schools. AHERA requires local education agencies to identify ACM in their school buildings, develop an asbestos management plan and implement this plan. An O&M program is one permitted response action, where appropriate. 275 Appendix E - Glossary 1992 NIBS ... ... n rt^ --- jta& MfcMHM. Fireproofing Materia! applied to strucutral elements or systems which provides increased fire resistance, usually serving no structural funtion. This material is typically applied using spray equipment Friable Asbestos (See "Regulated ACM") Glovebag A polyethylene or polyvinyl chloride bag-like enclosure affixed around an asbestos-containing source (most often, TS1) so that the material may be removed while minimizing release of airborne fibers to die surrounding atmosphere. HEPA Filter High-Efficiency Particulate Air Filter. Such filters are rated to trap at least 99.97% of all particles 0.3 microns (0.3 pm) in diameter or larger. Medical Surveillance Aperiodic comprehensive review of a worker's health status. The required elements of an acceptable medical surveillance program are listed in the Occupational Safety and Health Administration standards for asbestos. Mini-Enclosure An enclosure constructed of polyethylene sheeting used for small scale, short duration asbestos maintenance or renovation work. Mini-enclosures can be small enough to restrict entry to the asbestos work area to one worker. Appendix G to OSHA regulation 29 CFR 1926.58 discusses mini-enclosures and recommends that a change room be constructed contiguous to the mini enclosure. Miscellaneous ACM Interior asbestoscontaining building material on structural components, structural members or fixtures^uch as floor and ceiling tiles; does not include surfacing material or thermal system insulation. Negative Pressure System a local exhaust system intended to prevent the escape of contaminated air to the surrounding environment. It utilizes HEPA filtration capable of maintaining a pressure differential with a lower pressure inside the Work Area than in any adjacent area. This system recirculates clean air and/or generates a constant flow of air from adjacent areas into the work area. Negative Pressure Respirator a respirator in which the air pressure inside the respiratory-inlet covering is positive during exhalation in relation to the air pressure of die outside atmosphere and negative during inhalation in relation to the air pressure of the outside atmosphere. NESHAP National Emission Standard for Hazardous Air Pollutants - EPA Rules under the Clean Air Act NIOSH The National Institute for Occupational Safety and Health, which was established bv the Oc .i^aiioual Safety uid Health Act of 1970. Primary functions of NIOSH are to conduct research, issue technical information, and certify respirators. Operations & Maintenance (0&M) Program A program of work practices to maintain ACM in good condition, ensure clean up of asbestos fibers previously released, and prevent further release by minimizing and controlling ACM disturbance or damage. Occupied Area An area where personnel are present and are performing their normal activities intended for the area (such as in a typical office area from 8:00 to 5:00 p.ra., Monday through Friday). OSHA Occupational Health & Safety Administration 277 Appendix E Glossary 1992 NIBS Category 1 nonfriable asbestoscontaining material (ACM) means asbestos-containing packings, gaskets, resilient floor covering and asphalt roofing products containing more than 1 percent asbestos as determined using the method specified under AHERA. Category (I nonfriable ACM means any material, excluding Category I nonfriable ACM containing more than 1 percent asbestos as determined using the methods specified under AHERA, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. Remove For Operations and Maintenance work on ACM, "remove" refers to the removal of ACM as needed to perform a maintenance or repair O & M activity. Removal Encapsulate a penetrating encapsulant specifically designed to minimize fiber release during removal of asbestos-containing materials rather than for in situ encapsulation. Repair Returning damaged ACBM to an undamaged condition or to an intact state so as to prevent fiber release. Respirator A device designed to protect the wearer from the inhalation of harmful particulates. Small-scale, Short-duration (See Appendix H) Surfacing ACM Asbestos-containing material that is sprayed-on, troweled-on or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural member, or other materials on surfaces for acoustical, fireproofing, or other purposes. Suspended T Bar Celling System A false or dropped ceilng composed of acoustic tiles laid into an inverted metal "T" bar grid frame suspended by wires from building framing members. Surfactant A chemical wetting agent added to water to improve penetration, thus reducing the quantity of water required for a given operation or area. Temporary Barriers One or more layers of 6 mil polyethylene installed to isolate a work area from other portions of a facility. Thermal System Insulation (TSI) Thermal system insulation - asbestoscontaining material applied to pipes, fittings, boilers, breeching, tanks, ducts or other interior structural components to prevent heat loss or gain or water condensation. Time Weighted Average (TWA) in air sampling, this refers to the average air concentration of contaminants during a particular time period. Transmission ^kcMicroscopy (TEM) A method of analysis using an electron microscope, used to find and analyze the concentration of airborne or bulk asbestos fibers and structures. Distinguishes among asbestos and other materials; can detect smaller asbestos fibers than does PCM. Used by EPA to find area concentrations for large AHERA project clearance. Work Area The area where asbestosrelated work or removal operations are performed which is defined and/or isolated to prevent the spread of asbestos dust, fibers or debris, and entry by unauthorized personnel. Work Practices Procedures designed to be followed to avoid or minimize fiber release during activities affecting ACM. . 279 Appendix E - Glossary 1992 NIBS ' OSHA Regulations Occupational Safety and Health Administration, Asbestos Regulations for the Construction Industry 29 CFR 2926.58, Washington D.C., 1986. Occupational Safety and Health Administration, Respiratory Protection 29 CFR 2910.134, Washington, D.C., 1978. Occupational Safety and Health Administration, Hazard Communication Standard for the Construction Industry 29 CFR 1926.59, Washington D.C., 1987. U.S, General Services Administration (PMSE) Documentation Package for Asbestos Operations &. Maintenance Programs, Washington D.C., 1990. A$6e$f0$ (Air monitoring guidance, etc.) Information Center ` Miscellaneous References Institute for Environments! Assessment, 433 Jackson Street, Anoka, MN 55303: 1. Suggested Operations and Maintenance Procedures 2. Guide to Asbestos Personal Monitoring 3. Recognition of Damage, Deterioration and Delamination 4. Aerodynamic Characteristics ofAsbestos Keyes, Dale L. and Chesson, Jean. Guide to Monitoring Airborne Asleitf>s in Buildings, Tuscon, AZ, 1989. Health Effects Institute Asbestos Research, Asbestos in Public and Commercial Buildings A Literature Review and Synthesis of Current Knowledge; Cambridge, MA, 1991. 281 Appendix F - References 1992 NIBS Appendix G General Safety Considerations (Tills section is reprinted from Appendix D of the EPA's White Book for use by personnel performing 0 & II activities.) 