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1 I I Guidance Manual \H*1 Asbestos Operations & Maintenance Work Practices September 1992 The National Institute of Building Sciences (NIBS) is a non-governmental, 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-S17924-01-0 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. Fix pricing information contact: The National Institute of Building Sciences Publications Department 1201 L Street. N.W., Suite 400 Washington, D.C. 20005^(014 202/289-7800 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. Copying all or portions of this document for resale or redistribution is strictly prohibited. NIBS Document Number - 5076-7 DISCLAIMER The Guidance Manual: Asbestos Operations & Maintenance Work Practices was developed in response to a pressing national need far guidance oa managing in-place asbestos. Tbe 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. Tbe 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 far any financial loss, sustained as a result of the use or application of tbe 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 tbe location of the work. - Experts from the building, scientific, and environmental communities have differing views as to many aspects of proper management of in-place asbestoscontaining 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. These asbestos operations & maintenance work practices are neither laws nor regulations. While this document refers in some cases to certain federal and state laws and regulations, it is not intended to supersede or supplement any law or regulation or to identify all laws and regulations applicable to management of asbestos in buildings. NIBS does not assume responsibility for the currency of referenced documents, requirements, or other provisions included or identified in the Guidance Manual 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, ami 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, P., 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 EPA document Managing Asbestos In Place, also known as die "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 cross section 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 Preiace 1992 NIBS It is neither Intended nor appropriate for this guidance manual to be used for regulatory purposes, ft was purposely structured so that responsibilities for decisions relating to levels of precaution and stringency within each specific builtfing O&M program remain with the responsible building owner or employer. It is expected that the work practices in this manual will be refined and continually improved as they are used in a wide anay of O&M programs in numerous and varied building situations. The Institute encourages feedback from users of the manual as to the effectiveness of these work practices in order to improve its response to the likely need for revisions. The manual is a consensus document Nearly two hundred professionals and specialists from across the spectrum of the building and environmental communities helped to produce the guidance it offers. It is Intended that building owners, managers, designers, environmental consultants, and maintenance and custodial workers and their employers, avail themselves of this reference tool to help them effectively manage the asbestos-containing materials in their buildings while protecting workers and occupants. The Institute's Board of Directors recognizes and appreciates the extensive and highly professional effort and expertise that went into this document and is especially grateful to the members of the project steering committee who worked diligently to coorcfinate the development of the manual. A valuable public service has been performed by the Institute's Asbestos O&M Project Committee and others who contributed to this superior effort Robert C. Gibson, P.E. Chairman of the Board President ii a Preface a 61992 NIBS nv 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 IL 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....................................................... 23 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 ....................................................................................................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 W5 Putting on Respirators and Performing Fit Checks.................................. 37 W6 Putting on Protective Gothing ............................ 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 Cleaning Tools, Equipment and Work Area ..........................................46 W13 Decontaminating Waste ..............................................................................46 W14 Worker Decontamination and Removal of Protective Clothing and Respirators ............................................................................................ 46 W15 Visual Inspection arid CompletingAir Monitoring................................... 47 W16 Waste Transportation, Storage andDisposal .............................................48 W17 Glovebag Removal....................................................................................... 48 W18 Disposal of Contaminated Water...............................................................SI iii Table of Contents 1992 NIBS IV. Surfacing Materials Work Practices Surfacing Materials Location Illustration ....................................................... 54 Cods Lsrsh Dsicription 51 123 Moving one non-asbestos-containing ceiling panel below a plenum space that has exposed surficing ACM . 57 52 23 Attach component to an ACM finished surface that is above a non-asbestos-containing ceiling............... .............. 61 53 123 Work in ceiling plenum space where exposed surfacing . ACM is present ............................. 65 54 123 Install wiring in plenum space where exposed surfacing ACM is present ........................... .............................69 55 23 Attach item to ceiling finished with ACM......................... 73 56 23 Repair or replace item in surface finished with ACM ... 76 57 23 Cut or drill hole in surfacing ACM..................................... 80 S3 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 .. 87 510 123 Repair damaged surfing ACM............................................. 89 511 123> Accessing through an ACM finished surface....................... 93 512 123 Painting surfacing ACM ......................................................... 97 513 2 3 Accessing a contaminated light fixture ............................... 101 V. Thermal Systems Insulation (TSI) Work Practices Thermal Systems Insulation Location Illustration..........................................106 Cods LsvsJs Dsscriptiom T1 23 Remove asbestos-containing insulation on exposed {ripe for maintenance work................................................. 109 T2 23 Remove asbestos-containing insulation on pipe above ceiling for maintenance work......................... 112 T3 23 Remove asbestos-containing insulation on exposed (ripe in elevated location for maintenance work............. 115 T4 3 Remove asbestos-containing insulation on pipe in occupied area for maintenance work................................ 118 T5 23 Repair damaged asbestos-containing insulation on a pipe ............................................................ .. 120 T6 23 Repair damaged asbestos-containing insulation on a boiler, duct or flue .................................................. 124 T7 23 Install device in or access surface of asbestos-containing insulation on a pipe, boiler, duct or flue ......................... 128 T8 23 Remove asbestos-containing duct insulation above ceiling for maintenance work................................ 132 T9 23 Remove asbestos-containing insulation inside HVAC unit for maintenance work.......................................... ...... 135 T10 23 Clean up asbestos-containing debris in crawlspace or tunnel................................................................ 138 hi m Tahlp of Cnntpnk ffi 199? N1R9 1 ''Mpr VI Miscellaneous Materials Work Practices Miscellaneous Materials Location Dlustradon................................................. 142 Code Lords Description Ml 123 Replacement of resilient asbestos floor tiles...................... 146 M2 123 Replacement of vinyl sheet flooringwith ACM backing 152 M3 123 Penetrate resilient asbestos flooringand 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 flooring ............... 170 M8 1 Cleaning resilient asbestos flooring......................................172 M9 123 M10 1 2 Remove carpet over resilient asbestos flooring............... 174 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 2 3 Cut or drill asbestos cement panels......................................192 M15 123 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 1 2 Remove and replace asbestos cement siding...................... 205 M19 12 3 Remove high-temperature resistant (HTR) asbestos cement panels ........................................................208 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, piaster or drywall compound .......................................................... 228 M2S 2 3 Removfc section of asbestos-containing drywall ................232 M26 1 2 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 fanunit ........................................ 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 v Table of Contents 1992 NIBS Appendices Appends A Job Request Form for Maintenance Work ..............................267 Appendix B Maintenance Work Authorization Form ______ _______ 269 Appendix C- Evaluation of Work Affecting Asbestos-Containing Materials................................................... 271 Appendix D - Waste 'fracking Form.......... ...................................... 273 Appendix E Glossary.............. 275 Appendix F References....................................... 280 Appendix Q General Safety Considerations ................................................... 283 Appends H Definitions of Small-scale, Short-duration Operations............ 289 Appendxl* Regulations........................ ..293 Appendix J Minority Opinions................. 299 Appends K NIBS Feedback Form ...:.. ^...................... 317 Index to Blustrstions ; Figure 1 Guidelines for 3 Levels of Work Practices..................................... 9 Figure 2 Work Practices Selection and Use.................................................... 15 Figure2* Asbestos Program Manger Checklist ............................................... 20 Figure 4-Level 1 Worker Checklist.................................................................. 32 Figure 5 -Level 2 Worker Checklist.................................................................. 34 Figure 6 Level 3 Worker Checklist............... ................ .................................. 35 Figure 7 -Surfacing Materials Location Illustration ........................................54 Figure 8-Thermal Systems Insulation Location Illustration.................... .... 106 Figure Miscellaneous Materials Location Illustration .............................. 142 vi Table of Contents 01992 NIBS I. Manual Organization Introduction General This Guidance Manual: Asbestos Operations and Maintenance (OAM) 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 asbekos 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 SjteaagUBSjSuif& LiM** /nr~.\~i^m personnel who have first-hand knowl edge of the asbestos material, facility conditions, and other pertinent needs. These work practices were written with the knowledge that there might be alternate procedures or equipment beyond those in this manual that will adequately accomplish O&M objec tives. The project committee encourag es the development and application of new and innovative equipment and safe, cost effective procedures fat O&M work. The work practices ineluded in the manual are based on practices known to the committee. Many of these work practices were in use when the manual was written. Data indicating that these work practic es perform as intended is not available for many of the work practices. These work practices are not the only suc cessful methods currently available or in use, but were judged by the commit tee to be applicable to a wide range of common situations. Preventative mea sures that provide protection for un damaged ACM might be installed in conjunction with the O&M activities covered by this manual. A feedback form is included in Appendix K to allow users to provide alternate work practice procedures and,comments to NIBS. Different recommendations, referred to as levels, of the Same work practice are provided to accommodate for variations in the type and condition of the asbes tos-containing material to be worked on, the building conditions in which the ACM is located, and the skill level of workers. It is assumed that varying conditions will require different work practice levels to accomplish the same basic task. Selection of the appropriate levels of work practices should be made by the APM for a specific build ing based upon the conditions in that building. Risk assessments and liabili ty concerns might also Influence the selection of the level for a specific work practices. : Assumptions The manual has been developed on the assumption that all asbestos O&M work at a minimum will be done in accordance with appli cable regulations by persons trained in asbestos in general and O&M methods in particular. It is important to empha size that this is a guidance document only, and la not now, nor ever Intended to be used for regulatory purposes. In fact, because on-site circumstances are often sufficiently unique in null scale, short duration settings to defy rigid control prescriptions, any attempt to use It for regulatory purposes is Inap propriate. This manual is not intended to supplant work practices already In place and being successfully applied. Likewise, it must be emphasized that users of this manual might wish to modify (in compliance with applicable regulations) the guidance provided here to suit their unique circumstances. For example, as stated elsewhere, users might wish to alter the recommended forms included in the manual to ac commodate their operations and drcumstances, or modify work practices based on data from past work, new equipment developments or other unique situations. This manual offers guidance only. The user must verify the success of whatever work practices are used. The development of innova tive and creative new equipment and procedures that work safely and effec tively for performing O&M activities is encouraged. t w1 A m Intrnrinrtinn 1952 NIRS ................................................... f , !--- S^WHSie "`viiitr^^l*'t`*`>M>**^i:'''l} 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: ' Statutory & 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 a Introduction a 1992 NIBS O&M Work Practices General The EPA Green Book pro vides bulldog owners, managers, wor kers and other building staff with basic information on how to develop and carry out operations and maintenance programs. input to the design of O&M work. Workers might also wish to offer sug gestions for modifications to specific work practices. Any changes to the work practices should be reviewed with the APM. The O&M work practices in this manu- As a part of the O&M program, the ' al are designed to provide detailed and Asbestos Program Manager (APM) specific guidance to the O&M person should review building Inspection nel for conducting maintenance, repair information to determine whether or and minor renovation work In accordance with an established asbestos O&M program and applicable regula tions. The work practices in this man not a suspect material contains asbestos. If a suspect material which is to be worked on has not been sampled, it should either be sampled and analyzed ual are designed to reduce or contain materials, dust, or fiber release result ing from work performed on or near in accordance with the EPA Pink and/ , or Purple Books, or be assumed to contain asbestos and treated according-; asbestos-containing materials. The iy. work practices are also intended to minimize the extern and impact of any releases which do occur. Summaries of each work practice and examples of typical situations that might be encoun tered are included to assist in the selec tion of appropriate work practice lev els. : J ! If work practices from this manual are , incorporated into an existing O&M program, the entire O&M program should be reviewed and updated, if necessary. Building renovation, main , tenance or repair work that does not directly affect ACM might necessitate revisions to an O&M program if perti This manual presumes that an O&M program is, or will be, established.. nent factors, such as accessibility to ACM, are altered. ! The work practices in the manual ad dress most commonly encountered operations and maintenance tasks in volving asbestos-containing materials. This manual is not exhaustively com plete and does not document or estab lish a defined procedure for every possible situation. The manual is O&M Program Assumptions This O&M Work Practices Manual assumes that all elements of an O&M program listed below are considered and appli cable elements are established. Refer ences to related information are includ ed in Appendix F. formatted to present an array of actual Asbestos Program Manager ap conditions which might be encounte pointment and training red. It establishes a logical path to be Building inspection and assess followed in selecting the most appro ment ; priate work practice^) for a given Written building-specific O&M ! situation. Building workers are often program very familiar with actual building con Copies of applicable regulations ditions and might provide valuable and guidance documents 6 a 0 & M Work Practices a 1992 NIBS  Occupant notification/communica tion 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 periodically to ensure that 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 troweled 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 m<t precau tionary towel of work practice should be used. 2. The work area should be prepared in accordance with the checklist for the mtoet precautionary lewel 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 mod precautionary lewd of work practice being used. 7 O&M Work Practices 1992 NIBS Work practices in this manual need,to included, it was deemed unlikely to be be validated and/or modified for the encountered under typical conditions. facility where O&M work will be . An appropriate work practice level performed. When work is to be per* must be selected or created by the formed, the final work practices should , Asbestos Program Manager for each be given to workers along with other \ O&M activity that will occur in a referenced O&M forms. Repetition of facility. certain steps in different work practice levels is intentional in order to provide consistent and complete information to _ a worker for a given work practice leveL , Work Practice Levels up to three levels are included for each work prac* tice to address different degrees of potential asbestos fiber exposure. The levels are simply a means of structur ing the guidance which the manual provides. The NIBS project committee judged that three levels were sufficient to encompass a broad range of situa tions which are likely to be encoun* tered. A different number of levels might be selected by an APM or de signed into a specific asbestos O&M The three work practice levels are defined as fofiows: Level 1: Work practice ts usually in tended to avoid a disturbance ofACM and release of asbestosfibers, but (f ACM is disturbed. It Is Ukety that wor ker and building occupant exposures will be minimal Level 2: Work practice is likely to, or Intended to. disturb small amounts cf ACMfor short periods of time. Work er protection and localized engineering controls are Justified, but the disturbonce is unlikely to Create building oc cupant exposure or impact the building environment Level 3: Work practice is intended to program. .. ' disturb small amounts cfACM In ways A change of level does not imply a different task to be. accomplished. It implies a changed potential for asbes tos fiber exposure, typically related to sufficient to Justify engineering con trols, and protection of workers, build ing occupants and the building envi ronment either the condition of asbestos or the A "disturbance'* of ACM, as used in building context in whidi the task will the level definitions, refers to any ac be performed. tivity that disrupts the matrix of ACM, The levels for each work practice in cluded in fills manual were selected by or generates visible debris, or disturbs visible debris. the project committee through the Figure 1, which follows, summarizes NIBS consensus process to represent the engineering controls and practices readily identifiable and appropriate recommended for each level. The levels. Examples are provided to assist APM should determine the appropriate users in selecting appropriate levels for level, based on the O&M program specific building conditions. Higher objectives, the O&M program eleme levels become more protective arid nts, and level of training needed for hence more difficult, time consuming each level of work practices used in a ' and costly to implement. Three levels * facility. are not provided for every work prac tice. If a work practice level is not fl - O * M Work Prartirfts a 1M? NIBS ^rfiT^f"TwrmnniiKi mi JSJLStBiL AM 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 Work Ana (W4) Respiratory Protection (WS) Protective Clothing (W6, 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) Ana Decontamination (W11) Visual Inspection (W12) Air Clearance (W12) Personal Decontamination (W15) LEVEL I1 LEVEL2 Low/Minimal1 Moderate Awareness/O&M' O&M NO* YES NO YES NO NO5 NO YES NO4 YES' NO* YES NO*10 YES*10 NO10 YES NO As Needed" As Needed" YES As Needed" YES NO" Drop Cloth, Govebag NO AS Needed" NO YES" NO YES NO YES NO'4 NO14 NO" YES LEVEL 3* High O&M YES YES YES YES YES YES YES*" YES As Needed" YES YES Mini-Enclosure, Negative-Pressure System" As Needed" YES" YES YES YES YES NOTES 1 The exact meaning of these three levcb will vary depending upon the exposure objectives which are sped* Tied in the design of the OiM 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 informa 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 system(s). 5 Critical barriers may be necessary or be required for specific cases by the APM. 6 The OSHA asbestos standard. Appendix O, stales that maintenance stafT employees should be instructed not to remove ceiling tiles 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 work where contact with ACM is unlikely, appen dix E recommends *No respiratory protection required. (Air-purifying respirators with highelYiciency 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. S Protective clothing should be avail able and is required by OSHA if exposure is over pennissible 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 AMfliiiaiflfe Design & Validation of an O&M Program The O&M designer should determine Building owners and/or employers the exposure objectives for the facility. must comply with OSHA and other Establishing limits on airborne asbestos applicable regulations which relate to for each work practice level determines maintenance procedures and worker the exposures that maintenance, workers . protection. Some building owners/em* and building occupants will be players might choose to simply achieve subjected to. As a minimum the regulatory compliance. Others might requirements of the OSHA regulation establish O&M programs with mote mustbe met OSHA requires that air precautionary criteria for protection of monitoring be performed to determine workers and the building environment. what level of worker protection is Regulations do not set precise Stan necessary. OSHA specifies dards for the protection of building . requirements for the determination of environments. ., airborne fiber levels and worker exposures in the Code of Federal Regulations (29 CFR 1926.58 (f)). : Examples of building environment criteria commonly used by owners are: . OSHA requires employers to determine 1. The OSHA permissible exposure initially the level of airborne fibers to... i limit (PEL) - 0.2 Cfcc by PCM which an employee will be exposed through "initial monitoring* or the use of historical data. Where historical data is available (such as the Resilient Floor Covering Manufacturer's data), the employer must determine that the v work practices used match those upon 2. The OSHA action level (AL) - 0.1 f/ccbyPCM 3. The AHERA standard, or state stan dards, requiring a comparison of inside work area samples to outride work area samples which the data are. based, and that the 4.70 structures per square millimeter material type and circumstances are the for air samples of at least 1200 liters same. OSHA then requires periodic (AHERA level where comparison to monitoring unless supplied air respirators are used Finally, additional monitoring is required (unless supplied' air respirators are used) whenever a change in workers, the activity, or equipment use occurs which might outside is not required) 5. Outride ambient air levels 6. Inride ambient air levels under con ditions where there is no active dis turbance of ACM result in exposures above the 7.0.01 fibers per cubic centimeter of permissible exposure limit,'action level air by PCM (EPA Purple Book) and/or excursion limit. These air ^ . monitoring requirements provide ; building owners and managers with the 8. Indoor air standards for asbestos as regulated by state or local agencies. information necessary to determine what level of protection is required by the federal government. State and local laws may be more stringent. 