283 a Appendix G - General Safety Considerations 1992 NIBS (9) Wood or ffcerglass ladders should be provided to help control exposure to electrical hazards. (to) Employees Should not straddle the space between a ladder and another object (11) Employees should make a visual inspection of ladders before each shift Addftiona! information sources: "Ladders" - publication no. ISBN 0-919465-05-6 Construction Safety Association of Ontario 74 Victoria Street Toronto. Ontario Canada M5C 2A5 "Safety Requirements for Portable Wood Ladders" - ANSI A14.1 -1982 "Safety Requirements for Job-Made ladders" - ANSI A14.4 -1979 "Safety Requirements for Portable Reinforced Plastic Ladders" - ANSI A14.5 -1982 American National Standards Institute, Inc. 1430 Broadway New York, NY 10018 "Portable Ladders" - industrial Safety Data Sheet *885 National Safety Council 444 North Michigan Avenue Chicago Illinois 80811 Environmental Health and Safety Division Georgia Tech Research Institute Georgia Institute of Technology Atlanta, Georgia 30332 C. Scaffolds Falls from scaffolds result in about 2,000 injuries per month in the United States. These can be reduced by (1) providing guardrails around the perimeter of die work surface regardless of scaffold height (2) securing scaffold decks against slippage (3) keeping scaffold uprights venicai and pinned together when stacked (4) ensuring vertical members are braced to keep the scaffold plumb and level (5) decking the entire top ponion of the work surface in lieu of using minimum planking dmensions (6) extending planks at least 6* (150 mm) over their support and dealing or restraining them from movement (7) ensuring that manufacturer built-in ladders are in good condition (8) maintaining mobile scaffold casters in good coridition with position locking devices secured when employees are working from the scaffold 285 a Appendix G - General Safely Considerations a 1992 NIBS (3) Determine what equipment must remain energized during the abatement process. (4) Insulate or guard energized equipment and Wiring from employee contact and other conductive objects. (5) Avoid damaging permanent building wiring during the work. (6) Consider dry removal methods in the vicinity of electrical equipment which must remain energized. C. Temporary Power (!) All temporary circuits provided by the abatement operator must be provided with a grounding system and protected by ground fault circuit interrupters. (2) Avoid stringing temporary wiring across floors (3) Elevated wiring should not be fastened with staples, nails, or wire. (4) Use care not to damage the wiring insulation during Installation or abatement work. D. Electrical Cords and Tools (1) Provide extension cords which have a ground conductor. . (2) Ensure that cords are not damaged, contain no splices, and that the groung lug on the male plug is intact. (3) Position extension cords to eliminate stumbling/tripping hazards and to protect them from damage by moving scaffolds. (4) Provide electrical tools which are either grounded or of the double-insulated type (5) Use shatterproof, guarded bulbs and heavy duty wiring for temporary fighting. (6) Where plugs enter receptacles, ensure that the connection is protected by use of duct tape or by other means. Additional information sources: "National Electrical Safety Code" - ANSI C2-19S4 "National Electrical Code" - ANSI/NFPA 70-1984 American National Standards Institute, Inc. 1430 Broadway New York, NY 10018 "Temporary Electric Wiring for Construction Sites" - Industrial Safety Data Sheet #515 National Safety Council 444 North Michigan Avenue Chicago, Illinois 80611 267 Appendix G - Genera! Safety Considerations 1992 NIBS **' Appendix H Definitions of Small-Scale, Short-Duration Operations This section sets forth the EPA and OSHA definitions of small-scale, shortduration operations -- the scope of work intended under this manual All references are to the Code of Federal Regulations (CFR), the Federal Register (Fed. Reg.), or the OSHA Compliance Manual (OSHA INSTR.) This manual is intended for use only with operations qualifying as "smallscale, short-duration" projects under OSHA and EPA regulations and regulatory guidelines. A summary of these regulations and guidelines are set forth below. The complete regulations should be consulted for full information related to these definitions. The reader should review this Appendix in its entirety for a complete understanding of die current regulatory picture, and of the proposed changes to those regulations. The reader should also consult the regulations at the time of use to ensure that these definitions are still in place. Local and state guidelines and regulations should also be consulted. 1. OSHA DEFINITIONS A. Current Definition The definition contained in Appendix G of the construction asbestos standard (29 C.F.R. 1926.58) is as follows: For the purposes of this appendix, small-scale, short-duration renovation and maintenance activities are tasks such as, but not limited to: Removal of asbestos-containing insulation on pipes: Removal of small quantities of asbestos-containing insulation on beams or above ceilings: Replacement of an asbestos- containing gasket or valve; Installation or removal of a small section of drywall; Installation of electrical conduits through or proximate to asbestoscontaining materials. 29 C.F.R. 1926.58, App. G. B. Problems With the Current OSHA Definition OSHA has been under court order since February, 1988 to amend its definition of its exemption from the negative pressure enclosure requirement for small-scale, shortduration operations, because, as the court found, "the exception as now worded seems to erase the rule." See Building and Construction Trades Department, AFL-CIO v. Brock, 838 F.2d 1258, 1279 (D.C. Cir. 1988). OSHA is currently revising its definition as part of a rulemaking procedure begun in 1990 and is expected to promulgate a new regulation in 1992. OSHA's proposal is set forth below at l.D. C. Clarifications Contained in OSHA INSTRUCTION CPL 2-2.40 OSHA has issued only one compliance directive on the asbestos standard; the directive further defines small-scale operations as follows: 29 C.F.R. 1926.58(e)(6)(iv)grants exceptions from the requirements of establishing negative-pressure enclosures and designating a competent 289 Appendix H Definitions of S-S/SD 1992 NIBS 55 Fed Reg. 29,751 (1990). 2. EPA Definitions A. AHERA Hie EPA definition under AHERA (40 CFR 763 - Appendix B to Subpart E) repeats the basic OSHA definition (contained in I.A., above), but adds the following clarifications: Small-scale, short-duration maintenance activities can be further defined, for the purposes of this subpart, by the following considerations: (1) Removal of small quantities of asbestos-containing materials (ACM) only if required in the performance of another maintenance activity not intended as asbestos abatement2 (2) Removal of asbestos-containing thermal insulation not to exceed amounts greater than those which can be contained in a single glove bag.2 (3) Minor repairs to damaged thermal system insulation which do not require removal. (4) Repairs to a piece of asbestoscontaining wallboard (5) Repairs, involving encapsulation, enclosure or removal, to small amounts of friable asbestoscontaining material only if required in the performance of emergency or routine maintenance activity and not intended solely as asbestos abatement Such work mav not exceed amounts greater than those which can be contained in a single prefabricated mimenclosure. Such an enclosure shall conform spatially and geometrically to the localized work area, in order to perform its intended containment function. 