10 m noeinn and Validation of an OSM Prooram 1P9P.NIRS Exposure monitoring will be needed to durations. Readings are not instanta validate that each work practice level neous. O&M procedures are small in meets the intended exposure goals. To scale and short in duration, requiring fit within the level definitions, the fol that many procedures be repeated a lowing must hold true: number of times to enable the collection 1. Level 1 (NO Worker or Area Pro of a sample with sufficient sensitivity. tection) work practices should not The Air Monitoring Program developed result in elevated airborne asbestos for a specific facility needs to address levels. how exposure monitoring will be con ducted to provide data for use in the 2. Level 2 (Worker Protection, with design and validation of work practices. Minimal Area Protection) work The program should define exposure practices may result in localized limits for both workers and the building elevations of airborne asbestos environment. levels that will only affect the wor ker, but not the building environ ment. The Phase Contrast Microscopy (PCM) air monitoring required by OSHA for exposure monitoring does not distin 3. Level 3 (Worker and Area Protec guish between asbestos and non-asbes tion) work practices may, if uncon tos fibers and cannot measure the short trolled, result in elevations of air or thin fibers that might be detected borne asbestos levels that are suffi using Transmission Electron Microsco cient to require worker protection py (TEM). Air monitoring data for and isolation of the work area OSHA exposure might not be an accu from the rest of the facility. rate predictor of TEM results. Some 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 the 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 TEM data indicate that workers might be exposed to short 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. training of the APM and workers. The Portions of a report published in 1991 only way that a work practice can be by the Health Effects Institute (HEI) - validated is to perform the procedure Asbestos Research discuss available and monitor airborne levels during the information regarding asbestos fiber work. Personal monitoring is required sizes and their effect on asbestos related to determine if work area isolation is diseases. This report also discusses the needed. If no disturbance of ACM will current status of surface dust sampling occur (such as with many Level 1 work techniques that are used by portions of practices), monitoring might not be (he asbestos industry to determine as required. Meaningful exposure monitor bestos contamination on surfaces. ing requires sufficiently long sample 11 Design and Validation of an O&M Program 1992 NIBS Training The amount and content of worker training should correspond to the type, and quantity of ACM that the mfodial and/or mainte- nance staff wffl encounter in the course Of their work. Training should empha- size hands-on methods. The workers should leant how to use the O&M plan as well as to perform specific tasks. In adefition to spixific work practices, there are general subject areas that all O&M training should include, such as respirator training, where applicable. The APM should have training suffident to perform inspections and tdentify where asbestos will be encountered, assess the condition of asbestos-contalning materials, evaluate potential exposure, understand building componehts, building systems, building usage patterns, designing and conducting O&M activities, be familiar with clean ing and maintenance tasks, understand applicable laws and regulations, and be aware of othercrucial factors assodated with an O&M program. The position of APM is frequently held by one of the following; the building engineer, superintendent, facilities man ager, or safety and health director. In a small organization, the building own er might have this role. Regardless of who holds the position, foe APM must. be properly qualified, through training and experience, and be actively invol ved in all asbestos control activities. < APM training might consist, in part, of courses such as the AHERA approved Worker, Supervisor and Inspector/Man ager Planner courses. Worker training programs should stress the health risks associated with ashestos exposures. O&M workers need to understand the vital importance of carefully adhering to these work pncdees or to others specified in specific building O&M programs. The EPA Green Book gives guidance concerning the level of training recom mended for conducting different types of O&M activities. EPA and OSHA offices might be able to direct the user to listings of training providers. The AHERA regulation for schools indudes required O&M training and outlines a minimum training program. The OSHA construction standard con tains minimum training requirements . for construction workers Gnduding maintenance workers) exposed at or above the action level. Appendix G of OSHA standard 29 CFR 1926J8 pro vides minimum training requirements for maintenance workers where die employer does not establish full scale negative pressure enclosures, and does not utilize frill scale decontamination. State arid local regulations may impose training requirements for O&M activi i 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. Depending upon regulatory require ments applicable to O&M work,' train ing for the APM and workers might need to include "competent person" training as discussed in OSHA and EPA regulations. 12 Design and Validation of an O&M Program 1992 NIBS tO.l .1. ^ 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 sectioa If situations exist that are not covered by this manual, the APM should develop work practices appro priate to the situation based on the guidelines in this manual and other applicable sources. It might be desir able 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 in house 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 fadlity.and personnel who will perform the work. These in clude OSHA and EPA 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 1. A Job Request Form (Appendix A) should be completed for work that could disturb ACM. (Not* to APMs: Ifthe required work has been performed in the past, it might not be necessary to complete an APM checklistfor each OAM activity. Past checklists can be reusedfor the selec tion of work practices.) 2. The Asbestos Program Manager should complete an APM checklist (Figure 3) and evaluate die vork to be performed based upon the information on a com* pleted Job Request Form, available sur vey and assfssTnfnf data, awt data on past O&M activities (if available). When reviewing data and completing die APM checklist, the following should be determined: Whether the job requested is actually an asbestos O&M activity: The categories) of ACM that might be encountered during the work. The appropriate work nracticefs) to address the situation. The work prac tice summaries include a section of "related work practices" that are in tended to rid the APM in the selec tion of the proper work practice. The appropriate level of work prac tice's') to be used. Personal protective equipment, if any, for the work. 3. All of the above information should be recorded on a Maintenance Work Au thorization Form (see Appendix B). The completed APM checklist should be signed, dated and tiled. 4. Copies of information as listed on the APM checklist should be provided to the workers who will perform the work, along with the appropriate work practice checklist. If repetitive O&M activities using the same work practices will be performed in sequence over a short peri od of time, a single Maintenance Work Authorization Form may be completed to cover these situations for a single building. Note, however, that the NESHAP requirements apply to a facility if the combined additive amount of Regulated Asbestos Con taining Material (RACM) that will be removed or stripped in repetitive activities exceeds the quantities speci fied in NESHAP. Repetitive tasks might increase exposure levels such that more stringent OSHA worker protection and engineering control requirements are triggered. Caution should be used to insure that each of the repeated O&M activities is a discrete O&M activity. O&M work procedures are based on disturbing a small amount of material over a short period of time. Care must be taken to avoid violating the intent by allow ing contiguous activities that add up to a larger scale procedure and a potential accumulation of contamina tion. If a number of O&M activities need to occur at one time in one loca tion, it might be preferable to treat the work as a larger scale, non-O&M activity. The APM can set limits appropriate for a facility and O&M program that are based on quantities of ACM to be potentially disturbed in single and multiple O&M activities. Exposure monitoring procedures and methods for repetitive activities might need to be more stringent than for single activities. The forms used in Appendices A, B and C of this O&M Work Practices Manual are repro duced from the EPA Green Book for use or guidance. Users of this manu al can use these as a basis for devel oping forms for their O&M program and work permit process. It is rec ommended that O&M forms include the basic categories of information that are used on the Green Book forms. 14 Use of O&M Work Practices a 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 Work Practice Level Selection More specifically, the following are Factors The work practices included in this manual are written to help building owners develop site-specific procedures factors for evaluation by a properly trained Asbestos Program Manager when selecting work practice levels: that comply with the requirements of Fiber release potendal of material or current federal regulations. The work O&M activity practice levels do not directly correspond Condition and friability of ACM to any specific regulatory requirement. Exposure and air monitoring data OSHA regulations are triggered by Training, skill and experience of disturbance of asbestos, and require that workers certain engineering controls, work Quantity of ACM to be disturbed practices, personal protection and Type and percentage of asbestos administrative procedures be used- Location and use of ACM depending on whether the permissible Exposure potential for occupants and exposure limit (PEL), action level (AL) or other personnel excursion limit (EL) will be exceeded, or State and local regulations can reasonably be expected to be O&M and other management policies exceeded, during the work. In a facility HVAC and ventilation system config where the combined additive amount of urations RACM to be removed or stripped during On-rite supervision a calendar year exceeds the EPA NESH- AP requirements, environmental agencies Definitive quantities of ACM to be must be notified and area and affected have not been specified in the environmental controls are required. work practice level examples. This is to EPA's AHERA regulations apply to any provide greater flexibility and to empha asbestos work conducted in schools. size that other factors might influence State and local regulations may be more level selection by the APM Federal stringent, and win apply. Appendix I regulatory limits are currently in the includes more information on OSHA and process of changing and state and local EPA regulations. regulations are usually in a state of flux. The APM's determination of the appro Users of this manual might have opera priate level will often be based, at least tions and maintenance program objectives in part, upon the quantity of ACM to be which are more protective than the disturbed. The work practices are gen minimum regulatory requirements. erally designed for disturbing small Accordingly, it might be appropriate, in amounts of asbestos as required to per the selection of work practice levels, to form O&M tasks. consider more than just the OSHA regulated exposure levels. The conditions of the building and the O&M program objectives will dictate the work practice level necessary. 16 > I to of OftM Work Practices 1992 NIBS 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 the 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 work 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 may dictate the num ber of workers needed. General Proce dure APMS includes additional informa tion on assigning workers. Work Practice Checklists The 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 a 1992 NIBS > 11. Asbestos Program Manager General Procedures Figured: APM Checklist Asbestos Program Manager (APM) Checklist for Operations and Maintenance Work Practice Use Receive and review Job Request Form - Set Appendix A. Work to be performed:______ ;________ ' ___________ Review or request survey data to determine whether ACM Is affected. Complete Maintenance Work Authorization Form, including: - Sm Appendix B. Review historical air monitoring data for work practices to be used. i Work Practiced) selected for all ACM to be encountered - See Seedta t Figmrta 1,2. - . Select personnel protecflve equipment and decontamination requirements to v:be used, if needed St* General Pnctdtrt APH1. ' ' Select appropriate materials and review potential hazards (confined spaces, scaffold use. etc.) - Sm General Procedures APU8 A APM9. Schedule work when area Is not in use or plan developed to isolate area QI necessary) -See General Procodmre APM2. Federal, state and local notifications filed flf applicable) See General Procedure APUX ' Notify personnel affected by work * See Genend Procedure APM4. Assign workers (or contractor) with appropriate level of training. Verify currency of iraining. At tests, and medical surveillance >SM<*MrafAvMdw*APM5 Assign trained air monitoring person and determine air monitoring to be performed (if needed). Record air monitoring requirements on Maintenance Work Authoriza tion Form - St* General Procedure APM6. - Provide copies to workers/contractor of: Maintenance Work Authorization Form Work practice checklist for proper work level Work practiced): General Procedures) __________ "______________ ' Nodficadons Schedule of work - ; O As pracdcal, review work practices during work for compliance with requirements, and worker general procedures. Complete Evaluation of Work Affecting ACM form - Sm Appendix C G File all required records in proper files - Set Central Procedure APM71 . Signature: _________________ Data: __ _________ ' . -. 20 Asbestos Program Manager General Procedures a 1992 NIBS Section II Asbestos Program Manager General Procedures All references In this manual to Asbestos Program Manager (APM) refer to a person designated to perform the Asbestos Program Manager's dudes. This could be the building manager, owner, or another person reporting to the APM. The Asbestos Program Manager or a designee should review work practices with the workers who will perform the work. Workers should be nodded to consult with the APM or designated person if they have any questions during the work. If any problems occur, 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 genual procedures are referenced in APM Checklist .................................... the work practices and in the APM checklist The general procedures should be covered in O&M training related to die 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 the 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". 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 work practice. 21 a Asbestos Program Manager General Procedures a 01992 NIBS APM1 Selection of Personal Protective ful to the APM. Review of this addi Equipment & Decontamination Procedures Selecting personal pro tional information is strongly encour aged. tective equipment (PPE) for O&M ' In certain situations, full face respire work includes the selection of respin- : tors might be desirable to provide tors, protective clothing, gloves,boots, hardhats, and/or other equipment that additional eye and face protection for workers. Powered Air Purifying Respi might be necessary for a specific task. rators (PAPR's) are preferred by many The information in Appendix *G" : workers instead of negative pressure discusses general safety considerations 'respirators. OSHA regulations 29 CFR diat may affect equipment selection. 1910.1001 and 29 CFR 1926.58 require Respirators used for O&M acdvides must be selected based on the requirements of regulations and a * Respiratory Protection Program devel that an employer provide a PAPR in lieu of a negative pressure respirator if an employee chooses to use this type of respirator. oped in accordance with OSHA' : Depending upon the type of work and standard 29 CFR 1910.134 or the EPA , work practices to be used, combination "Worker Protection Rule" (40 CFR respirator filter cartridges or a Afferent 763.120,121), as applicable, for the type of respirator might be necessary to O&M workers. Appendix .'E' ofthe protect workers from other contami Gpeea Book includes EPA's recom nants or hazardous substances. Respi mendations on the types of respirators ratory protection for asbestos work to be used for custodial and mainte requires the use of high efficiency nance tasks. Liability concerns, histor particulate air (HEPA) filter cartridges. ical data and management policies might also influence whether respire- tors are used, and if so, the type of respirators for O&M activities. NIOSH recommends minimizing occupational exposure to cancer producing sub- : stances, such as asbestos to the, lowest feasible level. In practice, a maximum exposure level for workers of 0.01 fibers per cubic centimeter of air inside the respirator is commonly used when respirators are selected using protection factors. . Protective Clothing &Decontamlnatlon Procedures Protective clothing for O&M work typically consists of disposable coveralls, gloves and/or boots. Protective clothing for O&M ' work can-be selected by the APM or the worker, depending upon the O&M procedures. Protective clothing options that are typically used are discussed in Worker General Procedure W6. The : protective clothing option selected might depend in part upon the decon tamination procedures to be used and OSHA has stated that the OSHA pc- the type of work area preparation or rmissible exposure limit was selected enclosure. as a technical and economic compro mise for industry, and is not designed to totally prevent cancer causing expo sures. The EPA's White Book and the Introduction and Section 01362 of the NIBS Asbestos Abatement Guide Spec ification contain information regarding respirator selection that might be help- Decontamination procedures typically used for O&M work include HEPA vacuuming on a drop doth, changing in a change room, or showering. Worker General Procedure W14 ex plains the decontamination process for each option. 22 Asbestos Program Manager General Procedures 01992 NIBS APM l--continutd Hie 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 closed 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 notification requirements. All noli- ' 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 agencies concerning notification requirements for emergen cy work. APM3 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) rales 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 sions 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 nonschedulcd operations during a calendar year (Jan uary 1 through December 31) exceeds the amounts listed above, a NESHAP notice must be submitted at least ten working days before the end of the calendar year (e.g. December IS) pre ceding the 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 Asbestos Program Manager General Procedures 01992 NIBS APU 3~ccrtinud APM4 alternative emission control methods (dry removal). . The NESHAP notification requirements for emergency renovation work are set forth in 40 CFR 61.145 (a) and (b). More information on emergency work is included in General Procedure APM- 10. See Appendix H (2.B and 2D) of this manual, and the NESHAP regulations for details on Federal notification re . quirements. OSHA's proposed regula tory changes include adding notifica tion requirements in the OSHA regula tions. Additional requirements might also be included in state or local regu lations. State and Local Notification Require ments State and local notification requirements vary greatly. Many states and localities have notification require ments that are more stringent than the federal requirements. State and local requirements concerning permits for any repair or renovation work must be reviewed State and local requirements must be complied with before work is scheduled and commenced The EPA Regional Contacts (listed on page 37 in the Green Book) can provide informa tion on obtaining copies of state and local regulations. Notification of Personnel persons who use, occupy; or are affected by an area where ACM work will occur should be notified prior to the start of the work. Proposed changes to the OSHA regulations include mandatory notification of certain personnel prior to tiie performance of work regulated by OSHA. Notification of personnel is usually not necessary for Level 1 O&M activities. Personnel should be given information about the specific work to be performed, the work sched ule, precautions being taken, what will be visible during the work, and that posted warning signs must be obeyed. Section 4 of the Green Book includes information on occupant, tenant and worker notification of the presence of ACM that might be helpful to the APM. If O&M work occurs frequently' or for Level 1 Tasks where notification is needed, a general notice to affected personnel might be more convenient than notifying these personnel each time work occurs. State and local regulations may also include personnel notification requirements. APM5 Assigning Workers assigned to per form O&M work should have training and experience in the skills and tech niques required for the type of work to be performed, training in applicable asbestos O&M procedures, the O&M plan for the facility, and site-specific building conditions. The EPA Green Book gives guidance concerning the level of training recommended for conducting different types of O&M activities. EPA and OSHA offices might be able to direct the user to listings of training providers. The AHERA regulation for schools includes required O&M training and outlines a minimum training program. The OSHA construction standard con tains minimum training requirements for construction workers (including maintenance workers) exposed at or above the action level. Appendix G of OSHA standard 29 CFR 1926.58 pro vides minimum training requirements 24 Asbestos Program Manager General Procedures a 1992 NIBS APM S-xanUnutd APM 6 for maintenance workers where the employer does not establish full scale negative pressure enclosures, and does not utilize full scale decontamlnatioa 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 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 a task, the APM should review the work prac tice with the workers, if needed. Developing the Air Monitoring Program and Assigning Air Mont* toring Personnel Note: 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 address for O&M wort. 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 requirements 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 NlOSH 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 lor 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 General Procedures 01992 NIBS APU 6^contnutd monitoring, historic data and periodic monitoring: Initial monitoring is discussed in para graph (f)(2) of OSHA standard 29 CFR 1926.58: "Initial monitoring.(i) Each employer who has a workplace or work operation covered by this standard, except as pro vided for in paragraphs (fX2Xii) and (fX2Xiil) of this section, shall perform Initial monitoring at the initiation of each asbestos, tremolite, anthophyllite, actinolite job to accurately determine die airborne concentrations of asbestos, tremolite, anthophyllite, or actinolite to which employees may be exposed." Data generated by exposure monitoring performed in accordance with OSHA requirements may be used for historical data initial monitoring exemptions. The OSHA requirements for exposure mon itoring data under the Construction In dustry Asbestos Standard (29 CFR 19 26.58) are specified in paragraph (f)(2)(lii): "Where the employer has monitored each asbestos, tremolite, anthophyllite, or actinolite job, and the data were ob tained during work operations conduct ed under workplace conditions closely resembling the processes, type of mate rial, control methods, work practices, and environmental conditions used and prevailing in the employers current op erations, the employer may rely on such earlier monitoring results to satis fy tile requirements of paragraph (f)(2)(i) of this section." (Paragraph (fX2Xi) is the initial monitoring requirement.) OSHA then requires periodic monitor ing unless supplied air respirators are used. Periodic monitoring is discussed in paragraph (fX3) of OSHA standard 1926.58: "Periodic monitoring within regulated areas. The employer shall conduct dai ly monitoring that is representative of the exposure of each employee who is assigned to work in a regulated area. Exception: When all employees are equipped with supplied-air respirators operated in the positive pressure mode, the employer may dispense with the daily monitoring required by this para graph." Termination of monitoring is discussed in (fX4) of OSHA standard 1926.58: "Termination of monitoring. If the periodic monitoring required by para graph (f)(3) of this section reveals that employee exposures, as indicated by statistically reliable measurements, are below tiie action level, the employer may discontinue monitoring for those employees whose exposures are repre sented by such monitoring." Once data are generated for a certain work practice in a given facility, the APM should be able to judge whether that level of work practice is appropri ate for OAM work in that facility and whether more air monitoring is neces sary. In certain situations (ix. remov als of resilient floor coverings using manufacturer's recommended practic es), OSHA has allowed the use of data generated by third party manufacturers to support a claim for an exemption from initial air monitoring. Personal air monitoring is required following changes in work practices, employees, employee skill levels, or other pertinent factors which could lead to the OSHA action level or exposure limits being exceeded. Validation of the work practices using air monitoring data applies only when die OSHA monitor ing requirements listed above are met. Personal monitoring should consist of 26 Asbestos Program Manager General Procedures a 1992 NIBS APM 6~contnu*i 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 the local OSHA office. The use of TEM analysis or settled dust sampling to evaluate the need for predeaning 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 analyti 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 the 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 flies: 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 OSHA'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 Sm 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), the EPA Worker Protection Rule (40 CFR 763 Subpart G) and the Green Book for details on recordkeeping requirements. 27 Asbestos Program Manager General Procedures 01992 NIBS APM 7~canUnutd APM 8 Note that state and local regulations may require that additional information be recorded and retained. EPA recommends that building owners make available all written elements of the O&M program to the building's O&M staff as well as to tenants and building occupants, if applicable. Building owners are also encouraged to consult with their legal counsel con cerning appropriate recordkeeping strategies as a standard part of their O&M programs. Confined Spaces confined spaces are often encountered in O&M work. Probably the most common areas encountered are crawlspaces, utility and pipe tunnels, manholes and chases. Special precautions are necessary for working in confined spaces. A confined space program. Including an entry permit system, must be developed for use when confined spaces must be entered. The APM or another staff person should be able to identify and assess hazards associated with confined spaces. Procedures should be developed to address potential confined space hazards. NIOSH publication number 87-113 (July 1987), entitled "Guide to Safety in Confined Spaces", includes a checklist for safe entry into confined spaces, as well as general information on confined space issues. Confined space hazards include, but are not limited to: Low oxygen content Toxic atmospheres (gases, vapors and dusts) Hazardous chemicals Explosive atmospheres Heat'stress Fire Retention of dust and smoke Insufficient lighting Flooding Electrical shock hazards Noise Program elements should include: Entry and exit procedures Standby/emergency rescue procedures Head protection (from bumps, scrapes, cuts, abrasions) Worker communication procedures Entry permit system Atmosphere monitoring Ventilation Isolation Respiratory protection Depending upon the hazards present, monitoring and special precautions might be needed during the work to maintain a safe work area. As of, September 1992, OSHA had developed draft regulations (29 CFR 1910.146) concerning work in confined spaces. The preamble to the proposed rales discussed the types of hazards that will be covered by these regulations. The user of this manual might wish to obtain and review a copy of these proposed rules if confined spaces will be encountered in O&M work. Appendix G includes general information on safety considerations that should be reviewed if work will take place in confined spaces. 