40 C.F.R. 763, App. B to Subpart E (emphasis added). B. Worker Protection Rule The epa Worker Protection Rule (40 C.F.R. 763.121-126) regulates worker protection for those public employees not covered under the OSHA regulation or under state plan programs, on abatement jobs other than in schools. The rule covers only abatement jobs and does not apply to small-scale, short-duration operations. The implicit cut-off point is in the reporting requirement to EPA: the rule requires pre-job reporting of abatement projects, except ones that involve "less than either three linear (1 ml or three square feet (0.3 m2) of friable asbestos" or an emergency project 40 C.F.R. 763.124. C. Major/MInor Fiber Release Categories Under AHERA EPA also utilizes the 3 square or 3 linear feet cut-off in its regulations covering operations and maintenance in schools (40CF.R. 763.91). Paragraph (f), which regulate "fiber release episodes," defines a "major fiber release episode" requiring a trained abatement worker, as "the falling or dislodging of more than 3 square (0.8 m2) or 3 linear feet (1 m) of friable ACM." (40 C.F.R. 763.91(f)(2).). D. NESHAP EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP), 40 CFR Part 61, applies to demolition or renovation activities, and "individual nonscheduled operations" (such as O&M or emergency renovation operations work). NESHAP applies if the renovation or demolition involves more than the following amounts of regulated asbestoscontaining material (RACM) on a single project, or if the combined additive amount of RACM to be 291 Appendix H Definitions of S-S/SD 1992 NIBS .* Appendix i Regulations Note: This information is reproducedfrom chapter 6 of the Green Book. Building owners are governed by a variety of federal, state, and local regulations which influence the way they must deal with ACM in their facilities. Some of these regulations, particularly at the state and local level, may change frequently. Building owners should contact their state and local government agencies, in addition to organizations such as the National Conference of State Legislatures (NCSL), die National Institute of Building Sciences (NIBS), or EPA environmental assistance centers, for updated information on these requirements. 08A and the U.S. EPA Worker Protection Rule There are several important Occupational Safety and Health Administration (OSHA) and EPA regulations that are designed to protect workers. OSHA has specific requirements concerning worker protection and procedures used to control ACM. These include the OSHA construction industry standard for asbestos (29 CFR 1926.58), which applies to O & M work, and the general industry asbestos standard (29 CFR 1910.1001). State delegated OSHA plans, as well as local jurisdictions, may impose additional requirements. For most operations and maintenance activities in building areas where only non-friable ACM is present or where friable ACM is in good condition, applicable OSHA permissible exposure limits are not likely to be exceeded. However, it is possible that some O & M activities will disturb ACM to such an extent that the OSHA limits are exceeded, unless good work practices are followed. The OSHA standards generally cover private sector workers, and public sector workers, and public sector employees in states which have an OSHA state plan. Public sector employees, such as city or government employees, or certain school employees, who are not already subject to a state OSHA plan are covered by the EPA "Worker Protection Rule" (Federal Register February 25,1987; 40 CFR 763 Subpart G, Asbestos Abatement Projects; Worker Protection, Final Rule). Note: At this time, OSHA is considering a substantial number of changes to its regulations. The OSHA standards and the EPA Worker Protection Rule require employers to address a number of items which are triggered by exposure of employees to asbestos fibers. Exposure is discussed in terms of fibers per cubic centimeter (cc) of air. A cc is a volume approximately equivalent to that of a sugar cube. Two main provisions of the regulations fall into the general category of "Permissible Exposure Limits (PELs)" to airborne asbestos fibers. They are: 1. 8-hour time-weighted average (TWA) limit - 0.2 fiber per cubic centimeter (f/cc) of air based on an 8-hour TWA sampling period. This is the 293 Appendix i Regulations 1992 NIBS reasonably be expected to be exceeded. Appendix G is mandatory for smallscale, short-duration activities that exceed, or may reasonably be expected to exceed, these limits if an employer wishes to be exempt from paragraph (eX6) (establishing a negative pressure enclosure) and paragraphs (jXlXO or (j)(2Xi) (hill scale decontamination) of this regulation. OSHA states that it expects the engineering and work practice controls in Appendix G to reduce asbestos exposure levels below the Action Level. OSHA has proposed in its forthcoming rule that Appendix G become mandatory for all smallscale, short-duration activities and not be based on exceedance of particular asbestos exposure levels. Small-scale, short-duration projects are not currently precisely defined in terms of either size or duration, although their nature and scope are illustrated by examples presented in the text of the regulation. Properly trained maintenance workers may conduct these projects. ny Include removing small sections of pipe insulation or covering for pipe repair, replacing valves, installing electrical conduits, or patching or removing small sections of drywall. OSHA issued a clarification of the definition of a "small-scale, short-duration" (SS/SD) project in a September 1987 asbestos directive. The directive focuses on intent, stating that in SS/SD projects, the removal of ACM is not the primary goal of the job. If the purpose of a small-scale, short-duration project is maintenance, repair, or . renovation of the equipment or surface behind the ACM - not abatement of ACM - then the appendix provisions may apply. If the intent of the work is abatement of the ACM, then the full- scale abatement control requirements apply. In any event, this appendix section of the OSHA construction standard outlines requirements for the use of certain engineering and work practice controls such as glovebags, minienclosures, and special vacuuming techniques. Similar information on these procedures may be found in the EPA's AHERA regulations for schools. (See final AHERA rule, Appendix B, for SS/SD projects.) U.S. EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) (40 CFR 61 Subpart M) EPA's rules concerning the application, removal, and disposal of RACM, as well as manufacturing, spraying and fabricating of ACM, were issued under the asbestos NESHAP. The asbestos NESHAP regulation governs asbestos demolition and renovation projects in all facilities. The NESHAP rule usually requires owners or operators to have all friable ACM be removed before a building is demolished, and may require its removal before a renovation. For renovation projects where friable ACM will be disturbed, the NESHAP rule requires appropriate work practices or procedures for the control of emissions. It is prudent to note that any ACM which may become friable poses a potential hazard that should be addressed. The building owner should consider that in many instances, the removal of friable ACM prior to demolition could be less expensive than removals while the building is still occupied and being used. Notification EPA or the state Of the state has been delegated authority under NESHAP) must be notified before a building is demolished or renovated. The following information is required on the NESHAP notice: 1. Name and address of the building r 295 a Appendix I - Regulations 1992 NIBS Shipping limitations: Shipping Waste shipment record: The record "T" r "blue" or "brown" asbestos (as defined below), other than "small must be completed for each shipment of ACM waste. A copy quantity" shipments, is forbidden signed by the transporter must be from aircraft or passenger-carrying given to the building owner or railcars, and "white" asbestos is operator (e.g., maintenance or limited to 440 pound (200 kg) abatement contractor) when the shipments by such modes. The waste leaves the building site, and HMR defines chrysotile, actinolite, a copy signed by the disposal site anthophyllite and tremolite asbestos must be received in 45 days. as "white asbestos," crocidolite asbestos as "blue asbestos," and amosite and mysorite asbestos as "brown asbestos." Exceptions: The HMR does not cover asbestos immersed or fixed in a binder material such as cement, plastic, asphalt, resins or Vehicle marking: A vehicle mineral ore (e.g., nonfriable ACM transporting asbestos-containing that has not become crumbled, waste must be marked with pulverized or reduced to powder), asbestos danger signs during manufactured products containing loading and unloading of the waste. asbestos (e.g., pipe gaskets), and shipments of less than 1 pound of friable ACM. Packaging of ACM must conform to specific requirements, but need not meet HMR performance oriented T packaging specifications for Packaging Groups II and IQ. Shipping papers and marks: Entries used in the hazardous material description on shipping papers and marks are: RQ, (Reportable Quantity, if 1 lb or more of friable asbestos) WASTE (For transportation of waste material, if applicable) WHITE (or BLUE or BROWN) ASBESTOS (Shipping name; the DOT asbestos descriptions; listed in "shipping limitations," above) MIXTURE (For asbestos mixed with a binder or filler, etc.) 9, (Class 9, Miscellaneous Hazardous Materials, includes asbestos) ! 297 Appendix 1 Regulations 1992 NIBS Appendix J Minority Opinions Minority opinions by project committee members are permitted under the consensus rules of the Institute. Minority opinions must pertain to issues addressed in the members' ballot comments and be judged by the project committee to be relevant to the scope of the project The relevant comments were evaluated at a meeting of the project committee and categorized as persuasive, non-persuasive, or editorial. The minority opinions contained herein address comments judged to be non persuasive by the project committee. Comments judged to be persuasive and editorial have been incorporated into the text The project committee chairmr-i urge-* dissenting members to coauthor minority opinions on the same subject Several dissenting members chose to independently submit separate minority opinions. NIBS staff, in the exercise of its editorial discretion, combined separately submitted minority opinions on the same subject into one common statement on that subject The minority opinions contained in this appendix are solely those of the authors. These statements may, or may not, represent the opinions of the organizations with which the authors are affiliated. Neither the project committee nor the Institute has verified fire accuracy of facts and statements contained in the minority opinions, and furthermore none of the minority opinions represent the consensus of the project committee. The address and telephone number of the members submitting minority opinions are listed at the end of this appendix. 299 Appendix J - Minority Opinions 1992 NIBS .... -rrrT--riir-;`fr-''rTiriTM^-^-^-^= Minority Opinion Subject Subject James August; American Federation of State, County and Municipal Employees Adequacy of the Guidance Objection On a number of critical issues the Manual falls to provide adequate guidance and does not make recommendations essential to protect custodial and maintenance personnel, as well as other building occupants from the health risks caused by asbestos exposure. Rationale Managing ACM in place is not always simple or inexpensive. The infrastructure to properly manage asbestos in place does not yet exist Regulations governing O & M activities are inadequate. With die exception of schools, there are no federal requirements that buildings be inspected for asbestos or that O & M workers receive asbestos training. Critical personnel, such as asbestos program managers, do not have to be accredited, there is an absence of a model training curriculum, oversight for training providers, and meaningful enforcement A number of factors can compromise the effectiveness of an O & M program; such as a lack of asbestos awareness, cost and time constraints, and reluctance to disrupt building activities. Recommended Alternatives this Manual should err on the side of caution. Hie least burdensome options recommended should be fully protective of custodial and maintenance workers. Definition Level 1 (page 8) Both the EPA's "Purple Book" and Objection Guidance offered is "Green Took" (fit- : to this inconsistent with the definition of Level Manual) state that proper respiratory 1 regarding both training and respiratory protection is an integral part of all protection. custodial and maintenance activities involving potential exposure to asbestos Rationale The definition of Level 1 and that respirators be required during clearly states that disturbance of ACM is initial cleaning and whenever personnel not intended. However, the possibility come in contact with ACM. of unintended disturbance, with an unquantified level of exposure, is Recommended Alternatives Maintenance acknowledged as a distinct possibility. and custodial staff should have O & M training for any task that disturbs, or The minimum training recommended by may disturb ACM. The amount and the Manual is "Awareness" training content of the O & M training should which is intended to make building correspond to the type of ACM to be service representatives recognize encountered and should emphasize activities that disturb, or may disturb hands-on methods. Respiratory ACM and therefore should be avoided. protection should be recommended for Awareness training does not instruct most situations that are now being personnel how to actually perform tasks classified as Level 1. that disturb, or may disturb ACM. 301 Appendix J - Minority Opinions 1992 NIBS Minority Opinion Subject Subject Subject Subject G. William Bain; Woodmont Managements, Inc. Sarah Hospodor; National Realty Committee Usefulness of the Manual Objection The recommendations are excessively complex and burdensome. The paperwork, work permit process, and checklists are too long and detailed. Many work practices have no Level 1. Rationale Many buildings have only a part-time maintenance/custodial employee and adequate supervision may not be available to oversee the recordkeeping and training aspects of the program. Prior site inspection for routine maintenance tasks is an unreasonable expectation An employee on a small project is unlikely to call the APM prior to every routine