28 Asbestos Program Manager General Procedures 01992 NIBS APM9 APM10 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 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 0.1S 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, but is not widely used since it tears easily. Polyethylene is also avail able in fire retardant and anti-static types. Fire retardant polyethylene does not sup port flame as readily as standard 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 the intended use. Use high temperature rated encapsulants for heat ing 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. Lockdowns are available in clear or colored mixtures. Gear mixtures should be used where a colored encapsulant would be objectionable for ap pearance reasons. Colored encapsulants should be used (where possible) 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 full 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 III. Worker General Procedures Figure 4: Pre-Work Activities Level 1 Worker Checklist Operations and Maintenance 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(s) (as-applicable) : Schedule for work . > ; Review work practices and Count Pnetdmnt W1,W5, WIO, W12, W14, WiS and any other general procedures used in work practice. / ' Inspect work area for visible dust or debris. If present, stop work ! and notify APM . Obtain recommended tools, equipment and materials as described in Gaunt Procatmn Wl, work pnctic*(t) Mam 2, and Maintenance Work Authorization Form. Move tools, equipment and materials to weak area. Shut off and lock out any HVAC or electrical systems to be worked on. i If required, on Maintenance Work Authorization Form, put on respirators and perform fit checks - Sm Count Pnemdmn. WS.' j Work Practices Clean-Up and Tear-Down Perform work per steps in work practiced). ' Remove lockout tags (If used) ft restart any HVAC/electrical system(s) that were shutoff. Return tools, equipment and remaining materials to storage area. Notify Asbestos Program Manager or supervisor that work is completed ft return documents to APM : . j ; i " . 1 32 Worker General Procedures 1992 NIBS Section III 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 the 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 the 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 the 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 Encapsulate.................................... 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 Gothing............................................................. 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 Encapsulate.................................................................... 45 W12 Geanihg Tools, Equipment and Work Area .................................................46 W13 Decontaminating Waste ................................................................................... 46 W14 Worker Decontamination and Removal of Protective Clothing and Respirators..............................................................46 W1S Visual Inspection and Completing Air Monitoring.......................................47 W16 Waste Transportation, Storage and Disposal.................................................48 W17 Glovebag Removal ...........................................................................................48 W18 Disposal of Contaminated Water..................................................................... SI Note: Not all of the worker general procedures are used in every work practice. 33 Worker General Procedures 1992 NIBS Figure 5: Level 2 Worker Checklist Operations and Maintenance Work Practices Pie-Work Activities O Work Area Work Practices Obtain and review copies from Supervisor,,or Asbestos Program Manager of: Completed Maintenance Work Authorization Form Work practice^) to be used including personal protective equipment options Work Notification(s) (as applicable) Schedule for work ; ^ `* Review work practices and referenced general procedures used in work practiced). Obtain recommended tools, equipment arid materials Set General Procedure WI and work practkt(t) item 2. Obtain required respirators as listed on Maintenance Work Authorization Form, ' i Move tools, equipment and materials to work area. Shut off and lock out HVAC and electrical systems servfog work area See General Procedure W3. 1 , /. ; ' Vacate and secure work area, such as by locking doors and/br setting up temporary banders - Sot 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) * Sm General Procedure W7. . .i Preclean work area if visible dust or debris is present - Sm Omani Procedure WS. Set up work area as requiredby work practice item 3 - Sot Gtmtnd Procedure W9. Perform work per steps in work practiced). Cl68n-Up and Tear-Down n Package and label asbestos waste for disposal - See General Procedure W10. Apply lockdown encapstriant. Where required, using garden sprayer, to surfaces ; where ACM was removed or disturbed - See General Procedure WU. Perform ceiling panel repiacemeot work or ceiling repair work if needed. i , Clean tools, equipment and work area using wet wiping and HEPA vacuuming as appropriate and return fools and equipment to outride work area - J See General Procedure W12. j Decontaminate packaged waste St move waste to outride work area - - Stt General Proetdurt WI3. : ; Workers decontaminate' and remove protective clothing and respirators. If contaminated, dispose of protective clothing as ACM - Stt Central Procedure W14. Complete visual inspection. Complete air monitoring work See General Procedure WIS. ; , If feasible, get APM or designee to complete Evaluation of Work Form. ! Transport waste to designated asbestos waste storage area See General Procedure W16. ' Remove drop doth. < . | Return decontaminated tools, equipment and remaining materials to storage area. Remove lockout tags and restart HVAC/electrical system(s). Restore normal accessibility to work area. . ! ' Notify Asbestos Program Manager or Supervisor that work is completed St return documents to APM. ' 34 Worker General Procedures 1992 NIBS Figure 6: Level 3 Worker Checklist Operations and Maintenance Work Practices Pre-Work Activities Work Area Work Practices Obtain and review copies from Supervisor or Asbestos Program Manager of: Completed Maintenance Work Authorization Form Work practice(s) to be used including personal protective equipment options Work Notification(s) (as applicable) Schedule for work Review work practices and referenced general procedures used in work practices). Obtain recommended tools, equipment and materials Sm General Procedure Wl and work practical) item 2. Obtain required respirators as listed on Maintenance Work Authorization Form. Move tools, equipment and materials to work area. Shut off and lock out HVAC and electrical systems serving work area Sot Goheral Procedure WJL Vacate and secure work area, such as by locking doors and/or setting up temporary barriers - Set Gerund Procedure W4. Put on respirators and perform fit checks - See General Procedure W5. 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 W& Set up work area and decontamination facilities as required by work practice item 3 - See General Procedure W9. Perform work per steps in work practice^). Clean-Up and Tear-Down O Package and label asbestos waste for disposal - See General Procedure W10. Apply lockdown encapsulant, where required, using garden sprayer, to surfaces where ACM was removed or disturbed See General Procedure Wll. ' Perform ceiling panel replacement work or ceiling repair work if needed. Clean 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. Decontaminate packaged waste & move waste to outside work area See General Procedure W13. Workers decontaminate and remove protective clothing and respirators. If contaminated, dispose of protective clothing as ACM - See General Procedure W14. Complete visual inspectioa Complete air monitoring work See General Procedure W75. If feasible, get APM or designee to complete Evaluation of Work Form. Transport waste to designated asbestos waste storage area See Gerund Procedure W16. Remove drop cloth and/or mini-enclosure. Return decontaminated tools, equipment and remaining materials to storage area. Remove lockout tags and restart HVAC/electrical system(s). Restore normal accessibility to work area. Notify Asbestos Program Manager or Supervisor that work is completed & return documents to APM. 35 Worker General Procedures 1992 NIBS W-1 W-2 Tools, Equipment and Materials The Abatement Equipment and Materials following is a list of tools, equipment and ;a Polyethylene sheet materials that are referenced in the work a Duct tape practices and are recommended to perform the work practices. Tools, equipment or a # Disposal bags with labels materials that are'unique to a certain work High effidency particulate air practice are listed under item 2 in each (HEPA) vacuum with hose, attachments and proper HEPA filter work practice. For frequent O&M work, it might be helpful to maintain an "0&M (wet/dry type needed for some work practices) cart" containing the necessary tools, a Respirators (if required) equipment and materials. a Disposable coveralls Of required) Tools and Equipment Disposable towels or wet wipes Utility knife ; Ground fault circuit interrupters (GFCI's), Extension cords and adapters - GFCI's should be used on any electrical equipment or tools used in O&M work where water might be in use or present in the work area. Lockout tags Temporary work lights Ladder or scaffold for elevated work Wet wipes or bucket with dean water for wet wiping Smoke test bulb and tubes ,' Bone saw. Wire cutters Asbestos barrier tape . Warning signs' . Garden sprayer with amended water or removal encapsulant (Level 2 arid ' 3 practices) See general procedure W2. . Aerosol cans or garden sprayer with lockdown encapsulant (Level 2 and 3 practices) . Air monitoring pumps, cassettes and calibration equipment (if required) . Frame for mini-enclosure or ^ prefabricated mini-endosure (Levd 3 practices) . Negative pressure machine (HEPA filtered exhaust fan) as required for Tin snips Safety glasses size of enclosure (levd 3 practices could be negative pressure machine or additional HEPA vacuum) Manometer Of pressure differential measurements are desired) Glovebags Of required) Preparing Amended Water or Removal Encapsulant Amended water or removal encapsulant solutions are prepared by mixing a measured amount of surfactant or encapsulant with dean water in accordance with the manufacturer's . instructions. Surfactants and encapsulants materials might be considered hazardous substances. Containers of amended water or removal encapsulant should be labeled to identify the contents in accordance with the OSHA Hazard Communication Standard (29 CFR 1910.1200). Review and comply with Material Safety Data Sheet (MSDS) before mixing and using these materials. Amended water or removal encapsulant should be mixed in a labeled garden sprayer unit prior to the start of an O&M activity. Some practitioners have reported that liquid dishwashing detergent might be used as a surfactant for O&M work. They have used a mix of 8 parts water to one part detergent 36 Worker General Procedures 01992 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 the 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 the 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 readfiy 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 General Procedures 01992 NIBS W-5-.conBntMd Putting on Respirator Wearers should inspect their respirators before each use of the respirator. Respirators must not be damaged, have missing parts or be deformed in any way. The straps must be intact and well attached. Proper filter cartridges for the hazards to be encountered must be installed. Verify that filters have been replaced in . accordance with the Respiratory Protection Program. Batteries for powered respirators should be fully . charged. The respirator should also be cleaned if it was not cleaned after die last use. If any problems exist, the respirator should.be repaired or replaced in accordance with the Respiratory Protection Program. When putting on a respirator, the straps should be loosened before it is put on. Filter caps (such as those used on some Powered Air Purifying Respirators) should be taped to the filter body or stored where it will not be lost Powered respirators should be turned on and flow checked before the facepiece is put on. The respirator should be put on and then the straps tightened as recommended in the . manufacturer's information provided with the respirator. Fit checks should then be performed. Fit Checks Fit checks should be performed in accordance with the Respiratory Protection Program by each worker each time they put on a respirator. Both positive and negative pressure fit checks should be performed. When feasible, powered respirators should be checked with the motor unit turned off. A negative pressure fit check is done by donning the respirator and pulling the respirator straps so the unit fits snugly. Inhale gently while placing hands over filters to block off inhalation side. Respirator should pull to face and no air should leak in around face seal. A positive pressure fit check is done by exhaling gently (without breaking respirator seal to face) breathing normally while blocking off the exhalation valve. The face piece should then expand away from face while exhaling. ' Adjust respirator straps as needed to obtain a good seal of foe facepiece to the face. If a good seal cannot be obtained, obtain a new respirator and perform fit tests again. Putting on Protective Clothing Protective clothing for workers typically consists of disposable coveralls, gloves and boots. Coveralls should have hoods and booties attached. They should proride complete coverage of the body with foe exception of hands and face. Cloth coveralls that are cleaned by a facility equipped to launder asbestos contaminated clothing might also be used. Do not modify coveralls. Protective Clothing Options Available for O&M Work Include If potential for exposure to asbestos-containing dust and debris is low and localized, use: 1. One disposable coverall with no street clothes, or 2. One disposable coverall over street clothes. If potential for exposure to asbestoscontaining dust and debris is moderate or dispersed, use: 1. Two disposable coveralls with no street clothes, or 2. Two disposable coveralls over street clothes. 38 Worker General Procedures 01992 NIBS W-6~.continiHd W-7 If street clothes could become contaminated, two coveralls should be worn, or die street clothes should be removed before the start of work. When posable, street clothes should be removed in a changing area before protective clothing is put on. Protective clothing should be put on after respirators. Hie 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 Mr Monitoring Program and specific protocols neededfor OAM 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, area 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-five 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 39 Worker General Procedures a 1992 NIBS W-7~continu*d W-8 forty-five degree angle. The air r , monitoring person will retrieve or \ change cassettes as needed or when the work is completed. , .. If any samples analyzed during the work exceed predetermined "stop work levels" specified in the O&M program, productive work shall bestopped, the area Cleaned and additional engineering controls implemented, as necessary. Precleaning Work Areas and Wet Wiping Hredeaning of work areas prior to the start of work is done to remove accumulated debris that could be disturbed during the work. . Precleaning might include picking up . dust and debris widi a HEPA vacuum, wet wiping non-parous surfaces, HEPA vacuuming surfaces that cannot be wet wiped, and cleaning any carpeted surfaces uring steam extraction equipment Ptedeaning might reduce - the extent of cleaning required after the work and for dearances (if required). Wat Wiping The procedures to be used for wet wiping are as follows: 1. Immerse disposable towel in bucket containing amended water. 5. Dispose of used towels in disposal bags. 6. Dispose of contaminated water as required by applicable regulations St* gtmtnd pnctdar* W18. HEPA Vacuuming The procedures to be used for HEPA vacuuming are as follows: 1. For floors, use a floor attachment with rubber floor seals and adjustable floor-to-attachmcnt bright For furniture, fabrics or other surfaces use an upholstery . attachment or brush attachment. 2. Vacuum hard or smooth surfaces , with attachment about 1/16" (2 mm) above die surface. 2. Wring out towel and fold into quarters. 3. Wipe surface and refold to have a clean face exposed. Do not place , towd back into bucket or water will become contaminated and will need to be replaced. ' ,. , 4. Repeat step 3 until all faces of towd have been used. Obtain a clean . towd if more wiping is needed. 3. Vacuum carpet or fabrics with attachment Just touching the surface. '' 4. Vacuum all surfaces in paralld - ..passes with each pass overlapping die previous one by one-half the width of the attachment. 5. Once surfaces are cleaned in one direction, dean a second time at right angles to the first cleaning. 6. Use crevice brush or other tools to clean irregularly shaped surfaces. 40 Worker General Procedures 01992 NIBS W-8~continued W-9 Steam Cleaning Carpet The procedures to be used for steam cleaning carpet are as follows: 1. Steam dean carpet using carpet tool 2. Steam dean all surfaces in parallel passes with each pass overlapping the previous one by one-half the 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 Set W18. Setting up Work Areas Not't: 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 cf fiber control (hiring O&M work. Polyethylene protection, glovebags, and mini-enclosures are intended as a secondary means ofprotection during die work. State or local codes might require thatfire retardant polyethylene be usedfor asbestos related work. The NIBS Asbestos 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 mini enclosure. Other techniques, such as the use of a glovebag taped over a self supporting framework might also be used as a substitute for the spedfied 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-endosure. Polyethylene Drop Cloth Preparing a work area with a drop cloth 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 (or 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 W-9~conttnued V/ Mini-enclosures also serve to provide a visual barrier between the workers and any other personnel around the work area. As noted above, careful work ; practices should be the primary means of fiber control during the work in order to prevent gross contamination of the mini-enclosure. : .. It is sometimes appropriate to extend 1 mini-enclosures above ceilings, such as by using polyethylene sheet and toning taped togefter to provide ; . enclosure around fte work area. The mini-enclosure should not contact \ i ACM covered surfaces. The , : construction will vary depending on whether the enclosure will be attached to pipes, conduit, metal hangers, or some other form of existing , A'.~. construction. There are a variety of commercially available types of mini-enclosures, ; including prefabricated pop-up boxes and adjustable framework assemblies to permit different sizes of enclosures to be constructed. Disposable liners for mini-enclosures (to facilitate set up and dismantling of the enclosure) are available from some manufacturers. It might be beneficial to construct or purchase a portable mini-enclosure unit that works for the typical conditions found in a given facility. It is recommended that two workers be used to set up and operate mini enclosures., To construct a mini- , enclosure, erect a framework of wood, PVC piping or metal framing that will enclose the work area and be large enough for one person to work inside. The minimum width and depth of the enclosure should be at least 3 feet (1 meter). The height of the enclosure will vary depending upon the work to ' be performed and the height of the work area. A larger enclosure is : preferable, where space permits. However, if the enclosure is too large. the'final cleaning process anil require more time. A mini-enclosure can include a separate 3 foot by 3 foot by 7 foot (1 x 1 x 2.1 meters) change room, with curtain doorways, attached to the mini-enclosure for changing and removing protective clothing. If an entire room will be enclosed for performing work, the framework is usually not necessary, unless wall surfaces will be damaged by tape used to support polyethylene. A room can be enclosed for O&M work by installing one layer of polyethylene sheet on the walls and floor of the room. If the work to be performed is In an elevated location, the enclosure (and change room, if used) should be erected on a scaffold platform large enough to support the enclosure, change room (if used), and a step off area outside die enclosure. Refer to OSHA regulations 29 CFR 191028 and 29 CFR 1926.431 concerning scaffold requirements. Any ladders and/or scaffolds used must be built and used in conformance with the OSHA construction standards, and applicable state and local standards. Sm Appendix G of this manual. Cover the floor and the framework for the enclosure and change room with one layer of polyethylene attached using duct tape. A second layer of polyethylene laid on the floor might facilitate clean up work, or reduce the possibility of tearing the polyethylene if equipment is used (do not use two layers under the legs of ladders). Construct curtain doorways between the change room and the enclosure and 42 Worker General Procedures 61992 NIBS W-9~.continiMd 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 the 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, the enclosure should be separated from the ceiling 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 synonym for '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 Btdldings: Model Guide Specifications Section 01513 Temporary Pressure Differential & Air Circulation System" gives guidance on 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 Procedures 1992 NIBS W-9~continu*l W-10 possible. However, most vacuum units do not provide a connection for an i exhaust duct, and are commonly exhausted to the inside. 'Additional protection might be desirable fbr an area where air is exhausted inside a. building. A work'practice is provided for changing filters in HEPA vacuums and negative pressure machines (HEPA filtered exhautf fans) when needed. Filters should not be changed without ,, following these work practices. When HEPA filtered local exhaust ventilation is used in a work practice, this can be in addition to, or in place of, a negative pressure system. A HEPA filtered local exhaust ventilation system might replace a negative pressure system if the ventilation system provides adequate negative pressure in the work area.. Some work practices use HEPA filtered local exhaust ventilation for fiber control . where an enclosure is not used. A HEPA ventilation system can use a HEPA vacuum or negative pressure machine, the hose attached to the HEPA unit should be kept as close as possible to the location where ACM might be, or is, disturbed. j I j ! j | , ; Packaging and labeling Waste .. layer should be sealed tightly with duct Asbestos-containing waste material from O&M activities should be tape; Label outer layer as required by regulations. adequately wet In accordance with the s NESHAP requirements (40 CFR 61. ISO). Verify waste packagiqg and other waste disposal requirements with the landfill that will.receive the asbestos waste. Re-labeled asbestos Sharp objects that might puncture polyethylene (such as floor tile) should be placed into cardboard boxes before wrapping in one or two layers of 6 mil (0.15 mm) polyethylene. , disposal bags should be used for All waste should be labeled as required asbestos waste disposal where possible, by federal, state and local regulations. appropriate and permissible. Disposal Federal regulations requiring labeling bags should be collapsed by evacuating of waste indude OSHA regulations 29 the air from the bag with a HEPA CFR 1910.1200, 1910.1001 and vacuum in the work area or enclosure: 1926.58, EPA's NESHAP regulation Once collapsed, twist the bag to form a 40 CFR 61.150, and the Department of neck and wrap it tight with duct tape. Transportation's Hazardous Materials Fold neck of bag over to form a loop, Regulations 49 CFR 171 and 180. . then again wrap duct tape around neck ACM packaging, with some and loop. exceptions, must meet general DOT Although not a federal regulatory requirement, asbestos waste is often, placed into second disposal bag and sealed as described above;: Label disposal bags as required by applicable; NESHAP. OSHA and DOT regulations. and EPA requirements and be protective, marked and labeled. See Appendix I for further information. Review current labeling requirements with APM and disposal site. The : OSHA requirements apply regardless of the amount of waste or measured exposure levels (see 29 CFR Asbestos waste that does not fit into 1926.580). disposal bags should be wrapped leak- tight in one or two layers of 6 mil (0.1S mm) polyethylene sheet Each f I ' ; * , > ! ! i ! j ! ! 