task, such as removing a light fixture, for which he/she is trained and has equipment Recommended Alternatives Provide small building operations more flexibility to design programs that are manageable and fit realistic needs. Simplify the paperwork; limit checklists and documentation reports to one page. Recommend more Level 1 work practices. Air Clearance for Level 3 (Figure 1, page 9) Objection It is not necessary to perform air clearance for all Level 3 activities. Rationale In areas where quick laboratory turn-around is not available, mini-containment cubes must be left up overnight or longer. The APM should have the flexibility to judge actual site conditions and past experience in determining the need for clearance air sampling. Extensive data indicates that clearance sampling is not always warranted. Unnecessary expenditures of time and analytical costs will discourage good O & M practices. Recommended AILrmtv*: Change to "AS NEEDED". Respiratory Protection and Protective Clothing for Level 1 (page 9) Objection Providing maintenance workers who have been instructed to avoid disturbing ACM with respirators or protective clothing. Rationale O & M programs calling for outside contractors to perform all work that disturbs asbestos should not be required to provide respirators or protective clothing to in-house staff. Recommended Alternatives Add appropriate explanatory note. Settled Dust Sampling (page 28). * Maintaining settled dust sampling records (page 27). Objection An implied recommendation to perform settled dust sampling and the suggestion that settled dust sampling records be maintained are inappropriate. Rationale Settled dust sampling is an experimental technology and accepted standards for interpreting results do not exist. Even the ASTM standard regarding settled dust only applies to the methods of sample collection and to methods of microscopic examination. Neither ASTM nor anyone else provides guidance 303 Appendix J * Minority Opinions s 1992 NIBS Subject Subject Subject Health effects of asbestos Objection There is do mention of health effects of asbestos and how they might relate to risk assessment in the. Manual. Rationale The purpose of die Manual is to protect health of workers.- People responsible for O&M programs need health related information upon which to base decisions regarding relative risks of exposures to asbestos during the course of routine maintenance tasks. Many reports have published data that provide valuable information for assessing relative risks. One such report concluded that, at least based on currently available information, short fibers (shorter than 5 microns) have much less carcinogenic activity than longer fibers and may even be relatively inactive. It is also important to note that the "average" maintenance person usually only infrequently performs tasks that could disturb asbestos and place the person at increased risk. Again, published data indicate that in most cases, there is a dose-response relationship to asbestos. OSHA 8-hour Time-Weighted Averages assume exposure 5 days per week. Such constant exposures are uncommon in most O&M settings which means that the relative risk is further decreased. Recommended Alternatives Add a balanced discussion of health effects as they might relate to risk assessments for maintenance workers. Work Practice Levels (page 8) Objection The work practice levels do not provide meaningful guidance to users of the Manual on how to comply with the OSHA asbestos standards. Rationale The levels are not based on OSHA standards. The levels are based on qualitative descriptions which, depending on the circumstances, may or may not correspond to the OSHA standards. With the exception of resilient flooring and roof/siding removal work practices, the assignment of work practice levels and their examples is based on little o, no air monitoring data to determine OSHA compliance. Recommended Alternatives The Manual should be organized to include work practice levels clearly based on the OSHA asbestos standard. Maintenance of 0.01 fibers per cubic centimeter of air inride the respirator is common practice, (page 21) Objection NIOSH does not have a "maximum permissible exposure iimit." The statement regarding "common practice" is not based on verifiable facts. No survey was presented to indicate that such is indeed a common industrial hygiene practice. Rationale Permissible exposure limit is an OSHA term and is misleading in this context. OSHA has set 0.1 fibers per cubic centimeter of air as the "action level" for employee asbestos exposure in the work place. Respiratory protection is not currently required until a fiber concentration of 0.2 fibers per cubic centimeter is reached. The PEL is measured outside the respirator. As stated, the sentence can lead to confusion. A complete discussion of this issue would be too 305 Appendix J - Minority Opinions 1992 NIBS Minority Opinion Subject Subject Recommended Alternatives Inclusion of text clearly describing the various health effects associated with exposure to asbestos. Inclusion of clear health risk warnings to* workers and training needs on this subject This Manual should recommend that all users of the Manual receive fourteen hours of AHERA Maintenance/ Operations Training. Jim E. Lapping; The Building and Construction Trades Department, AfL-CIO Nora Leyland; Sherman, Dunn, Cohen, Leifer & YeUig John B. Moran and Bill Kojola; Laborers* Health & Safety Fund of North America Scott Schneider; Occupational Health Foundation Critical Barriers for Level 2 Objection The requirement for use of critical barriers for Level 2 work practices should be included in the "Guidelines for 3 Levels of Work Practices" (Figure 1), and the Level 2 Worker Checklist Rationale Critical barriers consist of putting plastic over openings through which asbestos might escape, such as windows, doorways, and HVAC vents, usually within a ten-foot radius of the work operation. Although most Level 2 operations utilize glove bags, some do not and asbestos could easily escape through these openings. Even where glove bags are used, there is risk of escape, as glove bags can tear or leak. NIOSH, for example, recommends back-up containment during glove bag use, based on the institute's study showing the uncertainty of exposures levels when using glove bags. Recommended Alternative Critical Barriers should be required for all Level 2 operations. Number of Workers Recommended Objection The Manual fails to recommend a sufficient number of workers when dry decontamination is used, and when glove bags are used. Rationale The Manual correctly recommends a minimum of two workers in situations involving confined spaces and where mini-enclosures are used. In order to be consistent with good practice and recommendations made in the model guide specifications published by NIBS in 1988, the Manual should also recommend two workers for situations calling for dry decontamination and where glove bags are used. In addition, some jurisdictions, such as Allegheny County, Pennsylvania, require a minimum of two workers for glove bag use. Recommended Alternative In addition to confined spaces and situations in which mini-enclosures are used, two workers should be recommended whenever dry decontamination or glove bags are recommended. Because dry decontamination is specified for all Level 2 operations, this recommendation applies to all Level 2 work practices (except those where two workers are recommended