44 Worker General Procedures 01992 NIBS W-10~.conttoumi W-11 Labels Requirements Include: 0SHA2SCFR 192SJ58(k)(2) requirement: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD Department ot 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 DOT asbestos descriptions) PG III (or II or II), (Packaging Groups for the 3 DOT asbestos descriptions; 11 and ID are medium and minor; use D 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," croddotite 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 1910.100l(jX2) or 1926.58 (k)(2Xiii) 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 61992 NIBS MM2 W-13 W-14 Cleaning Tools, Equipment, and Work Area Clean tools and . equipment using HEPA vacuuming, and/or wet wiping procedures. Special attention should be given to cleaning extension cords, equipment wheels, vacuum hoses and other items that could pick up debris during the work. Tools and equipment should be placed outside of the work area as soon as cleaning is completed. Drop cloths and mini-enclosures can be cleaned or disposed of as ACM. Any items that cannot be fully cleaned (such as boots or tools) that might be used in another OAM activity should be placed into disposal bags, sealed and labeled as ACM. Hiese bags should be wet f wiped and then placed outside of the work area with the other tools and equipment Do not open bags : containing contaminated tools, or open equipment such as a HEPA vacuum, , except during another O&M activity or in a designated work area. HEPA vacuum hoses can be sealed with tape ; oyer both ends if the outside of the i hose is dean. Cleaning of the work area where an i O&M activity is conducted consists of ; HEPA vacuuming and/or wet wiping 1 (as appropriate) all surfaces in the area. HEPA vacuuming and wet wiping shall be performed as described in general procedure W8 above. Decontaminating Waste Packaged waste should be HEPA vacuumed and wet wiped before it is moved out of > the work area. Use the wet wiping and HEPA vacuuming procedures in general procedure W8. Packaged waste should be placed on.a sheet of polyethylene when it is moved outside of the work area. This polyethylene can be the outer portion of a drop doth, if a drop doth is being used. Worker Decontamination and Removal of Protective Clothing and Respirators Removal of Protective Clothing (if used) Decontamination and removal of protective clothing following O&M activities should use the applicable procedure(s) described below: Removal of Protective Clothing When Drop Cloth Work Area Protection, or no Work Area Protection, is Used HEPA vacuum all partsof protective clothing while standing at perimeter , 'of drop cloth. Leaving respirator in ^ place, remove protective clothing and fold inside out as it is removed. Place clothing, if contaminated, into a disposal bag and label as ACM waste. Removal of Protective Clothing If A Mini-Enclosure and Change Room Is Provided HEPA vacuum an parts of protective clothing while inside work area enclosure. If two disposable coveralls are used, remove outer coveralls in work area while leaving respirator in place. Fold coveralls inside out as they are removed. Move to change room, HEPA vacuum protective clothing, and remove second set of coveralls in the same manner. If only one set of disposable coveralls is worn, remove in change room while leaving respirator in place. Fold coveralls inside out as they are removed. 46 Worker General Procedures 01992 NIBS W-14-continod W-15 Place protective clothing, if contaminated, into a disposal bag and label as ACM waste. Wadi 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, foDow the applicable clothing removal procedure described above. Remove protective clothing in work area and put on a dean set of protective coveralls. Proceed to Shower with respirator still in {dace. At shower fadlity, remove protective coveralls, folding inside out 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. Removal of Respirator (If used) 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. 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 respirator facepiece 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-spedfic 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 for 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 NI8S W-15.^eontinutd W-16 W-17 Mr Samples Complete air monitoring work in accordance with Air Monitoring Program and requirements noted on a Work Authorization Form. Verify that removal areas havebeen f encapsulated Clocked down"), that the work area, tools, and equipment have been cleaned, and that the area has passed a visual Inspection. When air sampling cassettes are retrieved; the air monitoring person should record the stop time to die samples and check and record the flow rate of the air monitoring pumps. Samples should be analyzed on-site (for PCM analysis) if possible, or sent to a laboratory for analysis. When sample results are received, compare results to Air Monitoring Program criteria for work release or clearance. If sample results exceed criteria, the work area should be recleaned, reinspected, and then additional air samples should be obtained. If samples are equal to or below release criteria, tear down work can proceed. Collect air sampling pumps and equipment from work area and other locations when air sampling work is completed. Waste Transportation, Storage and Disposal Transport asbestos waste from OftM activities to a designated storage area or an approved landfill . _ after the work is completed Workers transporting waste should follow Respiratory Protection Program . recommendations concerning respirator requirements to transporting asbestos waste. Do not drag packaged waste. All waste should be lifted and carried, or transported in wheeled carts, when moved from one area to another. Packaged waste should be placed, not thrown or dropped, into vehicles, storage areas and the landfill Any asbestos waste that is not taken to a landfill should be stored in a secure, lockable area. Signage in accordance with NESHAP should be posted at the storage area and on vehicles used to transport asbestos-containing waste material during loading and unloading. When asbestos waste in the storage area is taken to a landfill, it should be transported in accordance with all applicable federal, state and local regulations. Asbestos waste shipment records should be completed in accordance with the requirements in NESHSAP Section 61.1SO. The workers conducting the O&M activity should fill out part 1 of the waste tracking form included in Appendix D or an equivalent form. Once part 1 is completed and the waste is stored or taken to a landfill, the form should be turned over to the APM to complete part 2 and file with O&M records. NESHAP waste shipment records must also be completed (where applicable) and filed with waste disposal records. Glovebag Removal (Also includes other types of prefabricated removal enclosures) Remove asbestos- ; containing material inside a glove bag according to the following procedures. Glovebags should be used only once and should not be moved to another location to perform additional removal work, or reused in any way: Glovebags are available in many different sizes, shapes and configurations to accommodate the variety of removal situations that might be encountered. Glovebags are available for use in horizontal, vertical or other special applications. Since 48 Worker General Procedures 01992 NIBS W-17.~continud 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 self supporting 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 die glovebag area that could be disturbed during die work. Slit top of the glove bag open Of necessary) and cut down the sides to accommodate the removal area. Place necessary tools into pouch located inside glove bag (or into a sleeve turned Inside out). Tools needed typically include: scraper, bone saw, utility knife, disposable towels, nylon brush, abrasive pads, wire cutters, tin snips and pre-wetted 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 dosed. While holding the water sleeve tightly, gently squeeze glove bag and look for smoke leaking out, (espedally at the top and ends of the glove bag). If leaks are found, tape dosed using duct tape and re-test. If a negative pressure glovebag with a supporting framework and HEPA filtered makeup air port is bdng 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. Dud 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~xontJnutd Adequately wet material to be worked Contaminated tools might then be on with amended water and allow to placed directly into another glove bag soak in. Wet adequately to penetrate ; without cleaning. Alternatively, tool and soak material through to substrate. pouch with the tools can be placed in a Cut insulation section to be removed' using bone saw or utility knife. Use bucket of water, opened underwater, ! and tools cleaned and dried. Discard caution to avoid cutting giovebag. lift disposable towels and nylon brush with glovebag away from cutting area if asbestos waste. Dispose of contaminated water as set forth in necessary. Throughout this process, general procedure W18 below. spray amended water or removal encapsulate on the cutting area to keep Evacuate air from glovebag using dust to a minimum. HEPA vacuum. With HEPA vacuum Remove insulation using scraper or : other tools. Place pieces in bottom of bag without dropping. Rinse all tools with amended water inside the bag and {dace back into pouch or a sleeve of operating and removed insulation in the bottom of the bag, twist the bag several times and tape it to keep the material in the'bottom during removal of the glove bag from the removal area. die glovebag turned Inside out Slip a 6 mil (p.15 mm) disposal bag Using nylon brush, scrub pads, disposable towels and amended water, scrub and wipe down the removal area. over the glove bag (still attached to removal area). With the hose of an operating HEPA vacuum inserted in the upper part of glovebag, remove Seal exposed ACM around removal tape dr cut bag and open the top of the area using pre-wetted lag cloth or glove bag and fold it down into encapsulate with a bridging 1 disposal bag. - encapsulate Encapsulate removal area with an appropriate lockdown encapsulate Use suitable high : temperature encqwulants for hot piping. : Procedure B. Use of a Glovebag with SelffSupporting Frame Giovebagson self-supporting frames can be used for some O&M activities on surfacing materials, and might be able to be Wadi down inside of glovebag with adapted for other types of ACM. The amended water did wipe as necessaiy ,, general procedures for using these units to move all debris did residue to lower are as follows: part of glovebag (below where bag will be twisted and cut). Construct a rectangular or square frame of 1 1/2" (38mm) diameter PVC or Remove water wand from water sleeve, ABS pipe. Supporting legs can be twist water sleeve closed and seal with made of lengths of pipe and fittings as duct tape. . needed to achieve the required height Proprietary frames with telescoping From outside the bag, pull the tool pouch or sleeve away from the bag and > legs are available. twist pouch to seal it from rest of bag. To install glovebag on the frame, fold Place duct tape over twisted portion top edge of bag over the frame sides and then cut the tool bag from the and extend the open edge of the bag at glove bag, cutting through the least 10" (23 cm) beyond the frame. twisted/taped section. Secure the open edges to the rest ,of the bag using duct tape. Place tools and supplies needed (see glovebag 50 Worker General Procedures 01992 NIBS W-17.~eontinued W-18 procedure above) in tool pouch inside glovebag. Place frame and glovebag assembly below work location so that frame is close to, 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 die 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 General Procedures 1992 NIBS IV. Surfacing Materials Work Practices Figure 7: Surfacing Materials Location Illustration 54 Surfacing ACM Asbestos O&M Work Practices Q1992 NIBS Section IV Surfacing Materials Work Practices Surfacing Materials Location Illustration.......................................... ..................... 34 Code Levels Description 51 12 3 Moving one non-asbestos-containing ceiling panel below a plenum space that has exposed surfacing ACM .........................37 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 54 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 58 1 Replace bulbs in light fixtureattached to or insurface finished with ACM............................................................................85 59 1 Clean room with exposed surfaces finished withACM .................87 510 12 3 Repair damaged surfacing ACM.......................................................89 511 12 3 Accessing through an ACM finished surface ................................ 93 512 1 2 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 asbestos waste 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 anached to the small end of the funnel might be used in some cases to contain debris. 55 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS *ab 3. Three primary types of surfacing ACM were identified in developing work practice examples: A. Acoustical Plaster B. Decorative Texture Finish C. Fireproofing Definitions of all three are included in the glossary in Appendix E. 4.Careful work practices should be the primary means used to prevent releases of asbestos fibers during O&M work. Such practices include control measures such as wetting and local exhaust that control or collect fibers at the source. The goal of all asbestos O&M work should be to prevent any exposure of the worker and unnecessary contamination of the work area, drop cloths, mini enclosures and other secondary control devices. Mini-enclosures should never be used to excuse sloppy work or creation of "bigger" messes. 56 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS Summary SI 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 ceiling 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 instructedNot 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 V. 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 conditioa 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 52 Attach item to an ACM finished surface that is above a ceiling. 53 - Work in ceiling plenum space where exposed surfacing ACM is present 54 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 mon*toring training might be required. This person can be one of the workers. 57 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS SI Level 1 Moving one non-asbestos-containing ceiling panel below a plenum space that has exposed surfacing ACM Example Level 1: A. Move a non-ACM ceiling panel in a lay-in ceiling below exposed surfacing ACM in good condition to make observations. 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. Appendix G ofOSHA standard 29 CFR 1926.58 states that mmaintenance staff employees should be instructed: Not to remove ceiling dies below asbestos-containing materials without wearing the proper respiratory protection, clearing the area ofother people, and observing asbestos waste disposal procedures*.1 Work Practice 1. Perform Pre-work activities on Level 1 Worker Checklist 2. See General Procedure W1 for standard tools, equipment and materials list. 3. Place ladder or scaffold in work area. 4. Carefully lift up ceiling panel. If lifting is obstructed by wires, ducts, conduit etc., move to another 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. 5. Wet wipe or HEPA vacuum the underside of the panel which was moved. Carefully replace ceiling panel and complete applicable steps on Level 1 Worker Checklist to complete work. 58 Surfacing ACM a Asbestos O&M Work Practices 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 wort 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 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 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 Wl for standard tools, equipment and materials list). Tools and materials needed for work on ceiling 3. Prepare work area with drop doth. 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 SI Level 3 Moving one non-asbestos-containing ceiling panel below a plenum space that has exposed surfacing ACM. Examples 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. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a beret 3 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. . Appendix Go/OSHA standard 29CFR 1926.53 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 3 Worker Checklist 2. Additional tools, equipment and materials: (See General Procedure Wl for standard tools, equipment and materials list). Tools and materials needed for work on ceiling 3. Prepare work area with drop doth, 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. Carefully lift up ceiling pand 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 clean-up and tear-down steps on Level 3 Worker Checklist to complete work. 60 Surfacing ACM Asbestos 0&M Work Practices 01992 NIBS S2 Summary Attach component to an ACM finished surface that is above a non-asbestos-containing ceiling. Summary This work practice covers the 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: A. Attaching a pipe, ceiling or duct hanger to a deck or beam covered with ACM fireproofing, insulation or overspray. B. Attaching a pipe, ceiling or duct hanger to an old acoustical plaster ceiling above a lay-in ceiling system. Related Work Practices SI Moving one oon-asbestos-containing ceiling panel below a plenum space that has exposed surfacing ACM. S5 - Attach component to ceiling finished with ACM. S7 Cut hole in surfacing ACM. Worker One worker is usually sufficient for Level 2. Two workers for Level 3. More Recommendations 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 Surfacing ACM Asbestos O&M Work Practices a 1992 NIBS S2. Level 2 Attach component to an ACM finished surface that is above a non-asbestos-containing ceiling. Example Level 2? A. Removing a small area of ACM fireproofing using a negative pressure glovebag frame unit \\ 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 A M work practicefor accessing type of ceiling present in work area. See Work Practices Mil, M13 or M2S. . 1. Perform Pre-work activities on Level 2 checklist. 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment A materials list). . Negative pressure glovebag frame unit r Scraper 2-3" (50-75 mm) wide stiff blade Stiff nylon bristle brushes Maintenance item(s) to be attached to surface , Non-ACM surfacing repair material ' . 3. Prepare work area with drop cloth. See General Procedure W9. : 4. Place tools, equipment and materials needed into work area. Include a HEPA vacuum to use with negative pressure glovebag frame unit. 5. Obtain access through ceiling using O & M work practice selected (see note above step I). 6. HEPA vacuum area above ceiling within reach from access hole. 7. Install glovebag frame unit under area where ACM removal is needed. Do not contact ACM with frame. 8. Insert wand of garden sprayer with amended water through glovebag and [ adequately wet area of surfacing to be removed. Allow water to soak in for several minutes. Wet removal area frequently during removal of bulk material and residual material. Using glovebag procedures (see General Procedure W17), scrape off ACM to at least 3" (75 mm) beyond area where item will be attached When bulk material is removed, wet newly exposed.areas and use , scraper and nylon brush to remove remaining visible residual ACM. Place removed ACM into disposal bags. 9. Perform maintenance work, repair area with new non-ACM surfacing, and perform clean-up and tear-down steps on Level 2 checklist to complete work. 62 Surfacing ACM Asbestos 0&M Work Practices 1992 NIBS ! S2 Level 3 Attach component to an ACM finished surface that is above a non-asbestos-containing ceiling. Examples Level 3: A. 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 Level 3 Worker Checklist. The worker checklist Includes tasks that must be performed before these work practices are begun. Work Practice Coordinate work with proper 0 AM work practice for accessing type of ceiling present in work area. See Work Practices Mil, M13 or M23.1 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard tools, equipment A materials list). Scraper 2-3" (30-75 mm) wide stiff blade Stiff nylon bristle brushes Maintenance item(s) to be attached to surface Non-ACM surfacing 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 O & M work practice selected (see note above step 1). 6. HEPA vacuum area above ceiling within reach from access hole. 63 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S2 Level 3..conUnusd 7. Extend mini-enclosure above ceiling, if feasible, using polyethylene sheet and framing taped together to provide enclosure around the work area without contacting ACM covered surface. The construction of an extended mini enclosure will vary depending on the existing construction above the ceiling. Polyethylene and framing may be secured to pipes, conduit, and metal hangers if they are not covered with ACM. If an extended mini-enclosure is not feasible, mist area above ceiling and lay a polyethylene drop cloth below the area where removal is required. If drop cloth cannot be used, suspend polyethylene below immediate work area to catch ACM to be removed. Worker should be located to one side of removal area (inside enclosure) during removal. 8. Adequately wet area of surfacing to be removed using garden sprayer containing amended water and allow water to soak in for several minutes. Wet removal area frequently during removal of bulk material and residual material. Using scraper with HEPA vacuum within several inches of removal area, scrape off ACM to at least 3" (73 mm) beyond area where item will be attached. When bulk material is removed, wet newly exposed areas and use scraper and nylon brush to remove remaining visible residual ACM. Place removed ACM into disposal bags. 9. Perform maintenance work, repair area with new non-ACM surfacing, and perform dean-up and tear-down steps on Level 3 checklist to complete work. 64 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS nr-----rr I-1r- 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: (If work is likely to disturb ACM, use Lertl 2) A. Open or close one valve above ceiling where exposed fireproofing in good condition is present B. 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 ACM is present B. 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 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 One worker is usually sufficient for Level 1 and Level 2. Two workers for Level Recommendations 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. 63 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S3 Level 1 Work in celling plenum space where exposed surfacing ACM is present Examples Level 1: A. open or close one valve above celling where exposed fireproofing in good condition is present, , B. Inspect HVAC mixing box below asbestos-containing fireproofing in good condition. , . ; I Notes ' * .I t This work practice must be used in conjunction with General Procedure WI and a Level 1 ~ Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. ' .i Coordinate work with proper O AM work practice for accessing type ofceiling present,in work area. See Work Practices SI, Mil, M13 or M2S. Appendix G ofOSHA standard 29 CFR 1926J8 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 cf other people, and observing asbestos waste disposal procedures'. ; Work Practice 1. Perform Pre-work activities on Level 1 checklist. .2 Additional tools, equipment and materials: (sec General Procedure Wl for , standard tools, equipment and materials list). ; . Maintenance item(s) required to perform work in plenum space < 3. Place tools, equipment and materials needed in work area. 4. Obtain access above ceiling using 0 & M work practice selected (see note i above step 1). > ! 5. Perform maintenance work required and complete applicable steps on Level 1 checklist to complete work. -- ; 66 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S3 Level 2 Work in ceiling plenum space where exposed surfacing ACM is present. Examples Leva! 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. NotSS 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 Coordinate work with proper O 4s. M work practice for accessing type of ceiling present in work area. See Work Practices SI, Mil, MI3 or M25. 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 of other people, and observing asbestos waste disposal procedures".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). 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. 67 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S3 Level 3 ; Work in ceiling plenum space where exposed surfacing ACM is present /~ " ~; ! " :r Examples Level 3: A. Replace HVAC mixing box above ceiling where dust or debris from surfacing ACM is present B. Repair piping below surfacing ACM in poor condition. ! Notes This work practice must be used in cottfunction with General, Procedures Wl, W9 and a - Level 3 Worker Checklist. The worker checklist includes talks that must be performed before these work practices are begun. ;i : Coordinate work with proper OA M work practice for accessing type ofceiling present in work area. See Work Practices St, MU, M13 or M25. 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'. , , ' , . ; Work Practice 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See General Procedure Wt for i standard tools, equipment and materials list,% Maintenance item(s) required to perform work in plenum space. i 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. Include a HEPA vacuum inside enclosure for vacuuming areas above ceiling. 5. Obtain access above ceiling usjng O & Mwork practices selected (see note above step 1). Pick up any bulk debris within reach on top of ceiling and place into disposal bags. - 6. HEPA vacuum top side of ceiling within reach from access area, and HEPA: vacuum and wet-wipe item to be repaired or replaced. : 7. Perform maintenance work required and clean-up and tear-down steps on Level 3 checklist to complete work! I 'i 68 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S4 Summary Install wiring in plenum space where exposed surfacing ACM is present Summary This work practice covers situations where small amounts of wiring andfor conduit are being installed in a ceiling plenum space that has exposed surfacing ACM. The procedures assume that the ACM will 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 non-asbestos-containing ceiling panel below a plenum space that ^ exPose<^ surfacing ACM. 52 Attach component to an ACM finished surface that is above a ceiling. 53 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 Asbestos O&M Work Practices 1992 NIBS S4 Level 1 Install wiring in plenum space where exposed surfacing ACM is present Example Level 1: A. Install new wiring in existing conduit that does not have overspray ACM on conduit Movement in conduit should not disturb ACM. 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 Coordinate work with proper O AM work practice for accessing type of ceiling present in work area. See Work Practices SI, Mil, M13 or M2S.1 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). Wiring and related tools . 3. Place tools, equipment and materials needed in work area.' 4. Obtain access through ceiling using O & M work practice selected (see note above step 1). 5. Run wiring as required. Do not contact exposed ACM surfacing and minimize disturbance of ceiling system and other components above ceiling while running wiring. 6. Perform clean-up and tear-down steps on Level 1 checklist to complete work. 70 Surfacing ACM Asbestos 0&M Work Practices 1992 NIBS S4 Level 2 Install wiring in plenum space where exposed surfacing ACM is present. Examples Level Z 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 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 Coordinate work with proper 0 it. M work practice for accessing type of ceiling present in work area. See Work Practices SI, MU, 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). 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 drop cloth. 5. Obtain access through ceiling using O & 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 Asbestos O&M Work Practices 1992 NIBS S4 Level 3 Install wiring in plenum space where exposed surfacing ACM is present. Example Level 3: A. Install new cables that will lay on top of ceiling where visible dust or debris is present N0t68 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 Coordinate this work with proper OAM work practice for accessing type of ceiling present in work area. See Work Practices SI, MU, M13 or M25.1 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). Wiring and related tools 3. Prepare work area with drop doth, erect mini-enclosure and set up negative pressure system. See General Procedure W9. Set up multiple enclosures if needed. 4. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuum inside endosure for vacuuming areas above ceiling. 5. Enter enclosure and obtain access through ceiling using 0 & M work practice selected (see note above step I). HEPA vacuum top ride of cdling within reach from access hole. 6. Mist top ride of ceiling in work area where dust or debris is present and 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 3 checklist to complete work.; 72 Surfacing ACM a Asbestos O&M Work Practices 1992 NIBS S5 Summary Attach item to ceiling finished with ACM Summary This work practice describes the 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 plaster where structural modifications are not needed for support Related Work Practices si - Move 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. 57 - Cut or drill hole in Surfacing ACM. 58 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 needed 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 S5 Level 2 Attach item to ceiling finished with ACM Examples Level 2: A. Attach a battery-powered smoke detector to acoustical plaster. ; B. Attach track lighting to an ACM finished surface where experience has proven a minimal disturbance will occur. . . Notes Work Practice This work practice mutt be used in conjunction with General Procedures Wl, W9 and a bevel 2 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 staff employees should be instructed: Not to hang plants or pictures on structures covered with asbestos-containing materials." 1. Perform Pre-work activities on Level 2 checklist. 2. Additional tools, equipment and materials: (see General Procedure vri for standard tools, equipment and materials list). Item to be attached to ceiling and related tools 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Wet area on ceiling where item will be attached using garden sprayer with amended water. , 6. Using hand tools and HEPA vacuum near attachment location, 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" [150mm] of where scraping is occurring. Adequately wet scraping area and any dust or debris generated. Drill hole through substrate after ACM is removed. Place all debris and sponges into ACM disposal bags. 7. Perform clean-up and tear-down steps on Level 2 checklist to complete work. 74 Surfacing ACM Asbestos 0&M Work Practices 1992 NIBS S5 Level 3 Attach item to ceiling finished with ACM Examples 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 plaster where structural modifications are not needed for support Notes i 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. Work Practice 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 instructed: Not 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 Wl 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 inside 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 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S6 Summary Repair or replace item In surface finished with ACM Summary This work practice covers the procedures for repairing or replacing an item that is installed in or attached to a surface finished with ACM, such as an acoustical plaster ceiling or fireproofed deck or beam. Examples Level 1: A. Replace light fixture in ceiling finished with ACM where a disturbance of ACM is not expected. : B. Replace Venetian blinds attached to a surface finished with ACM. Level 2r A. Replacement of ballast in recessed light fixture attached in acoustical plaster ' ceiling where ACM may be disturbed. B. Diffuser repair in acoustical piaster ceiling. C. Replace light fixture in celling finished with asbestos-containing decorative textured finish that may be disturbed. Level 3: A Replace electrical panel attached to fireproofed column. B. Replace access panel in ceiling finished with ACM. C. Replace HVAC unit attached to poor condition acoustical plaster ceiling. Related Work Practices si Moving one non-asbestos-containing ceiling panel below a plenum space that has exposed surfacing ACM. S5 Attach item to ceiling finished with ACM. 57 Cut or drill hole in Surfacing ACM. 58 Replace bulbs in light fixture attached to or in surface finished with ACM. S10 * Repair damaged surfacing ACM. ` Worker One worker is usually sufficient for Level 1 and Level 2. Two workers for Level Recommendations 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. 76 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S6 Level 1 Repair or replace item in surface finished with ACM Examples Level 1: A. Replace light fixture in ceiling finished with ACM where a disturbance of ACM is not expected. B. Replace Venetian blinds attached to a surface finished with ACM. Notes This work practice must be used in conjunction with General Procedures Wl, V/9 and a Lerel I 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 MU, M13 or MIL1 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 end materials list). Repair and/or replacement parts and tools as needed 3. Prepare work area with drop Cloth, fif desired). See General Procedure W9. 4. Place tools, equipment and materials needed in work area or on drop doth. 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 (if 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 a Surfacing ACM Asbestos 0&M Work Practices a 1992 NIBS S6 Level 2 Repair or replace item in surface finished with ACM Examples Level 2: A. Replacement of ballast in recessed light fixture attached in acoustical plaster celling where ACM may be disturbed. B. Diffuser repair in acoustical plaster ceiling. C. Replace light fixture In ceiling finished with asbestos-containing decorative texture finish that may be disturbed. 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. Coordinate work with proper OAM work practice for accessing type of ceiling present in work area. See Work Practices ,MU, M13 or M25. Work Practice i. 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). Repair and/or replacement parts and tools as needed 3. Prepare work area with drop doth, (if desired). See General Procedure W9. 4. Place tools, equipment and materials needed in work area or on drop doth. 5. Lightly mist area of surfadng within 6" [ISO 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 dr 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, dean (if 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. 78 Surfacing ACM Asbestos O&M Work Practices 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. B. 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 Ms work with proper 0 AM work practice for accessing type of ceiling present in work area. See Work Practices Mil, M13 or M25.1 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 (if 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/replacemenl work using HEPA vacuum. 9. Perform clean-up and tear-down steps on Level 3 checklist to complete work. 79 Surfacing ACM Asbestos 0&M Work Practices 1992 NIBS Cut or drill hole in surfacing ACM Summary This work practice covers the work required to cut or drill a hole through surfacing ACM, such as acoustical plaster or fireproofing. If possible. ACM ; should be removed before holes are drilled. If holes are drilled in an ACM wall surface with a cavity behind the wall, labels or recordkeeping information should note that ACM might be present in the cavity. Examples Level 2: A. Install a few new conduits through fireproofed metal deck. B. Drill a hole through asbestos-containing decorative texture finish. C. Drill a hole using a drill with HEPA filtered dust collection. LevelS: A. Drill or cut hole for pipe or duct chase using tools with or without HEPA filtered dust collection in an enclosure. Related Wort Practices - Si Move one non-asbestos-cointaining ceiling panel below a plenum space that has exposed surfacing ACM. S2 Attach component to an ACM finished surface that is above a ceiling. 55 Attach item to ceiling finished with ACM. 56 Repair or replace item in surface finished with ACM. Worker One worker is usually sufficient for Level 2. Two workers for Level 3. More Recommendations 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. ; 80 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 hole through asbestos-containing decorative texture finish. C. Drill a hole using a drill with HEPA filtered dust collection. 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 Coordinate work with proper O dAf work practice for accessing type of ceiling present in work area. See Work Practices SI, MU, MI3. 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 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 hole. Wet sponge or shaving cream (if used) 3. Prepare work area with drop doth. 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 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. Install polyethylene sheet below removal location to catch any falling debris. B. Adequately wet area where hole is to be drilled. 81 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S7 Level 2..condnuad C. (1) Small holes'can be drilled through a wet sponge or shaving cream. See C(2) for alternative methods. After drilling, remove shaving cream using wet/dry type HEPA vacuum. (2) 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* [150mm] of where scraping is occurring. Adequately wet scraping area and any dust or debris generated. Drill hole through substrate after ACM is removed. 0. Place HEPA vacuum hose near or through hole and run for several minutes to clean air on backside of surface. 7. A. If hole is drilled from top side of deck, adequately wet ACM on underside and install polyethylene sheet or enclosure below ACM on underside that will catch any falling debris, including material from hole (such as a concrete cylinder). (If hoir it drilledfrom underside, see step B). Drill hole through surface. Adequately wet drilling area while drilling. Wet any debris on drop cloth or in enclosure on underside, package up debris and drop cloth/enclosure and dispose of as ACM. B. If hole is drilled from underside of deck, follow steps 6A, 6B and 6C(2). 8. Perform clean-up and tear-down steps on Level 2 checklist to complete work. 82 Surfacing ACM Asbestos 0&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 This work practice must be used in conjunction with General Procedures WJ, W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice Coordinate this work with proper OAM work practice Jbr accessing type of ceiling present in work area. See Work Practices SI, MU, M13 or MIS. Appendix G to OSHA regulation 29 CFR 1926.58 states: "The training program for 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: Mot 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 W1 for standard tools, equipment and materials list). Scraper 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 Gltered 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 O & 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 mml 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 a Asbestos O&M Work Practices 1992 NIBS S7 Level 3~contimj*d C. (1) Small holes can be drilled through a wet sponge or shaving cream. See C(2) for alternative methods. Alter drilling, remove shaving cream using wet/dry type HEPA vacuum. (2) 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" [130 mm] of where surveying is occurring. Adequately wet, any dust or debris generated. Drill surveying area and hole through substrate alter ACM is removed. 0. Place HEPA vacuum hose near or through hole and rim for several minutes to clean air on backside of surface. 7. A. If hole is drilled from top side of deck, adequately set ACM on underside and Install enclosure below ACM on underside that will catch any falling debris, including material from hole (such as a concrete cylinder). (If koU it drUUifrom unimi&t, ut slop B). Drill hole through surface. Adequately wet drilling area while drilling. Wet any debris in enclosure on underside, package up debris and enclosure and dispose of as ACM. B. If hole is drilled from underside of deck, provide an enclosure on top side where hole will penetrate deck and follow steps 6A, 6B, 6C(2), and 6D. 8. Let HEPA vacuum ran for at least 13 minutes to clean air in enclosure. 9. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist to complete work. 84 Surfacing ACM Asbestos O&M Work Practices a 01992 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 S5 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 1992 NIBS * -f AM S8 Level 1 Replace bulbs In light fixture attached to or in surface finished with ACM 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. 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. Use Work Practice Mil if HEPA vacuum needs maintenance, or Ifbag orfilter needs to be replaced ,1 Work Practice 1. Perform Pre-work activities on Level 1 checklist 2. Special tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Replacement bulbs 3. Place tools, equipment and materials needed in work area. 4. Carefully replace light bulbs without jarring fixture. Clean-up any dust or debris generated using HEPA vacuum. 5. Perform clean-up and tear-down steps on Level 1 checklist to complete work. 86 a Surfacing ACM a Asbestos O&M Work Practices 1992 NIBS i 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. - B. Routine cleaning in mechanical room with exposed fireproofing in good condition where there is no visible dust or debris. Related Work Practices S10 Repair damaged surfacing ACM. T6 - Repair damaged thermal system insulation on a pipe. M8 * Clean resilient asbestos flooring. M29 Clean up debris from minor fiber release. Worker One worker. Recommendations 87 Surfacing ACM Asbestos O&M Work Practices a 1992 NIBS S9 Level 1 Clean room with exposed surfaces finished with ACM Examples Level 1: A. Routine cleaning in room with spray applied acoustical plaster on walls or ceilings where there is no visible debris. B. Routine cleaning in mechanical room with exposed fireproofing in good condition where there is no visible debris. Notes ~ Work Practice 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. . . Ifany debrisfrom ACM isfound in an area to be cleaned, notify the APM oryour supervisor. The APM will need to determine whether this work practice is appropriate or if more stringent practices are needed 1. Tools, equipment and materials: Standard cleaning equipment and materials 2. Gean area using standard cleaning methods. Avoid contact with any ACM materials that could be damaged during cleaning. The APM will select the appropriate work practice and personnel to clean up any debris from ACM. The following precautions should be observed when working around die ACM: A). Do not bump ACM with vacuum cleaners, broom handles, mop handles or similar objects. Do not exhaust vacuum cleaners toward ACM. B). Do not brush ACM surfaces with a broom or similar objects to remove cobwebs or other items attached to ACM. 88 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. B. Repair small gouged area in asbestos-containing decorative texture finish without disturbing surrounding finish. 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. 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 S2 Attach component to an ACM finished surface that is above a ceiling. S5 - Attach item to ceiling finished with ACM. Worker One worker is usually sufficient for Level 1 and Level 2. Two workers for Level Recommendations 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 Asbestos O&M Work Practices 01992 NIBS I S10 * Level t Repair damaged surfacing ACM Examples Level 1: A. Repair small hole in acoustics plaster ceiling or wall without disturbing surrounding plaster. .: B. Repair small gouged area in asbestos-containing decorative texture finish without disturbing surrounding finish. . Notes - - Work Practice . This work practice must be used In conjunction with General Procedurt W1 and a Lerell Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. . 1. Performprc-work activities on Level 1 checklist. 2. Additional tools, equipment and materials: (see General Procedure W1 for ; standard tools, equipment and materials list). . Non-ACM caulking materials & tools 3. Place tools, equipment and materials needed in work area. 4. Repair damaged area using non-ACM caulking without disturbing ACM. Do not scrape or sand existing ceiling. ; 5. Perform clean-up and tear-down steps on Level 1 checklist to complete work. I j 90 Surfacing ACM 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 Work Practice This work practice must be used in coryunction 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). 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 area, remove any loose material by hand or with scraper. Collect material in 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 Asbestos O&M Work Practices 1992 NIBS .\ S10 Level 3 Repair damaged surfacing ACM EX9mples 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. Notes This work practice must be used in conjunction with a Worker Checklistfor Level 3 Work , . Practices. General Procedures Wl end W9 are used. , The checklist Includes tasks that must be performed before these work practices are used. Coordinate this work with proper OAM work practice for accessing type ofceiling present in work area. See Work Practices, SI, Mil, MIS or M25. (fACM is in poor ; condition, abatement may need lo be consideredfor the damaged area. 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). ' ' Small stiff-Waded scraper . : Non-ACM repair materials & 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 heeded into enclosure. Include a HEPA vacuum inside enclosure for use during repair work. If access above ceiling is required, obtain access using O&M work practice selected (see note above step i). ' "` - ; 5. Adequately wet area of 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 area, remove any loose ^ material by hand or with scraper. Collect material in 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 inside enclosure.; Mist removal area during removal of damaged material. ; 7. Repair damaged area using non-ACM materials. 8. Perform clean-up and tear-down steps on Level 3 checklist to complete work. 92 Surfacing ACM Asbestos O&M Work Practices 01992 NIBS i 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: A. 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: A. Open access door in acoustical plaster ceiling where ACM is in fair condition and may be disturbed. Level 3: A. 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 S5 Attach item to ceiling finished with ACM. 56 ' Repair or replace item in surface finished with ACM. S7 - 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 Surfacing ACM Asbestos O&M Work Practices a 1992 NIBS S11 Level 1 Accessing through an ACM finished surface Example Level 1: A. Open access door in acoustical plaster ceiling or wall that has been opened before. Ceiling or wail is in good condition and debris is not likely on door. Notee This work practice must be used in confunction wtih General Procedure Wt and a Level 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. v Work Practice _ 1. Perform pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure Wi far standard tools, equipment and materials list)i Sponge ~ 3. Place tools, equipment and materials needed in work area. 4. Unlatch door and open careAillyi . 5. Perform maintenance work required above or behind access door and slowly close door until it is secured in place. 6. Complete applicable steps oh Level 1 checklist to complete work. 94 a Surfacing ACM a Asbestos O&M Work Practices a 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. /Votes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a Lere12 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 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). Spoqge 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 access 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 a Surfacing ACM Asbestos O&M Work Practices 1992 NIBS S11 Level 3 Accessing through an ACM finished Examples Level 3: A. 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 ACM debris may be present on back side of door. Notes Work Practice j* This work practice must bi ased in conjunction with General Procedures W1, 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 O 4 M work practice for accessing type of celling 1 present in work area. See Work Practices SI, MU, M13 or M25.1 2 3 4 5 6 7 8 9 10 1. Perform pre-work i^vities on Levd 3 checklist. I 2. Additional 'tools, equipment and materials: (See Genera! Procedure Wlfor standard tools, equipment and materials lisp: Sponge i;>' -. j Small sdff-bladed scraper ", 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 use sponge or sprayer to wet any ACM on access door flanges that may be disturbed. Allow water to soak in for several minutes. 6. If door has not been previously opened, cut around perimeter of door using utility knife and operating HEPA vacuum within several inches of cutting area. 7. Adequately wet any loose ACM on door edges and flame, remove using scraper, and place ACM and debris into ACM disposal bags. 8. Perform maintenance work required above or behind access door. 9. Slowly close door until it is secured in place. ; 10. Perform clean-up and tear-down steps on Level 3 checklist to complete work. 96 Surfacing ACM a Asbestos O&M Work Practices a 1992 NIBS S12 Summary Painting surfacing ACM. Summary This work practice describes die 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 friability of the ACM, this work may need to be treated as an abatement activity instead of O A. M work. Examples Level 1: A. Repaint previously painted asbestos-containing acoustical plaster in good condition. No preparation of the surface is required. Level 2: 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. Related Work Practices S10 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 a 1992 NIBS S12 Level 1 Painting surfacing ACM. Example Laval 1: A. Repaint previously painted asbestos-containing acoustical plaster in good condition. No preparation of the surface is required. NOtaS This work practice mass be used in conjunction with General Procedure WI, W9 and a bevel 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. . Use Work Practice Mil if HEPA vacuum needs maintenance, or ifbag orfiber needs to _ be replaced. -1 Work Practice 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). Paint, rollers or low pressure airless sprayer, and other printing equipment 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools, equipment and materials needed on drop doth. 5. Print 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, dean up any loose debris uring wet wiping and/or HEPA vacuuming, and roll up drop doth. Dispose of print rollers as ACM. 7. Perform clean-up and tear-down steps on Level 1 checklist to complete work. 98 Surfacing ACM Asbestos O&M Work Practices 1992 NIBS SI 2 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 Lerel 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 rollers 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 and/or 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 S12 Level 3 Painting surfacing ACM. Examples Level 3: A. Paint asbestos-containing acoustical plaster that has not been previously painted. B. Paint asbestos-containing fireproofing. Notes Work Practice This work practice must be used in conjunction with Gerund Procedures Wl, W9 and a here13 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Coordinate this work with proper O A M work practice for accessing type of ceiling 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). Paint, and rollers or low pressure airless sprayer, and other painting equipment . 3. Prepare work area with drop cloth, erect mini-enclosure (or enclose entire room) and set up negative pressure system. See General Procedure W9. 4. Place tools, equipment and materials needed into enclosure. 5. Enter enclosure and paint ceiling as follows: A. For acoustical plaster, use rollers or sprayer. If rollers are used, try to contact each area of the ceiling only once to avoid damage to ACM. B. For fireproofing, use airless sprayer only. 6. When painting is completed, wet drop doth with amended water, roll up and dispose of as ACM. Use HEPA vacuum and/or wet-wiping to clean up any dust or debris under drop doth. Dispose of rollers as ACM. 7. Perform clean-up and tear-down steps on Level 3 checklist to complete work. 100 a Surfacing ACM Asbestos 0&M Work Practices 1992 NIBS SI 3 Summary Accessing a contaminated iight fixture Summary This 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 2l A. Replace bulbs ill 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 S5 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 0&M Work Practices 1992 NIBS S13 Level 2 Accessing a contaminated light fixture . i Examples Level 2: A. 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. . " 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). Replacement Bulbs 3. Prepare work area with drop doth. See General Procedure W9. 4. Place tools, equipment and materials needed on drop cloth. 5. Wet wipe exposed surfaces of fixture. 6. Carefully replace light bulbs without jarring fixture. Clean up any dust or debris generated using HEPA vacuum. 7. Perform clean-up and tear-down steps on Levd 2 checklist to complete work. 102 Surfacing ACM a Asbestos O&M Work Practices a 01992 NIBS SI3 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 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 WI 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. 103 a Surfacing ACM Asbestos 0&M Work Practices a 1992 NIBS I ! o H JUUAI V. Thermal Systems Insulation (TSI) Work Practices Figure 8: Thermal Systems Insulation Location Illustration f06 Thermal System Insulation Asbestos O&M Work Practices 01992 NIBS T1 Level 2 Remove asbestos-containing insulation on exposed pipe for maintenance work. 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. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9, WI7 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). Glovebags Replacement non-ACM insulation if required Pipe repair materials and tools 3. Prepare work area with drop cloth. See general procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Place all needed tools inside of glovebag and attach glovebag to area of pipe insuladon to be removed. See general procedure W17. 6. Remove ACM using glovebag procedures. Adequately wet removal area frequently during removal of the bulk material. Seal exposed ends of insulation before removing glovebags. 7. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. 110 Thermal Systems Insulation Asbestos OKM Work Prartirps n ft W5 nirp T1 Summary Remove asbestos-containing insulation on exposed pipe for maintenance work. Summary This work practice covers the procedures for removing small amounts of asbestos- containing 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 insulatioa 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 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. 109 Thermal Systems Insulation Asbestos O&M Work Practices 01992 NIBS t I r, T2 Summary Remove asbestos-containing insulation on pipe above ceiling for maintenance work. Summary This work practice covers the procedures for removing small amounts of asbestoscontaining insulation on a pipe located above a lay-in panel ceiling. Examples Level 2: A. Remove pipe insulation above lay-in panel ceiling where insulation is in good condition, e.g., pipe leak. B. Repair pipe leak above a non-ACM plaster or drywall ceiling. C. Attach branch line to existing steam line above non-ACM plaster ceiling. Level 3: A. Remove section of pipe insulation in poor condition for fitting replacement. B. Remove section of pipe insulation in poor condition, or with metal jacket, or waterproofed to replace a section of pipe. C. Remove ACM insulation which is damaged and in poor condition from steam line above non-ACM plaster ceiling. 0. Remove insulation in poor condition on a pipe to repair leak above a nonACM drywall ceiling. Related Work Practices S2 - Observation or work in ceiling plenum space where exposed surfacing , ACM is present T3 - Remove asbestos-containing insulation on exposed pipe in elevated location for maintenance work Mil - Replace asbestos-containing ceiling panels in lay-in ceiling system. M12 - Replace asbestos containing ceiling tiles attached with adhesive M13 Replace asbestos containing ceiling tiles in spline ceiling system M29 Clean up debris from minor fiber release Worker Two workers. A person with air monitoring training might be required. This Recommendations person can be a worker. 112 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 Gt 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 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 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 general procedure W17. If pipe is hot or will not fit in a glovebag, set up HEPA filtered local exhaust ventilation and follow 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. Ill Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T2 Level 3 Remove asbestos-containing insulation on pipe above lay-in panel ceiling for maintenance Examples Level 3: A. Remove section of pipe insulation in poor condition for fitting replacement. B. Remove section of pipe insulation in poor condition, or with metal jacket, or waterproofed to replace a section of pipe. Notes This work practice must be used in conjunction with General Procedures WI, W9 and W17 and a Level 3 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Note: Coordinate this work with proper O & M work practice for accessing type of ceiling present in work area. See Work Practice Mil, Ml3, M25.1 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). Tools and Equipment: 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, 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 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 irom access hole. 8. If present, remove any metal jacket material over insulation to be removed. 9. Place all tools needed inside glovebag and attach glovebag to area of pipe insulation to be removed. See general procedure W17. 10. Remove ACM using glovebag procedures. Adequately wet removal area frequently during removal of the bulk material. 11. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist to complete work. 114 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T2 Level 2 Remove asbestos-containing insulation on pipe above lay-in panel ceiling for maintenance work Example Level 2t 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 AM work practice for accessing type of ceiling present in work area. See Work Practice MU, 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 general procedure 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. 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 general procedure 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 a Asbestos O&M Work Practices a 01992 NIBS T3 Level 2 Remove asbestos-containing insulation on exposed pipe in elevated location for maintenance work 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. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9, WI7 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 activides 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 Non-slip drop cloth ' 3. Prepare work area with drop cloth. See general procedure W9. Erect scaffold system using proper OSHA procedures. Care should be taken not to disturb the ACM. 4. Place tools, equipment and materials needed onto non-slip drop cloth on scaffold system. 5. 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 2 checklist to complete work. - *-u r\oi n> 4t 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 2l A. Repair small pipe leak in boiler room B. Install new ceiling mounted hot water beating unit in warehouse space fed from existing piping. 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 Une. B. Remove insulation on (ripe 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 for maintenance work. Worker Two workers. A person with air monitoring training might be required. This Recommendations person can be a worker. 115 Thermal Systems Insulation n Asbestos O&M Work Practices 1992 NIBS T4 Summary Remove asbestos-containing insulation on pipe in occupied area for maintenance work Summary This work practice covers the procedures for removing small amounts of asbestoscontaining pipe insulation inside a mini-enclosure located in an occupied area. This procedure assumes that maintenance work must occur immediately in an occupied area or work area is occupied 24 hours a day. 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. Related Work Practices T2 Remove asbestos-containing insulation on pipe above ceiling for maintenance work T3 Remove asbestos-containing insulation on exposed pipe in elevated location for maintenance work Worker Two workers. A person with air monitoring training might be required. This Recommendations P"* canbea worker- 118 a Thermal Systems Insulation a 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, IS 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, WJ7 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 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 WIT. 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 T5 Summary Repair damaged asbestos-containing insulation on a pipe Summary This work practice covers the procedures for repairing small areas of damaged asbestos-containing insulation.- 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. Level 3: A. Repair damaged pipe insulation adjacent to operating HVAC. B. Repair delaminated pipe insulation in an occupied area. Related Work Practices T3 - Remove asbestos-containing insulation on exposed pipe in elevated location location for maintenance work M29 Clean up debris from minor fiber release Worker One worker - Level 2. Two workers - Level 3. A person with air monitoring Recommendations haining might be required. This person can be a worker. 120 Thermal Systems Insulation Asbestos O&M Work Practices 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, WI7 and a Level 3 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. If access above ceiling is needed, coordinate this work with proper OAM work practice for accessing type of ceiling present in work area. See Work Practices Mil, M13 or M25. 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 Replacement non-ACM insulation if required Pipe repair materials and tools Glovebags 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. 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 J). 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. 119 Thermal Systems Insulation a Asbestos O&M Work Practices 1992 NIBS T5 Level 3 Repair damaged asbestos-containing insulation on a Pipe________________________________________________________ Examples L6vel 3: A. Repair damaged pipe insulation adjacent to operating HVAC. 6. Repair delaminated pipe insulation in an occupied area. 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. If access above ceiling is needed, coordinate this work with proper 0 AM work practice for accessing type of ceiling present in work area. See Work Practices Mil, M13 or M25.1 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 Sponge Non-ACM insulation patching material Putty Knife Lag cloth 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. If work must occur above ceiling, include a HEPA vacuum inside enclosure for vacuuming areas above ceiling. 5. Enter enclosure. If access above ceiling is required, obtain access above ceiling using O & M work practice selected (see note above step 1). 6. If work can be done with a glovebag method, follow procedures below: A. Install duct tape around area to be repaired. 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 6b above. 122 Thermal Systems Insulation Asbestos 0&M Work Practices 1992 NIBS T5. Level 2 . Repair damaged asbestos-containing insulation on a Pjpe________________________ _____________________________ Examples Level 2l A. Repair small area of impact damage on pipe insulation in good condition. B. Repair minor damage to insuladon on a pipe fitting. Notes ~ Work Practice - , This work practice must be used in conjunction with General Procedures WI end W9 and a Lewd 2 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. if access 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 or M25. 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see general procedure WI 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 required, obtain access above ceiling 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. 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. 121 Thermal Systems Insulation Asbestos O&M Work Practices 01992 NIBS T6 Summary Repair damaged asbestos-containing insulation on a boiler, duct or flue Summary This work practice covers the procedures for repairing small amounts of damaged asbestos-containing thermal systems insulation. The procedures assume that the area to be repaired is within the OSHA short-scale/short-duration project limits. 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. Level 3: A. Repair badly damaged flue or duct insulation. B. Repair area of water damaged insulation on hot water tank or boiler. Related Work Practices T3 Remove asbestos-containing insulation on exposed pipe in elevated location for maintenance work M29 Clean up debris from minor fiber release Worker One worker - Level 2. Two workers - Level 3. A person with air monitoring Recommendations training might be required. This person can be a worker. 124 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS LevelT5 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 T6 Level 3 Repair damaged asbestos-containing insulation on a boiler, duct or flue Examples Level 3: A. Repair badly damaged flue or duct insulation. B. Repair area of water damaged insulation on hot water tank or boiler. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9, and W17 and a Lord 3 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. Ifaccess above ceiling is needed, coordinate this work with proper OAM work practice for accessing type of ceiling present in work area. See Work Practices Mil, Ml3 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). Scraper (2-3" [50-75 mmj wide stiff blade) Stiff nylon bristle brushes Sponge HEPA vacuum, hose and attachments Putty Knife - Glovebags Lag cloth 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. If work must occur above ceiling, include a HEPA vacuum inside enclosure for vacuuming areas above ceiling. 5. Enter enclosure. If access above ceiling is required, obtain access above ceiling using 0 & M work practice selected (see note above step 1). 6. If work can be done with a glovebag method, follow procedures below: A Install duct tape around area to be repaired. 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 6b above. 126 Thermal Systems Insulation Asbestos O&M Work Practices 01992 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 Work Practice This work practice must be used in conjunction with General Procedures Wl and W9 and a Lewd 2 Worker Checklist The worker checklist includes tasks that must be performed before these work practices are begun. If access above ceiling Is needed, coordinate work with proper 0 A. M work practice for accessing type of ceiling present in work area. See Work Practices MU, 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). 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 required, obtain access above ceiling using O &. M work practice selected (see note above step 1). 5. Adequately wet area of insulation to be repaired where appropriate. REPA 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 1992 NIBS T7, Summary Install device in, or access surface of, asbestoscontaining insulation on a pipe, boiler, duct or flue Summary This summary covers the removal of small amounts of ACM as required to install a device (such as a temperature sensor or damper control) in, or simply to access, the surface of an ACM insulated pipe, boiler, duct or flue. Examples Level 2: A. Remove ACM in good condition in order to install energy management system sensors and controls. Level 3: A. Drill through insulation using power tools to attach heat sensor directly on metal flue. B. Remove damaged insulation in order to attach heat sensor directly on metal flue. Related Work Practices T1 Remove Asbestos-containing insulation on exposed pipe 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 Worker One worker. A person with air monitoring training might be required. This Recommendations person can be the worker. 128 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T6 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. , C. Place ACM debris into disposal bags. 8. Remove glovebag and fill in repair area with non-ACM patching material. 9. 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. 10. Perform dean-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 01992 NIBS T7 Level 3 Install device in, or access surface of, asbestoscontaining insulation on a pipe, boiler, duct or flue Examples Level 3: A. Drill through insulation using power tools to attach heat sensor directly on metal flue. B. Remove damaged insulation in order to attach heat sensor directly on metal flue. 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. Work Practice If access above ceiling is needed, coordinate this work with proper O A M work practice for accessing type of ceiling present in work area. See Work Practices MU, MI3 or M25.1 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 (1" [23 mm] wide blade) Stiff nylon bristle brushes Wire cutters Power drill with HEPA attachment Hole saw or drill bits Glovebags Non-ACM replacement insulation or patching material (if required) Device to be installed and related tools 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. If work must occur above ceiling, include a HEPA vacuum inside enclosure for use during the work. 5. Enter enclosure. If access above ceiling is required, obtain access above ceiling using 0 & M work practice selected (see note above step 1). 6. If work can be done with a glovebag method, follow procedures below: A Install duct tape around area to be penetrated or 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 6b above. 130 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T7. Level 2 Install device in, or access surface of, asbestoscontaining insulation on a pipe, insulated boiler, duct or flue Example Level 2* A. Remove ACM in good condition in order to install energy management system sensors and controls. Notes This work practice must be used iu conjunction with General Procedures Wl, W9, dud W17 and a Level 2 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 work with proper O AM work practice fir accessing type of ceiling present in work area. See Work Practices Mil, M13 or M25. 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 .< . 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 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. 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 in- place. 129 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T8 Summary Remove asbestos-containing duct insulation above ceiling for maintenance work Summary This work practice describes the procedures for removing small amounts of asbestos-containing duct insulation above a ceiling. Ceiling might be ACM or non-ACM. Ceiling might be plaster, drywall or lay-in. 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. Level 3: A. Remove damaged duct insulation so that new branch lines can be tied to existing duct system for sub-divided office space. B. Remove delaminating duct insulation above lay-in ceiling. C. Remove delaminating duct insulation above plaster or drywall ceiling. Related Work Practices T6 Repair damaged asbestos-containing insulation on a boiler, duct or flue M25 * Remove section of asbestos-containing drywall or plaster. Worker Two workers. A person with air monitoring training might be required. This Recommendations person can be a worker. 132 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T7 Level 3.,,contInued 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 the 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. 131 Thermal Systems Insulation Asbestos O&M Work Practices 01992 NIBS T8 Level 3 Remove asbestos-containing duct insulation above ceiling for maintenance work Examples Level 3: A. Remove damaged duct insulation so that new branch lines can be tied to existing duct system for sub-divided office space. B. Remove delaminating duct Insulation above lay-in ceiling. C. Remove delaminating duct insulation above plaster or dyrwall ceiling. Notes Work Practice 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. Coordinate work with proper OAM work practice for accessing type ofceiling present in work area. See work practices Mil, M12, M13 and M25.1 11 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, size and configuration as required 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. Include a HEPA vacuum inside enclosure fix use during the work. 5. Obtain access above ceiling using 0 & M work practices selected (see note above step 1). 6. Pick up 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 procedures W17. Adequately wet removal area frequently during removal of bulk material. 11. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist and ceiling access work practice to complete work. Leave duct tape installed in step 8 in place. 134 Thermal Systems Insulation Asbestos 0&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 must be used in conjunction with General Procedures Wl, 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" [30-73 mm] wide stiff blade) Stiff nylon bristle brushes Non-acm replacement duct insulation ' Glovebags 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 abort step I). 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 a 1992 NIBS T9. Level 2 Remove asbestos-containing insulation inside HVAC unit for maintenance work Example Level 2: A. Remove small amount of pipe insulation in good condition to replace cooling or heating coil. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9, and W17 and a lord 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). Scraper (2-3" [50-75 mm] wide stiff blade) Stiff nylon bristle brushes Non-ACM replacement insulation Glovebags 3. Prepare work area with drop Cloth. See general procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Install duct tape around insulation to be removed. 6. Place all tools needed inside of glovebag and attach glovebag to duct tape around area where insulation will be removed. 7. Remove ACM using glovebag procedures. See general procedure W17. Adequately wet removal area frequendy during removal of bulk materials. 8. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. Leave duct tape installed in step 5 in place. 136 Thermal Systems Insulation Asbestos 0&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 food 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 T10 Summary Clean up asbestos-containing debris in crawlspace or tunnel Summary This work practice describes the work required to clean up small amounts of asbestos-containing debris (below the small-scale, short-duration project limits) found in a crawlspace area or tunneL Examples Level 2: A. Qean up several pieces of pipe insulation debris in crawlspace B. Clean up small amount of insulation debris in tunnel Level 3: A. CTean up of ACM debris in a tunnel that is used as a plenum for tte HVAC system. B. Clean-up of delaminated duct insulation or fallen pipe insulation in an area where maintenance work will be performed. Related Work Practices T1 - Remove asbestos-containing insulation on exposed pipe for maintenance work T5 - Repair damaged asbestos-containing insulation on a pipe T6 - Repair damaged asbestos-containing insulation on a boiler, duct or flue Worker Two workers due to confined space safety concerns. A person with air monitoring Recommendations training might be required. This person can be a worker. . 138 Thermal Systems Insulation Asbestos O&M Work Practices 1992 NIBS T9 Level 3 Remove asbestos-containing insulation inside HVAC unit for maintenance work Note: If a flexible connector must be removed, see Work Practice IDS. Examples Level 3: A. Remove ACM pipe insulation in poor condition inside HVAC unit. B. Remove duct insulation required to replace flexible connector. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9, and W17 and a lord 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 Non-ACM replacement duct insulation Glovebags 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative- pressure system where feasible. Sea 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. 0. 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 01992 NIBS T10 Level 3 Clean up asbestos-containing debris in crawispace or tunnel Examples Level 3: A. Clean up of ACM debris in a tunnel that is used as a plenum for the HVAC system. B. Clean-up of delaminated duct insulation or fallen pipe insulation in an area where maintenance work will be performed. Notes Work Practice This work practice must be used in conjunction with General Procedures W1 and W9 and a Level 3 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 8.1 1. Perform Pre-work activities on Level 3 checklist. 2. See general procedure W1 for standard tools, equipment and materials list 3. One worker should remain outside to communicate with inside worker and handle rescue arrangements if needed. Prepare work area with mini-enclosure (without floor) and set up negative pressure system and/or local exhaust ventilation. See general procedure W9. 4. Place tools, equipment and materials needed into enclosure. Include a HEPA vacuum inside enclosure. 5. Adequately wet floor area and debris inside enclosure. 6. Starting near entry to area and working toward rear of area, pick up pieces of debris and place into disposal bags. 7. Adequately wet areas where debris was removed. Use HEPA vacuum to remove any remaining debris. Place debris into disposal bags. HEPA vacuum floor after gross debris is removed. 8. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist to complete work. 140 Thermal Systems Insulation Asbestos O&M Work Practices > 1992 NIBS T10. Level2 Clean up asbestos-containing debris in crawispace or tunnel Examples Level 2: A. Clean up several pieces of pipe insulation debris in crawispace B. Clean up small amount of insulation debris in tunnel Notes This work practice must be used in conjunction with General Procedures W1 and a LevcT 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 8.1 Work Practice 1. Perform Pre-work activities on Level 2 checklist 2. 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. Use HEPA vacuum to remove any remaining debris. Place debris into disposal bags. 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. , 139 Thermal Systems Insulation Asbestos O&M Work Practices a 01992 NIBS Ml 8 Level 1 Remove and replace asbestos-cement siding shingles Example 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. 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 ifHEPA vacuum needs maintenance, or if bag orfiber 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). Pry bars, slatter's ripper and/or nail clipper Replacement siding, if required 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 encapsulant on siding panels. 4. Starting at top of removal area, remove nails, cut nails or pry up edge of first panel until edges can be gripped by hand. Remove panel and place into disposal bags or polyethylene lined cardboard boxes and lower to ground level. 5. Continue removing panels 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. 206 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M18 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 2l 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. MIS 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. 205 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS Ml 9 Summary Remove high-temperature resistant (HTR) asbestos cement panels. Summary This work practice covers the procedures for removing small amounts of high temperature resistant asbestos panels for maintenance work. These panels typically have a high asbestos content Examples Level 1: A. Remove HTR asbestos cement panels in good condition that can be removed with minimal breakage. Level 2: A. Remove HTR asbestos cement panels that are damaged and may become friable during removal. Level 3: A. Remove HTR asbestos cement panels in poor and friable condition inside a mini-enclosure. Related Work Practices M14 Cut or drill asbestos cement panels. M15 - Remove asbestos cement ponds. M17 - Remove and replace asbestos cement shingles. M22 Remove asbestos-containing built-up roofing. 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. 208 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS i Ml8 Level 2 ' . . Remove and replace asbestos cement siding shingles Example Level 2: A. Replace or remove asbestos cement siding shingles that are sufficiently damaged and may-become friable during removal. >. 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. : ,* 2 3 4 5 6 7 8 9 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). Pry bars, slatter's ripper and/or nail clipper . Replacement siding; if required . , Spray encapsulant (if used) i 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 workarea with polyethylene. Do not cover over exhaust vents. ; 4. Place tools, equipment and materials needed onto drop cloth. 5. Apply spray encapsulant, to or adequately wet siding to be removed. 6. Starting at top of removal area, remove 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 arid tear-down steps on Level 2 checklist to complete work. 1 I 207 Miscellaneous ACM Asbestos O&M Work Practices 01992 NIBS Ml9 . Level 2 Remove high temperature resistant (HTR) asbestos cement panels. Example Level 2: A. Remove HTR asbestos cement panels that are 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 Level 2 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 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 needed to remove panels and fasteners 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. 4. Place tools, equipment and materials needed onto drop cloth. 5. Adequately wet panels to be removed using spray encapsulant or amended water. 6. Remove fasteners securing 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 wrap in polyethylene. 