already). The Level 2 work practices which specify a glove bag, but which do not recommend two workers are: S2, T7, M27, M30, and M31. .f 307 Appendix J * Minority Opinions 1992 NIBS Subject Subject Rationale Many of the Level 1 work demonstrated that the material can be practices covering non-friable materials handled easily without damaging or are limited to situations in which they do disturbing the asbestos. The following not become friable. The major objection work practices are covered by this to permitting some of these operations to recommendation: Ml, M2, (Note: If the be classified as Level 1, is die inherent backing separates from the wear layer, difficultly in predicting, before a job tins operation should absolutely not be begins, whether or the operation will downgraded to a Level One: the felt disturb asbestos. It is unrealistic to backing is itself a friable material; i.e., expect that, once the job has begun and it once adhered to the floor it cannot be is discovered that asbestos is actually removed, even by "non-aggressive being disturbed, the job will be halted methods," without being rendered and more protective measures put in friable), M3, M6, M9 (Note: here the place. Recommended Alternative Our recommendation, therefore, would be to have these jobs begin as Level 2 operation should be Level 2 until it is established that the carpet is not adhered to resilient asbestos flooring), Mil, M13, M26, M27, M30. operations, which can be downgraded to Level 1 (respirators removed, etc.), after the work has commenced and it has been Explidt Limitations on the Size of Many implication that the Level 3 operation Work Practices carries no size limitation at all. Objection Many of the work practices are Recommended Alternatives The not explicitly limited in size or scope. following work practices should cany Rationale Work practices which are not specific size limitations in the examples explicitly limited in size and scope could given on the stand-alone work practice easily become full scale abatement jobs sheets, such as "a small area, "several" done under the guise of O&M work if or "a few:" SI - Levels 2 (Example B) not so limited. Even though the and 3 (Example B), S10 - Level 3 Summary sheets do reference "several" or (Example C), Ml - Level 2, M2 - all "a few" as size limitations, these Levels, M3 - Level 3, M9 - all Levels, restrictions are not repeated in the stand Mil - Level 3, M12 - Levels 2 and 3, alone, work practice sheets for the various M13 - Levels 2 and 3, M14 - Level 2, levels of operations. And, in some cases, M15 - all Levels, M16 - Levels 1 and 2, Levels One or Two contain a size limit M17 - Level 2, M18 - Level 2, and but Level 3 does not, with the M19 - all Levels. Definition of a disturbance of ACM' Objection The Manual fails to include ACM dust in its definition of a disturbance of ACM. Rationale ACM dust can cause signifi cant exposure if disturbed. Several studies have demonstrated that re suspension of settled fibers is one of the main sources of exposure to asbestos in buildings. Recommended Alternatives The Manual should define a disturbance of ACM as "any activity that disrupts the matrix of ACM, or visible ACM debris or dust." 309 i Appendix J Minority Opinions 1992 NIBS .V'fi'r'n artriiriH'i-- Minority Opinion Subject Subject Rationale Historically, OSHA has provided exposure levels to asbestos as the basis for implementing specific requirements to protect workers, e.g. medical surveillance, training, respiratory protection, regulated areas, labeling, etc. The definition of work practice levels do not contain exposure levels. The Manual states that the work practices are intended to assist in meeting the current OSHA regulations applicable to O&M work. The Manual actually goes beyond any relevant federal regulations and, therefore, only contributes to confusion, overreaction, and unnecessary effort and expense in the field. John Welch; Safe Buildings Alliance (SBA) Usefulness of the Manual Objection The Manual's work practices are excessive and complicated. Rather than setting forth simple work procedures for the variety of minor operations that typically involve asbestos-containing material (ACM) in buildings, most of the Manual's recommended practices are needlessly complicated and mirror precautions required for full-scale asbestos removal projects. The Manual will be counter productive because its complexity is a disincentive to the use of O&M programs. Rationale Exposure data compiled by real estate associations and SBA show that workers who perform small-scale, short-duration activities involving ACM do so infrequently and for such short periods that exposures rarely exceed 0.1 f/cc, (the eight hour timeweighted average level that OSHA has recently proposed to reduce exposure risk during such operations). Exposure data, largely generated by OSHA, demonstrate that episodic exposures during O&M activities, and 8-hour time-weighted average exposures, are well below the current and proposed OSHA standards. In sum, these data demonstrate that asbestos exposures during O&M can be efficiently controlled through any of a variety of simple work practices. Recommended Alternatives The usefulness of the Manual would be enhanced by the inclusion of simple, flexible work practices based on existing Occupational Safety and Health Administration (OSHA) regulations. Work Practice Levels (page 9) Objection The Manual's guidelines do not include work practices allowed by OSHA and do not inform users of the OSHA requirements for O&M activities involving ACM. This information is needed for the Manual to provide comprehensive advice and be an effective tool for those who make asbestos management decisions. The guidelines for three levels of work practices omit these baseline OSHA requirements, and prescribe work practices exceeding virtually all regulatory requirements. Rationale Inclusion of OSHA regulations in defining work practice levels would make the Manual more 311 Appendix J - Minority Opinions 1992 NIBS Delineated Work Area (W4) No Respiratory Protection (W5) No Protective Clothing No Initial Monitoring (W7) Yes Periodic Monitoring (W7) Only if Activity/ Process changes Preclean (W8) No Use HEPA Vacuum (W8) Optional Wet Methods (W8) If Needed to meet 0.2 Work Area Protection (W9> Remove moveable objects Local HEPA Exhaust (W9) Optional Lockdown (Wll) No Personal Decontamination (W14) No Area Decontamination No Visual Inspection (W15) No Air Clearance (W15) No Yes Yes Yes Yes Yes No Optional Optional Regulated Area Optional No Yes No No No 313 Appendix J - Minority Opinions 1992 NIBS Xb John B. Moran and Bill Kojola Laborers* Health and Safety Fund of North America 905 16th Street, NW Washington, DC 20006-1765 202/628-5465 The Laborers' Health & Safety Fund of North America is a joint labor-management organization, comprised of the Laborers International Union of North America and contractors who employ members of the union, which provides technical assistance on workplace health and safety issues. Jim E. Lapping Building & Construction Trades Department, AFL-CIO 815 16th Street, NW, Suite 603 Washington, DC 20006 202/347-1461 The BCTD represents fifteen labor unions which have over five million members working in all phases of the construction industry, including plumbers, carpenters, sheet metal workers, general laborers, electricians, iron workers, bricklayers, painters, boilermakers, plasterers, operating engineers, insulation/asbestos