7. Clean up any debris or dust using HEPA vacuuming and wet wiping. 8. Perform maintenance work and ciean-up and tear-down steps on Level 2 checklist to complete work. 210 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS t M19 Level 1 Remove high temperature resistant (HTR) asbestos cement panels. Example Notes Level 1: A. Remove HTR asbestos cenient panels to good condition that can be removed! . w ith .minima. l break*a. ge. " ' ' i; , .. This work practice mist 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 (fHEPA 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: (tee General Procedure W1 for standard tools, equipment and materials list). Tools needed to remove panels and fastened Spray encapsulate 0f 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 into disposal bags or wrap in polyethylene. 5. Clean up any debris or dust 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 Miscellaneous ACM a Asbestos O&M Work Practices 01992 NIBS M20 Summary Remove asbestos-containing chalk board Summary This work practice describes the work required to remove a chalkboard that is made of asbestos-containing material. Examples Level 1: a. Remove asbestos-containing chalkboard that is non-adhered and easily removed. Level 2: A. Remove asbestos-containing chalkboard that is adhered or may generate minor debris from removal. Level 3: A. Remove asbestos-containing chalkboard that is in poor condition or strongly adhered to wall Related Work Practices None Worker One worker for small boards or mechanically attached units. Two workers for Recommendations larger boards or adhered units. A person with air monitoring training might be required. This person can be a worker. 212 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M19 Level 3 Remove high temperature resistant (HTR) asbestos cement panels Example Level 3: A. Remove HTR asbestos cementpanels 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 1 Level 3 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 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). Tools needed to remove panels and fasteners ' Spray encapsulant (if 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 encapsulant or amended water. 6. Remove fasteners holding 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 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M20. Level 2 Remove asbestos-containing chalk board Example Level 2: A. Remove asbestos-containing chalkboard that is adhered or may generate minor debris from 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.1 2 3 4 5 6 7 8 9 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (tee General Procedure Wl for standard tools, equipment and materials list). Scraper 2-3" (30-73 mm) wide stiff blade Stiff nylon bristle brushes Crow bar and screwdrivers 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. 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. 6. 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 prying 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 2 checklist to complete work. 214 Miscellaneous ACM * Asbestos 0&M Work Practices 1992 NIBS M20 Level 1 Remove asbestos-containing chalk board Example Level 1: A. Remove asbestos-containing chalkboard that is non-adhered and easily . ; removed. \ - Notes ,, Work Practice This work practice must be used in conjunction with General Procedure H7 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 if bag orfiber needs to be replaced. . . 1. Perform Pre-work activities on Leyd 1 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Scraper 2-3" (30-75 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 *nrhing board to wall and remow board. Some boards lift up out of a supporting tray or off of supporting clips to remove. Wrap 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 1992 NIBS M21 Summary Remove asbestos-containing fire door and/or door hardware Summary This procedure sets forth the O&M work procedures to remove an asbestoscontaining fire door or door hardware in an asbestos-containing fire door. Cutting or drilling into asbestos containing doors are included as Level 3 work. Examples Level 1: A. 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. Level 2: A. Remove asbestos-containing fire door that is damaged. B. Replace lockset or closer on asbestos-containing fire door in poor condition. Lockset may penetrate asbestos core of door. Level 3: A. Cut a door to install new window. B. Drill hole for new lockset through asbestos core of door. Related None Work Practices Worker One worker for Level 1 and Level 2. Two workers may facilitate handling of Recommendations heavy doors being removed. Two workers for Level 3. A person with air monitoring training might be required. This person can be a worker. 216 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 WI, W9 and a bevel 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 Wl for standard tools, equipment and materials list). Scraper 2-3" (30-73 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 General 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. ~ 6. 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 prying 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 a Miscellaneous ACM Asbestos O&M Work Practices a 1992 NIBS M21 Level 2 Remove asbestos-containing fire door and/or door hardware Examples Level 2: A. Remove asbestos-containing fire door that is damaged. B. Replace lockset or closer on asbestos-containing fire door in poor condition. Lockset may penetrate asbestos core of door. 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 Wl for standard tools, equipment and materials list). Screwdrivers and tools needed for hardware and door removal 3. Prepare work area with drop cloth. See General Procedures. 4. Place tools, equipment and materials needed on drop cloth. 5. Wet any damaged areas with amended water. 6. If door is equipped with a closer, detach closer arm from door frame. Wet closer and area where closer is attached to door using amended water. Remove screws attaching closer to door. Wet screws during removal and area behind closer once all screws are removed. HEPA vacuum and wet wipe closer and screws if it is to be re-used. If closer and screws will not be re used, dispose of as ACM waste. 7. Remove lockset from door using procedures used for closer. HEPA vacuum lockset if it will be re-used or dispose of as ACM waste. 8. Lay two layers of polyethylene sheet on floor for wrapping door. 9. Remove hinge pins or screws attaching hinges to door frame. Lay door on polyethylene. 10. 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. 11. Wrap door for disposal. 12. Perform clean-up and tear-down steps on Level 2 checklist to complete work. 218 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M21 Level 1 Remove asbestos-containing fire door and/or door hardware Examples Level 1: A. 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 This work practice must be used in conjunction with General Procedure WI and a Level l Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. : Work Practice 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 WI 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 M22 Summary Remove asbestos-containing built-up roofing Summary This work practice explains the work required to remove a small amount of asbestos-containing built-up roofing or flashing for maintenance or repair work. Examples Level 1: A. Remove small section of damaged asbestos-containing built-up roofing to perform patching, repair or install equipment Level Z- A. Remove small section of asbestos-containing built-up roofing which is damaged to the extent that it has become friable. Related Work Practices M17 Remove and replace asbestos cement roof shingles. M23 Remove asbestos-containing asphalt shingles. 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. 220 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M21 Level 3 Remove asbestos-containing fire door and/or door hardware Examples Level 3: 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 W, 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 Wt for 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 01992 NIBS M22 Level 2 Remove asbestos-containing built-up roofing Example Level 2: A. Remove small section of asbestos-containing built-up rooting which is damaged to the extent that it has become friable. 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. 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 (f surfacing ACM is present on underside ofdeck. 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). Safety hamess/warning line system and/or motion stopping system Hook knife Scraper 2-3* (50-75 mm) wide stiff blade Replacement roofing materials and tools Rope for lowering bags 3. Prepare work area with barrier tape and seal any windows, HVAC units, air intakes or other openings that could allow fibers from work area into building See General Procedure W4. Do not seal any plumbing vents in work area. 4. Place tools, equipment and materials needed in work area. 5. If feasible and safe, adequately wet roofing to be removed using garden sprayer with amended water. 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/bituman 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. 6. Cut around area to be removed using hand tools. Wet cutting area using amended water. Note that several layers may be present. 7. Scrape up roofing section and place into disposal bags. Wet and remove any roofing debris in removal area using scraper. Lower bags to ground. 8. 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. 9. Perform maintenance/repair work and clean-up and tear-down steps on Level 2 checklist to complete work. 222 Miscellaneous ACM Asbestos O&M Work Practices 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 perforin patching, repair or install equipment. Notes Work Practice This work practice must be used in conjunction with General Procedure W1 and a Level I 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 O A hi Work Practice S7 ifsurfacing is present on underside qf deck. ' 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 Wi 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 tiools, 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 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M23. Level 1 Remove asbestos-containing asphalt shingles Example Level 1: A. Remove asbestos-containing asphalt shingles to install a new vent stack. Notes Work Practice This work practice must be used in conjunction with General Procedure Wl and a Level I 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 far roofing wort Roofing removal work shall be completed before any penetrations are made in the roof deck Use Work Practice M31 if HEPA vacuum needs maintenance, or (fbag orfilter needs to be replaced.1 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). Garden sprayer with amended water Scraper 2-3" (30-75 mm) wide stiff blade Roofing repair materials (shingles, roofing cement, nails) Hammer Pry bar Safety harness/warning line system and/or motion stopping system Non-slip boots Spray encapsulant (if used) 3. Place tools, equipment and materials needed in work area. If feasible and safe, adequately wet shingles to be removed with amended water or encapsulant. 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/bituman 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. Slide scraper under bottom shingle and twist scraper to break shingle seal. Remove entire shingle or sections of 3-Tab type shingles. Perimeter of removal area must have clean, straight vertical cuts to allow installation of new shingles. Note that several layers may be present. 5. 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. 6. Pry up tabs on shingles immediately above removal area to facilitate installing new shingles. 224 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M23 Summary Remove asbestos-containing asphalt shingles Summary This work practice describes the 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 the extent that they have become friable. Related Work Practices M17 Remove and replace asbestos cement roof shingles. **22 - 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 1992 NIBS M23 Level 2 Remove asbestos-containing asphalt shingles Example Level 2: A. Remove asbestos-containing asphalt shingles in poor condition to repair roof leak. Shingles are damaged to the extent that they have become friable. 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. Use fail 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 are made in the roof leak.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 Roofing repair materials (shingles, roofing cement, nails) Hammer Pry bar Safety hamess/waming line system and/or motion stopping system Non-slip boots Spray encapsulant (if used) 3. Prepare work area with barrier tape and seal over any windows, HVAC units, air intakes or other openings that could allow fibers from work area into building. See General Procedure W4. Do not seal over any plumbing vents in work area. 4. Place tools, equipment and materials needed in work area. 5. If feasible and safe, adequately wet area of shingles to be removed with amended water or encapsulant. The use of wetting and amended water for roofing work should be limited for the following reasons: A. Wet roofing can create slip hazards. B. Roofing mastic/cool tar/bituman 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. 6. Slide scraper under bottom shingle and twist scraper to break shingle seal. Remove entire shingle or sections of 3-Tab type shingles. Wet underside of shingles as they are removed. Perimeter of removal area must have clean, straight vertical cuts to allow installation of new shingles. Note that several layers may be present. 226 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M23 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.. , ; t 225 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M24 Summary Cut or drill asbestos-containing drywall, piaster or drywall compound Summary This work practice covers the procedures for cutting or drilling of asbestoscontaining drywall or plaster. Joint compounds and tape are also covered by this procedure. 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-poweted hand tools. C. Drill holes in asbestos-containing joint compound where drywall or plaster is non-asbestos. Level 3: A. Install conduit or ductwork through asbestos-containing drywall or plaster using power tools. Related Work Practices M14 Cut or drill asbestos cement panels. Mis Remove asbestos cement panels. Worker One worker is usually sufficient for Level 2. Two workers for Level 3. Two Recommendations workers may be needed to increase efficiency or for additional health and/or safety considerations. Workers should be trained in working with drywall and asbestos. A person with air monitoring training might be required. This person can be a worker. 228 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M23 Level 2~eonumMd 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 sirea. Use HEPA vacuum where needed to clean up ACM. It may not be appropriate or necessary to use HEPA ! vacuum on non-ACM. V 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 them to new shingles. . 1 227 Miscellaneous ACM a Asbestos O&M Work Practices 01992 NIBS M24 Level 2...continued 9. HEPA vacuum removal area and areas accessible from hole. 10. HEPA vacuum and wet wipe up any accessible dust or debris generated on back side. Wet wipe drop cloth and surfaces adjacent to area where hole was cut or drilled. Remove drop cloth and place into disposal bags. 11. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. 230 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS tm i'TWtiTi i 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 if it provides the desired degree of worker and environmental protection. Level 3 ought be necessary to , perform this activity. Appendix G to OSHA regulation 29 CFR 1926.58 states: "The training program for 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 instructedNot to drill holes in asbestos-containing 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). 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 drillcd/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 n Asbestos O&M Work Practices 01992 NIBS M25 Summary Remove section of asbestos-containing drywall Summary This work practice describes the work required to remove a small area of asbestoscontaining drywall, or non-ACM drywall with ACM joint compound in support of O&M work. Examples Level 2: A. Remove small area of asbestos-containing drywall in good condition using non-powered hand tools. Low dust Level expected. Level 3: A. Replace damaged section of asbestos-containing drywall or drywall adhered to studs using hand tools or power tools with HEPA vacuum dust collection attachments. Related Work Practices 1124 Cut or drill asbestos-containing drywall or drywall compound. Worker One worker is usually sufficient for Level 2. Two workers for Level 3. Two or Recommendations 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. 232 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. 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 fades that must be performed before these work practices are begun. Appendix G to OSHA regulation 29 CFR1926JS states: "The training program for the maintenance engineering staff should describe methods of handling asbestoscontaining materials as welt 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. 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). ' 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 local exhaust ventilation. See General Procedure W9. If back side of drywall is accessible, 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 on 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 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M25. Level 3 Remove section of asbestos-containing drywall Example Level 3: A. Replace damaged section of asbestos-containing drywall or drywall adhered to studs using hand tools or power tools with HEPA vacuum dust collection attachments. 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 11 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). Tools as needed Pry bars 3. Prepare regulated area with drop cloth, erect mini-enclosure and set up negative pressure system. See General Procedure W9. If back side of drywall is accessible, enclose and provide negative pressure for enclosure. 4. Place tools, equipment and materials needed into enclosure. 5. Enter enclosure and adequately wet area of drywall to be removed using garden sprayer with amended water. 6. Cut around perimeter of area to be removed using utility knife. Wet cutting area during cutting. 7. If drywall remains attached to studs or substrate, use pry bar to pull sheet out enough so edge can be gripped with hands. Mist cavity behind drywall, and back side of drywall to be 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 3 checklist to complete work. 234 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS `^iTV tunft irttrt ik 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 WI 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 substrate, use pry bar to pull sheet out enough so edge can be gripped with hands. Mist cavity behind drywall and back side of drywall to be 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 M26 Level 1 Remove asbestos-containing 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. Notes _ Work Practice This work practice must be used in conjunction with General Procedure Wl, W4 and a Level I 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 removing duct insulation if needed to access fasteners attaching flexible connector in place. Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag orfilter needs to be replaced.1 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). Scraper 2-3" (30-75 mm) wide stiff blade Stiff nylon bristle brushes Manual or power screwdriver with screwdriver bits and hex head sockets 3. Turn off, lock out and tag out HVAC unit Install critical barriers in ductwork or HVAC unit adjacent to both sides of flexible connector (if possible). See General Procedure W4. 4. Place tools, equipment and materials needed in work area. 5. A. If ductwork will be cut to remove connector, cover flexible connector with polyethylene on outside, and on inside, if accessible. If connector is in good condition, follow step 5B below. Cut away ductwork on both sides of connector and remove ductwork section with connector in place. Package connector for disposal as ACM. B. For connectors in good condition, unscrew all screws holding flexible connector in place. Place screws into a disposal bag if they will not be reused, or clean with water and nylon brushes for reuse. Slide connector off ductwork, pull out of space between ducts, and package for disposal as ACM. 6. HEPA vacuum interior of ducts accessible at both sides where connector was installed. 7. Remove critical barriers if installed inside ductwork or HVAC unit. 8. Perform maintenance work and clean-up and tear-down steps on Level 1 checklist to complete work. 236 Miscellaneous ACM 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 be required. This person can be a worker. 235 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M26 Level 3 Remove asbestos-containing flexible duct connector Example Level 3: A. Remove flexible duct connector in poor condition. 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. - Work Practice Coordinate work with proper OAM work practice for removing duct insulation if needed to access fasteners attaching flexible connector in place.1 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (Set General Procedure Wl for standard tools; equipment and materials list). Scraper 2-3* (50-73 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, erect mini-enclosure and set up negative pressure system and/or HEPA filtered local exhaust ventilation. Enclosure must allow access to all screws attaching connector in place. See Genera! Procedure W9. Also install critical barriers in ductwork or HVAC unit adjacent to both sides flexible connector to be removed Of possible). 4. Place tools, equipment and materials needed into enclosure. 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, clean 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 and wet wipe surfaces where flanges were attached and interior of ducts accessible at both sides where connector was installed. 9. Remove critical barriers if installed inside ductwork or HVAC unit. 10. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist to complete work. 236 Miscellaneous ACM Asbestos O&M Work Practices 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 This work practice must be used in conjunction with General Procedures WI, 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 proper OAM work practice for removing duct insulation ifneeded to accessfasteners attaching flexible connector bi place.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 , Manual or power screwdriver with screwdriver bits and hex head sockets 3. Prepare work area with drop doth. See General Procedure W9. Also, install critical barriers in ductwork or HVAC unit adjacent to both sides of flexible connector (if possible). 4. Place tools, equipment and materials needed into work area. 5. Adequately wet flexible connector with amended water or removal encapsulate. 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 a Asbestos 0&M Work Practices 1992 NIBS M27 Level 1 Remove asbestos-containing ductwork taping cloth Examples Level 1: A. Remove ductwork taping cloth with duct section. B. Remove loose pieces of ductwork taping doth. 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 if bag or filter needs to be replaced.1 1. Perform Pie-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Tin snips 3. Place tools, equipment and materials needed in work area. 4. Using garden sprayer with amended water or removal encapsulant, adequately wet any loose pieces of taping cloth to be removed. 5. If taping doth will be removed with dud section, follow step SA. If loose pieces will be removed, follow step SB. . A. Cover taping cloth with dud tape or polyethylene taped in place. Using tin snips, cut away ductwork on both sides of connedor (do not cut through taping cloth) and remove ductwork section. Package for disposal as ACM. B. Pick up wet pieces of taping cloth and place into disposal bag. 6. HEPA vacuum and/or wet wipe up any visible debris. 7. Perform maintenance work and clean-up and tear-down steps on Level 1 checklist to complete work. 240 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 doth. Level 2; A. Remove a small amount of ductwork taping doth in good condition to install _ new dud attached to existing ducts. Level 3: A. Replace damaged section of ductwork. B. Remove asbestos-containing paper-type dud wrap in poor condition. Related Work Practices M26 Remove asbestos-containing flexible dud connector. Worker One worker is usually sufficient for Levd 1 and Levd 2. Two workers for Level Recommendations 3. Two or more workers may be needed to increase effidency or for additional health and/or safety considerations. A person with air monitoring training might be required. This person can be a worker. 239 Miscellaneous ACM Asbestos O&M Work Practices 01992 NIBS M27. Level 3 Remove asbestos-containing ductwork taping cloth Examples Level 3: A. Replace damaged section of ductwork. B. Remove asbestos-containing paper-type duct wrap in poor condition. 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 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 Scraper 2-3" (30-75 mm) wide stiff blade Stiff nylon bristle brushes Glovebags 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. 5. Enter enclosure and 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 (if used) and adequately wet ACM to be removed. 7. Using scraper, remove taping cloth using glovebag procedures. See General Procedure W17. Wet removal are 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 of as ACM waste. 11. Perform maintenance work and clean-up and tear-down steps on Level 3 checklist to complete work. 242 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M27 Level 2 Remove asbestos-containing ductwork taping cloth Example Level 2: 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, Vi17 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 Gerund Procedure Wl for standard tools, equipment and materials list). . Tools and materials needed for duct work Glovebags . Scraper 2-3" (30-75 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 encapsulate into glovebag and adequately wet taping cloth to be removed. 7. Using scraper inside glovebag, remove taping cloth using glovebag procedures See General Procedure W17. Wet removal area during removal. 8. Gean 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 of as 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 M28 Level 2 Remove contaminated filters in HVAC unit serving plenum space with exposed ACM Examples Level 2: A. Remove prefabricated slip-in type filters from HVAC unit in mechanical room. B. Replace filters in HVAC unit in mechanical room with roll-type filters. 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 Coordinate work with proper OAM work practice for accessing type of ceiling present in work area. OSHA standard 29 CFR 1926.58 Appendix G states employees should be instructed to not remove ventilation system filters dry and not to shake ventilation system filters.