workers, roofers, teamsters, and elevator constructors. Nora Leyland Sherman, Dunn, Cohen, Leifer & Yellig 1125 15th Street, NW, Suite 801 Washington, DC 20005 202/785-9300 Attorney to the Building & Construction Trade Department, AFL-CIO. Marilyn P. Mueller Supradur Manufacturing Corporation 411 Theodore Fremd Avenue; P.O. Box 908 Rye, NY 10580 914/967-8230 Supradur Manufacturing Corporation is a former manufacturer of asbestos-cement roofing and siding shingles. Hie company now manufacturers their entire line of fiber-cement shingles with asbestosfree, fiber-cement technology. Bob J. Pigg Asbestos Information Association/North America 1745 Jefferson Davis Hwy., Suite 509 Arlington, VA 22202 703/979-1950 AIA/NA is an incorporated/non-profit organization representing firms which manufacture, sell, or use asbestos-containing products or mine, mill, or sell asbestos fibers. AIA/NA provides industry wide information and cooperates with government agencies developing and implementing asbestos standards. Scott Schneider, CIH Occupational Health Foundation 1126 16th Street, NW, Suite 413 Washington, DC 20036 202/887-1980 The Occupational Health Foundation is a non-profit, labor-sponsored organization in Washington, DC which provides technical assistance to labor unions on issues of occupational safety and health. *'*/ * 315 Appendix J - Minority Opinions 1992 NIBS Appendix K - Feedback Form This form is to be used to provide comments to NIBS concerning use of the Guidance Manual: Asbestos O&M Work Practices. Comments and suggestions submitted will be considered during future revisions to the manual. Any relevant data derived from the use of the work practices may be submitted. Date:. Comment applies to section: I II 111 IV V VI Vil Work Practice (if applicable):Level: 1 2 3 Comment/recommendation:. Supporting data or informaiion:. Submitted by: Phone: Please Return to: NIBS 1201 L Street, N.W. Fourth Floor Washington, D.C. 20005 317 Appendix K Feedback Form 1992 NIBS Project Committee *Steering Committee Members Chairman: 'William H. Hoffman, QuestCo, Inc. Vice-Chairman: 'Richard P. Peduto, The Port Authority of NY & NJ Secretary: 'Roger G. Morse, AIA, Entek Environmental & Technical Services, Inc. Vicki Ainslie * Georgia Tech Research Institute/Environ. Science & Tech. Peter F. Allard PE., CIH - Scott, Allard & Bohannan, Inc. Walter D. Anderson - Resilient Floor Covering Institute Charles L. Anderson, PE. - SSM/Spotts, Stevens & McCoy, Inc. Robert Angione - Asbestos Disposal Agency, Inc. Bruce Atlas - NYC Deptof General Services, Bureau of Bldg. Design James August - American Federation of State, County & Municipal Employees David S. Babcock - Babcock Environmental Engineering, Inc. G. William Bain - Woodmont Managements, Inc. William J. Basta - Environmental Science & Engineering, Inc. Earl R. Bell - USDA Fanners Home Administration Ken Bolton, PE. - Management International Walter F. Brian - Armstrong World Industries, Inc. Joseph R. Bridgewater, P.E. - Bridgewater & Associates 'James 0. Bynum - MD Department of the Environment - TESH Albert N. Caro - Caro Associates, Inc. William T. Cavness - The Asbestos Institute Frank A. Cellini - Illinois Department of Transportation Weilin P. Chang - M. E. Rinker, Sr. School of Building Construction Frank Chmelik - Converse Environmental West Dr. Aileen T. Compton - Villanova University 'Zachary S. Cowan, in - National Asbestos Council, Inc. R. Wayne Crandlemere - Certified Engineering & Testing Co., Inc. Ellen M. Davis - New England Telephone Mark L. Demyanek, CIH, CSP - R.J. Lee Group, Inc. R. Landon Doggett - Law Associates, Inc. Paul Elkourie - BellSouth Services James B. Evans - O'Brien & Gere Engineers, Inc. Mary A. Finn, CIH - CHART Services, Ltd. James Fite White Lung Associations John R. Folkner, P.E. - Law Associates Neal B. Freuden - EnviroScience Consultants, Inc. 'Warren Friedman, Ph.D., CIH - General Services Administration Christopher K. Gale - Gale/Jordan Associates, Inc. William C. Gallagher - Environmental Hazards Consulting, Inc. C. Michael Gambone - James River Asbestos Services, Inc. James Goumas - The Brand Companies, Inc. 319 a Project Committee a 1992 NIBS *' * Kenneth M. Sedor - Rea] Estate Support Services, Inc. sJames Sharpe - Charles E. Smith Companies Dennis D. Shelton - Technical Environmental Initiatives Reginald B. Simmons - Environmental Protection Systems William E. Sloan - Institute for Environmental Assessment Stephen Smiley - PBS Environmental, Inc. Wil A. Spaul, Ph.D. - Spaul Environmental, Inc. Thomas H. Stephan - Northern Division, Naval Facilities Engineering Command Elia M. Sterling - Theodor D. Sterling and Associates Ltd. Martin A. Stevens - Con-Test, Inc. Ian M. Stewart - R. J. Lee Group, Inc. Neal R. Sweeney - Scott, Allard & Bohannan, Inc. Casimer T. Szewczak - Navy Environmental Health Center DET 5William A. Tlppin, IV - EnviroControI, Inc. H. Jeff Turner, P.E. - Carpenter Turner Group, Inc. Richard W. Turpin - Williams Engineering Corp. Daniel R. Twilley - General Physics Corporation Robert C. Utesch, CIH - Argonne National Laboratory Carl R. Vander linden - Vander Linden and Associates Kurt Varga - Ohio Asbestos Council, Inc. Leonard A. Vernon - Port Authority of NY & NJ Marc P. Vink - Fidelity Environmental Insurance Company Anthony F. Vuozzo - Asbestos Management Consultants, Inc. John F. Welch - Safe Buildings Alliance Judith A. Whelan - Whelan Associates, Inc. Wynn L. White - Wynn L. White Consisting Engineers, David L. Young - Lanier and Associates, Inc. Contractors Steve M. Hays, P.E., CIH, Gobbell Hays Partners, Inc Preston H. Quirk, AIA, Gobbell Hays Partners, Inc Bems & Kay, Graphic Design Consultant NIBS Project Staff Alexander T. Shaw, III, Program Manager Pamela R. Williams, Manager - Publications/Membership Records Baldev R. Sikka, Administrative Assistant 321 Project Committee 1992 NIBS BOARD OF DIRECTORS Chairman: Robert C. Gibson, P.E., President & CEO, Clark, Nexsen, Owen, Barbieri & Gibson, P.C,, Norfolk, VA Vice-Chairman: John C. Canestro, P.E,, Pleasanton, CA Secretary: Dr. Carol B. Meeks, Professor & Head, College of Family & Consumer Sciences, Univ. Georgia, Athens, GA Treasurer: Robert W. Lisle, Chairman & CEO, Famham Corporation, Dallas, TX MacDonald Becket, FAIA, Los Angeles, CA William M. Connolly, AIA, Director, Division of Housing & Development, State of New Jersey, Trenton, NJ Peter G. Doyle, FAIA, President & CEO, LTB Interior Constructors, Inc., Houston, TX Wayne P. Ellis, Harleysville, PA Charles O. Everly, P.E., Director of Building and Zoning, County of Sarasota, Sarasota, FL Dianne Ingels, President, Dianne Ingels & Associates/DEICO, Denver, CO William B. King, Director, Government Relations, Armstrong World Industries, Washington, DC Joseph G. O'Grady, President, ASTM, Philadelphia, PA Harry A. Pryde, President and CEO, Pryde Corporation, Bellevue, WA E. W. Rogers, Vice President, Specialty Plastics, Construction Materials, New Ventures, Dow Chemical USA, Midland, MI Chief Russell E. Sanders, Louisville Fire Department, Louisville, KY David C. Smith, David C. Smith, Inc., McDowell, VA James L. Werner, Group Vice-President, Technical Services, Brand Environmental Services, Inc., Westchester, IL NIBS PROFESSIONAL STAFF David A. Harris, AIA, President N Bruce E. Vogelsinger, PE., Vice-President of Planning and Councils John G. Lloyd, Vice-President of Finance and Administration Earle W. Kennett, Vice President of Construction Criteria Base James R. Smith, Executive Director, Building Seismic Safety Council William A. Brenner, AIA, Executive Director, Construction Metrication Council Philip Schneider, AIA, Director of Technical Programs Neil Sandler, Director of Communications Alexander T. Shaw, in. Project Manager O. Allen Israelsen, Project Manager Layne Evans, Manager of CCB Marketing Lillian Funk, Computer Systems Manager Kelly Sue McCullough, CCB Pre-Production Manager Ted Gryder, Computer Programmer Alynne Cutler, Information Systems Specialist Teresa Scott, CCB Production Manager Patricia Broughton, CCB Production Assistant Pamela R. Williams, Manager, Publications & Membership Records Diane T. Kruzykowski, Manager, Office Services Claret M. Heider, Technical Writer/Editor Gene C. Brewer, President Emeritus NatoraJ buldbsgsobices 1201 L Street, NW, Suite 400 Washington, DC 20005 T)cm Customer. As a purchaser of Guidance Manual: Asbestos Operations & Maintenance Work Practices, we are offering you $30 off the regular membership fee when youjoin the National Institute ofBuilding Sciences. Tbe recommendations found in this document were arrived at through a consensus of broad-based building interests serving on a NIBS project committee. As a member, you would be eligible to participate actively or as a reviewer on any NIBS project committee. Our members play a key role in helping to organize and focus die efforts ofthe national building community in addressing critical problems. Through membership and participation, you can help shape policies to ease the burden of the building regulatory process, improve tbe introduction of technology, and facilitate tbe development and dissemination ofpertinent construction criteria and standards. The Institute, a non-government, non-profit organization authorized by an act of Congress in 1974, is die only organization ofits kind designed to bring together members ofall segments of the nation's building and housing communities to address conflicts and problems and to develop workable solutions. In addition to this publication, NIBS publishes the bestos Abatement and Management in Buildings, Model Guide Specifications along with u. ^ide rar~<' other technical publications for the building industry. We also publish Building Sciences (a bi monthly newsletter), a membership directory and handbook, the Construction Criteria Base (an electronic database ofdesign criteria and industry information), an annual repeat, a calendar of building community events, seminars and more.... These activities are designed to enhance the flow of information on tcg\dasjxy and technical issues and design criteria. -- -- ____ Simply complete tbe membership application on the back of tbis letter and mure tbe application with you payment to the above address. We will acknowledgeyour . membership and send you more NIBS information withoutdelay. Sincerely, " NATIONAL mSTntrre OF BUILDING SCIENCES TAKE ^DVAHTAGE OF THH? OFFERS SAVE $30 ALSO AVAILABLE FROM NIBS ASBESTOS ABATEMENT AND MANAGEMENT IN BUILDINGS, MODEL GUIDE SPECIFICATIONS, SECOND EDITION Member nice: $115 Non-Member Price: $145 This guide offers authoritative advice and guidance in the design and execution ofabatement ofasbestos* containing materials (ACM). It was revised in 1988 to include die latest developments in products, equipment, regulations, and procedures. In 1992, abatement of asbestos containing resilient flooring sections and an 80page Introduction and Instructions for Use were added. The new, comprehensive introduction provides information to facilitate a more effective use ofthe Model Guide. This document will serve as an improved tool for design professionals, contractors, building owners and others maintaining and repairing, enclosing, encapsulating or removing ACM. This consensus document reflects the knowledge and experience of the nearly 100 members of the Institute's asbestos task force who assisted in the development of the guide. This information is also available on 3 1/2" or 51/4" floppy diskettes for use on MS-DOS or PC* DOS based micro-computers in 6 formats (sold below). Please note, the diskettes can not be purchased separately. [485 Pages/1988] Model Guide Specifications Mh Diskettes: WordPerfect, WordStar, ASCII, Multimate, Microsoft Word, Displaywrite 2/3, or Displaywrite 4 Member Price: $170 Non-Member Price: $195 Please specify word processing format and diskette size when ordering. nationalcompilation oftechnicalprotocols,practices, and proceduresontesting, abatement,workerprotection,clean up, and disposal of LBP in residential structures. The Interim Guidelines, previouslypublisbed in theApril 18, 1990editionoftheFederalRegister, areofferedhere in rtv> official amended version, withcorrections todeletions and errors,reformatted foreasierreading,comprehension, and reproduction. [580 Pages/1990] METHODS AND TECHNIQUES FOR REDUCING RADON LEVELS WITHIN NEW BUILDINGS Member Price: $10 Non-Member Price: $12 This document contains guidelines applicable toreducing radonlevelsinnew oneandtwo-familydwellingsandother residential structures three stories or less in height. Guidelines are provided on such techniques as sub-slab depressurization, sealing of foundations, and reducing stackeffect Devek^edbyNIBS'RadonProjectCommittee underacooperativeagreementwiththeU.S. Environmental ProtectionAgency (EPA),theseguidelinesrebasedlargely onradonmitigationexperiences insiLgle-famil, ivokjcuus andasmallnumberofschools andnon-residential buildings. [32 Pages/1990] METRIC GUIDE FOR FEDERAL CONSTRUCTION Member Price: $12 Non-Member Price: $15 HUD's LEAD-BASED PAINT: INTERIM GUIDEUNES FOR HAZARD IDENTIFICATION AND ABATEMENT IN PUBLIC AND INDIAN HOUSING Member Price: $45 Non-Member Price: $55 The original draft for these guidelines was prepared by NIBS' Lead BasedPaintProjectCommitteeofdistinguished experts in the field of lead-based paint (LBP) under a contract with the U.S. Department ofHousing and Urban Development (HUD). This document represents the first Thisuniquepublication wasdesignedtohelp theconstruc tionindustrycomply withnew federalmetricprocurement requirements. By September 30, 1992 agencies of the federal government are required to use the metric system ofmeasurement, totheextent feasible, inallprocurement, grants, and business-related activities. The Metric Guide was created by NIBS under the direction of public and private members ofthe Interagency Construction Subcom mittee. It is the only publication of its kind currently available to aid the construction industry in making this transition. The Metric Guide includes an introduction to metric, a primer on metric usage, instruction on metric document preparation, and guidance on metric manage ment and training. [34 Pages/1991) ,, ^f ' National Institute of BUILDING SCIENCES GUIDANCE MANUAL, ASBE MAINTENANCE WORK PRA The diskette version of the NIBS' Asbestos O&M Work Practices will allow the user to edit the text for fine tuning O&M programs in response to special building conditions or specific program requirements. Additional O&M work practices which are currently in use may be incorporated easily. And, refine ments and work practice modifications may be developed as experience is gained in each particular situation without retyping the entire text. The Guidance Manual is available, on . computer diskette for use on MS-DOS and PC-DOS based microcomputers in formats compatible with most wordprocessors. 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