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 filter material, if needed 3. Prepare work area with drop cloth. See General Procedure W9. Verify that HVAC unit is shut off and locked out. 4. Place tools, equipment and materials needed onto drop cloth. 5. Adequately wet filters to be removed. 6. Remove filters and dispose of as ACM. Cut away exposed portions of roll type filters, wrap in polyethylene sheet and dispose of as ACM. 7. Wet any dust or debris on drop cloth, and fold up drop cloth and dispose of as ACM. 8. HEPA vacuum and wet wipe area where filters were installed and accessible surfaces in filter chamber. 9. Roll new filter material into place and cover remaining filter material. Perform clean-up and tear-down steps on Level 2 checklist to complete work. 244 Miscellaneous ACM Asbestos 0&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 Level 2: A. Remove prefabricated slip*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 G1992 NIBS M29 Level 1 Clean up debris from minor fiber release Example Level 1: A. Clean up small amount of ACM debris that will stick to a small piece of duct tape. Notes This work practice ftuist 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. Work Practice Coordinate work with proper OAM work practice to repair cause offiber release If repair is necessary. 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). None 3. Cover debris with duct tape and press to adhere debris to tape. Repeat with another piece of tape if needed. Dispose of tape as ACM or in accordance with applicable regulations. 4. Perform applicable steps on Level 1 checklist to complete work. 246 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M29 Summary Clean up debris from minor fiber release Summary This work practice describes the 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. Clean up a small amount of debris from damaged diywall. Related Work Practices S10 Repair damaged surfacing ACM. 17 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 a Miscellaneous ACM a Asbestos O&M Work Practices a 01992 NIBS M30 Summary Replace asbestos-containing gaskets Summary This work practice describes the work required to replace ACM gaskets or ACM valve packings for O&M work. Examples Level 1: A. Replace small non-adhered gasket that can be removed intact Level 2: A. Replace small valve packing. B. Replace gasket between two small or medium size pipe flanges. C. Replace small damaged gasket Level 3: A. Replace large pipe flange gasket B. Replace gasket on boiler door. C. Replace well-adhered gasket Related Work Practices Tl Remove insulation on exposed pipe for maintenance work. T4 * Remove insulation on exposed pipe in elevated location for maintenance work. T7 Repair damaged thermal system insulation on a boiler, duct or flue. 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. 248 Miscellaneous ACM Asbestos O&M Work Practices 1992 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 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. Work Practice Coordinate work with proper O AM work practice to repair cause offiber release.1 2 3 4 5 6 7 8 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 - 3. Prepare work area with critical barriers. See General Procedure W4. 4. Place tools, equipment and materials needed into work area. 1 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 Miscellaneous ACM a Asbestos O&M Work Practices 1992 NIBS M30 Level 2 Replace asbestos-containing gaskets Examples Level 2: A. Replace small valve packing. B. Replace gasket between two small or medium size pipe flanges. C. Replace small damaged gasket Notes 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 A M work practice if other 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 2 3 4 5 6 7 8 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 Tools required to access or remove gasket Non-ACM replacement materials Glovebag 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools, equipment and materials needed into work area. 5. 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 Altered 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 clean-up and tear-down steps on Level 2 checklist to complete work. 250 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M30 Level 1 Replace asbestos-containing gaskets Example Level 1: A. Replace small non-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 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. ; Coordinate work with proper O AM work practice If other 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 lisp. Tools required to access gasket Non-ACM replacement materials ............ 3. Place tools, equipment and materials needed in work area. 4. Disassemble equipment as needed 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 1992 NIBS M31 Summary Emptying and changing filter in HEPA vacuum or changing filter in HEPA fan unit Summary This work practice covers the procedures for changing the bag, filter and/or cleaning a HEPA vacuum, or changing the filter in a HEPA filtered fan unit. Examples Level 2: 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. Level 3: A. Empty bag, change filter and clean HEPA vacuum. B. Change filter in a HEPA fan unit in a mini-enclosure. Related None Work Practices Worker One worker for Level 2. Two workers for Level 3. A person with air monitoring Recommendations training might be required. This person can be the worker. 252 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 B. Replace gasket on boiler door. C. Replace well-adhered gasket Notes This work practice must be used in conjunction with General Procedures Wl, W9, WI7 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 OAM work practice if other ACM must be removed prior to gasket replacement. Ifactive electrical equipment is in work area, delete wetting (f permitted by EPA) for this work.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" (30-73 mm) wide stiff blade Stiff nylon bristle brushes Tools required to access or remove gasket Non-ACM replacement materials Glovebag 3. Prepare work urea 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. 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 O&M Work Practices 1992 NIBS M31 Level 3 Emptying and changing filter in HEPA vacuum or changing filter in HEPA fan unit Examples Level 3: A. Empty bag, change filter and clean HEPA vacuum. B. Change filter in HEPA fan unit in a mini-enclosure. Notes Work Practice This work practice must be used in conjunction with General Procedures WI, W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. This procedure may be performed in an existing mini-enclosure, if available.1 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). Manufacturer's instructions for unit having filter or bag replaced Tools as needed to remove filter or bag Replacement filters or bags 3. Prepare work area with drop cloth, erect mini-enclosure and set up negative pressure system or HEPA filtered local exhaust ventilation. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth, including HEPA vacuum or fan unit with filter or bag to be changed. If available, include an operable HEPA vacuum for cleaning up any dust or debris from the filter change operation. 5. Enter enclosure and carefully disassemble unit as needed to access filter or bag. Adequately wet filter and/or bag, remove from unit and place into disposal bag. 6. Adequately wet any remaining debris. Pick up debris or empty debris into a disposal bag. 7. Using operable HEPA vacuum or wet wiping, clean area where filter or bag was installed. 8. Install new filter and/or bag in unit, reassemble unit and perform clean-up and tear-down steps on Level 3 checklist to complete work. 254 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 2: 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. Notes - Work Practice This work practice must be used in conjunction with General Procedures Wi, W9 and a Lewd 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 WI for standard toots, 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 cloth and HEPA filtered local exhaust ventilation. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth, including HEPA vacuum or fan unit with filter or bag to be changed. If available, include an operable HEPA vacuum for cleaning up any dust 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 SB procedures. 5. A. Insert new bag or filter, wet wiping cloths, 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. Gose 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. 253 Miscellaneous ACM Asbestos O&M Work Practices 01992 NIBS M32. Level 1 Remove asbestos-wrapped wiring Example Level 1: A. Remove wiring in good condition on single stage spotlight. Notes 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. Work Practice - Verify that approval has been receivedfrom the EPA if wetting will not be usedfor removing asbestos-containing electrical wiring. Use Work Practice Mil if HEPA vacuum needs maintenance, or if bag or filter 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). Electrician's insulated gloves Screwdrivers Wire cutters Voltmeter Soldering iron for soldered connections 3. Place tools, equipment and materials needed in work area. Verify that electrical power to wiring is shut off and locked out Test circuits using voltmeter. 4. Put on insulated gloves and cut out exposed wiring to be removed. Roll up wiring and place into disposal bags. 5. Open any junction boxes or equipment as needed to remove wiring back to screw terminals or soldered connections. 6. Cut or disconnect wiring from terminals or connections. Place wiring into disposal bags. HEPA vacuum any surfaces that were in contact with wiring. 7. Perform maintenance work and clean-up and tear-down steps on Level 1 checklist to complete work. 256 Miscellaneous ACM i 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 asbestos wrapped 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. B. 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. B. 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 and/or if work occurs in a confined space. Workers should be trained electricians with asbestos training to perform this work. A person with air monitoring training might be required. This person can be the worker. 255 Miscellaneous ACM Asbestos O&M Work Practices 01992 NIBS M32 Level 2 Remove asbestos-wrapped wiring Examples Level 2: A. Remove wiring in good condition on several stage spotlights. B. Remove asbestos wrapped wiring located in underground electrical vaults where wrapping is in good condition. See APM8 regarding confined space precautions. , 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. Verify that approval has been receivedfrom the EPA if wetting will not be usedfor removing asbestos-containing electrical wiring.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). Electricians insulated gloves Screwdrivers Wire cutters Voltmeter Soldering iron for soldered connections 3. Prepare work area with drop cloth. 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 onto drop cloth. 5. Put on insulated gloves ant) 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. Disconnect remaining wiring from terminals or connections. Place wiring into disposal bags. 8. HEPA vacuum any surfaces that were in contact with wiring. 9. Perform maintenance work and clean-up and tear-down steps on Level 2 checklist to complete work. tr MI i . -1 in /?* e iaiinA M32.Level3 Remove asbestos-wrapped wiring Examples Laval 3: A. Remove damaged wiring in poor condition. B. Remove asbestos wrapped wiring located in underground electrical vaults where wrapping is in poor condition. See APM8 regarding confined space precautions. . . , 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. Work Practice Verify that approval has been receivedfrom the EPA ifwetting will not be used on electrical wiring to be removed.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). Electricians insulated gloves Screwdrivers Wire cutters Voltmeter . 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. 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 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 01992 NIBS M34 Summary Clean room that has asbestos-containing dust Summary This work practice should be used for routine or special cleaning in rooms where asbestos-containing dust is present, or is assumed to be present The practices include the cleaning of furniture, fixtures, and other surfaces. 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. Clean a mechanical room where dust is assumed to contain ACM from thermal systems insulation present in room. Related Work Practices S9 Clean room with exposed surfaces finished with ACM M6 Wet strip floor wax from resilient asbestos flooring M7 Dry or spray buffing resilient asbestos flooring M8 Cleaning resilient asbestos flooring M29 Clean up debris from minor release Worker One worker trained in special cleaning procedures. A person with air monitoring Recommendations training might be required. This person can be the worker. 263 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. Clean a mechanical room where dust is assumed to contain ACM from thermal systems insulation present in room.;, Notes This work practice must be used in conjunction with General Procedures W, W* and a ^ Lord I Worker Checklist. The worker checklist includes tasks that must be performed before these work practices ore begun. . , Use Work Practice M31jfHEPA vacuum needs maintenance, or ifbag orfilter needs to 1 ~ be replaced. ;1 2 3 4 5 6 7 Work Practice 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (toe General Procedure Wlfor 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 > ;j 3. Place Tools, equipment and materials needed in work area, 4. Using damp or treated dusting materials, dean surfaces beginning from the top of the room and working towards the floor. HEPA vacuum surfaces that are not easily cleaned with dusting materials; Surfaces that are not routinely cleaned (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 doth is : needed. Dispose of all dirty cloths and soiled dusting materials while still i damp in ACM disposal bags. . , 5. Clean floor with HEPA vacuum. See General Procedure W8. 6. Apply new polish where needed using standard procedures. 7. Perform clean-up and tear-down steps on Level 1 checklist to complete work. I 264 Miscellaneous ACM Asbestos O&M Work Practices a 01992 NIBS M33 Level 3 Remove asbestos-containing caulking compound Example Level 3: A. Reglaze an entire window or several windows 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.1 2 3 4 5 6 7 8 9 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). Scraper (2-3" wide stiff blade) Stiff nylon bristle brushes 3. Prepare work area with drop cloth, mini-enclosure and set up negative pressure system and/or HEPA filtered local exhaust ventilation on side of window with exposed caulking compound. See General Procedure W9. 4. Place tools, equipment and materials needed into enclosure. 5. Enter enclosure and adequately wet caulking to be removed using garden sprayer with amended water. 6. 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 place caulking 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 3 checklist to complete work. 262 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 Work Practice This work practice nuat 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 Re-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 drop doth. See General Procedure W9. 4. Place tools, equipment and materials needed 'onto drop cloth. 5. Enter workareaand adequately wet caulking to be removed using garden sprayer with amended water. ' 6. 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 place caulking 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. 261 Miscellaneous ACM a Asbestos O&M Work Practices a 01992 NIBS M33 Summary Remove asbestos-containing caulking compound Summary This work practice describes the procedures for removing small amounts of asbestos-containing caulldng compound as required for maintenance or repair work. Examples Level 1: A. Remove a small amount of pliable caulking compound. No sanding will be performed. Level 2: A. Reglaze several small window panes. No sanding will be performed. B. Remove small amount of dry caulking compound. Level 3: A. Reglaze an entire window or several windows. Related None Work Practices Worker One worker for Level 1 and Level 2. Two workers for Level 3. A person with air Recommendations monitoring training might be required. This person can be the worker. 259 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M33 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 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 if bag 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 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. Perform 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 Section V. Thermal Systems Insulation (TSI) Work Practices Work Practices Location Illustration.................................................................... 106 Code Levels Description T1 2 3 Remove asbestos-containing insulation on exposed pipe for maintenance work.....................................................109 72 2 3 Remove asbestos-containing insulation on pipe above ceiling for maintenance work...............................112 73 2 3 Remove asbestos-containing insulation on exposed pipe in elevated location for maintenance work.................... 113 74 3 Remove asbestos-containing insulation on pipe in occupied area for maintenance work................................... l lg 75 2 3 Repair damaged asbestos-containing insulation on a pipe ............................................................................... 120 76 2 3 Repair damaged asbestos-containing insulation on a boiler, duct or flue.................................................................. 124 77 2 3 Install device in or access surface of asbestos-containing insulation on a pipe, boiler, duct or flue............................... 128 78 2 3 Remove asbestos-containing duct insulation above ceiling for maintenance work........................................132 79 2 3 Remove asbestos-containing insulation inside HVAC unit for maintenance work................................. 133 710 23 Clean up asbestos-containing debris in crawlspace or tunnel................................................................................. 138 The accompanying diagram illustrates typical applications of these work practices. The following general notes should be reviewed by users of the TSI work practices:1 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 the appropriate type for the size of the 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. The O & M program may also require that two workers be used for glovebag removal work. 107 Thermal Systems Insulation Asbestos 0&M Work Practices 01992 NIBS 4. General Procedure APM10 discusses emergency work and/or dry removal that might be necessary under certain conditions, such as removing insulation adjacent to an activated power panel to make emergency repairs on a critical piece of equipment Review and comply with all applicable regulatory requirements. 5. Some of the TSI Work Practices specify attaching a glovebag over duct tape applied around a pipe. If the pipe insulation surface is smooth, a flexible metal sleeve might be wrapped around the pipe in lieu of duct tape if an adequate seal can be obtained. This allows removal of the metal sleeve at the end of the work rather than leaving duct tape in place around the pipe (duct tape is recommended to be left in [dace because removal of duct tape can damage ACM insulation). 6. Careful work practices should be the primary means used to prevent releases of asbestos fibers during O&M work. Such practices include control measures such as wetting and local exhaust that control or collect fibers at the source. The goal of all asbestos O&M work should be to prevent any exposure of the worker and unnecessary contamination of the work area, drop cloths, mini-enclosures and other secondary control devices. Mini-enclosures should never be used to excuse sloppy work or creation of "bigger" messes. 108 a Thermal Systems Insulation Asbestos O&M Work Practices a 1992 NIBS rrtf iH.fwfTitoT hirfrfnaTdMii Appendices Appendices Appendix A Job Request Form for Maintenance Work........................... 267 Appendix B Maintenance Work Authorization Form................................269 Appendix C Evaluation of Work Affecting Asbestos-Containing Materials......... ...............................................271 Appendix 0 Waste Tracking Form ........................... ...............................273 Appendix E Glossary .................. ....................................................... 273 Appendix F References......................................................... 280 Appendix G General Safety Considerations ............................................. 283 Appendix H Definitions of Small-scale, Short-duration Operations......... 289 Appendix I Regulations........................................................................... 293 Appendix J * Minority Opinions..... ............ 299 Appendix K NIBS Feedback Form ........................................................ .. 317 i 266 Appendices a 1992 NIBS Appendix A Job Request Form for Maintenance Work (from EPA Green Book) 267 Appendices 1992 NIBS Job Request Form for Maintenance Work Name:___________________ - _______________________________________________ ______Dte:___________ Telephone No.__________lab Request No. Requested starting dale: - 'i; Anticipated finish date: Address, building, and room numbers) (or description of area) where work is to be performed: Description of work: Description of any asbestos-containing material that might be affected, if known (include location and type): Name and telephone number of requestor Name and telephone number of supervisor Submit this application to: (The Arbeatoa Program Manager) NOTE: An application must be submitted for all maintenance work whether or not asbestos-containing material might be affected. An authorization must then be received before any work can proceed. ' _______Granted (lob Request No.) _______With conditions* . _______Dented , . 'Conditions: 268 Appendices 1992 NIBS Appendix B______________________ Maintenance Work Authorization Form (from EPA Green Book) 269 Appendices 1992 NIBS Maintenance Wort Authorization Form AUTHORIZATION AuthortzjUon ie given to peocaad with the following maintenance work: No. PRESENCE OF ASBESIDS40NTAMMG HATEHALS ______ AAnloMniM| an aot prunt ia the vidairy at the maiatraaara aok. ie if win___ ACM is present- bat its disturbaace act aatidpaled: however, coaditioaa chaage, the Aebeetoe Flopa Maaager rn nahtwr te work request prior la prooeediaf. _______ ACM ie preset*, sad may be disoabed. Wort PtacUet I Aebaetoe-Containing Ualerial* An Pmatnl Th* followiaf work practice* shall be employed to avoid or miaimize distutbiag asbestoe: Ptitonai Protection I Atbaeto*-Containing Material* An Praaant The foDowiag equipmeat/clothes shell be used/wora daring the work to protect workers: (oiaauals oa personal protectioa caa be refereaoed) Special Practtoea and/or Equipment Required: Signed:. (Asbestos Program Manager) 270 Appendices 1992 NIBS Dale:. trm.ajn.~eeM iCS'-iar.TTr T (a> wifra^-ai.-nnii ,--rt^i.-i i-riv^.r^iivi'' Appendix C Evaluation of Work Affecting Asbestos-Containing Materials (from EPA Green Book) 271 Appendices 1992 NIBS Evaluation at Work Mlacting Asbosioa-Coatalning Hotartels Thi< evaluation coven the foflowiig maintenance wart: Lacalioa af wmkd (address, buildiag, room numbers). or gcocnl description): Dale(<) of week:__________________________________________________________ Description ot work:______________________________________________________ Work approval fono number Evihiatioa of wort praclioea employed to disunbaaoe of eabcetoe: Evaluation of oak pnetiom employed to nnotaio released tjben aad to deal op the wok area: Evahtatioo of equipment aad procedures used to protect workers: Pences] air monitorial results: Go-house worker or contract?) Worker aame_____________________________________________________ Results: _ Worker aame Results: _ Handling or storage of ACM waste:_______________________________________________________ Signed:Date:. (Asbestos Prognm Manager) 272 Appendices 1992 NIBS -nni-riiiiafn Appendix D________ Waste Tracking Form lUnAmno wirt/. 273 a Appendices 1992 NIBS Waste Tracking Form Prt 1 - To be completed by worken: Maioteaaace World Aiahoriiatioa No.___ Work Locatioa: Building:________________ Room # or Are*:_____________ Type of ACM Removed: Quality of Vole generated: _ Other coauimn:_______ Wide tamponed to: ____________________________________ Treuponed by: Trecking Form give* to:__________________________________ Part 2 - To be completed bv Aabeetoe Ptoerem Manner Wane Properly Packaged A Labeled: Yea______No______ EXCEPTIONS:_____________________________________ Wuu Storage Locatioa: Waau Dijpoaal Locatioa: Waite Stipmeat Record* Received: Date:_________ SIGNED: ASBESTOS PROGRAM MANAGER DATE: Bagi 274 Appendices 1992 NIBS Appendix E Glossary Acoustical Plaster Sound absorbing finishing materia! 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). Hie 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-Containing Material (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 waste and materials 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 ACM. Asbestos Hazard Emergency Response Act (AHERA) AnEPA regulation published in the 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 - Glossaty 1992 NIBS Asbestos O&M Work Cleaning, maintenance, repair or renovation work involving asbestos containing materials where the intent of the activity is not to remove asbestos. NESHAP requires that the owner or operator of a demolition or renovation activity conduct a thorough inspection of the affected facility or part of the facility where demolition or renovation will occur. Asbestos Program Manager (APM) a building owner or designated representative who supervises all aspects of the facility asbestos management and control program. Breathing Zone A hemisphere forward of the shoulders with a radius of approximately 6" to 9" (150-230 mm). Bridging encapsulate An encapsulate that forms a discrete layer on the surface of an in situ asbestos matrix. Concealed Suspension or Concealed Spline Celling System Presents a monolithic ceiling surface, unobstructed by the cross-hatching of exposed grid members. Tiles are typically 12" x 12" (305 x 305 mm) or 12" x 24" (305 x 610 mm) with slots or kerfs cut into the edges of tiles for the purposes of accepting flat or "T" splines to support the tiles. Confined Space A space that has limited openings for entry and exit, unfavorable natural ventilation and/or a space not desgned for continuous worker occupancy. Examples include boilers, furnaces, pits, septic tanks, manholes, silas and utility vaults. Critical Barrier One or more layers of polyethylene taped in place over openings into a work area. Openings to be covered include doors, windows, diffusers, and any other opening that could allow outside air into a work area. Decorative Acoustic Finish: Finishing material mill-formulated and spray applied up to about 3/8" (10 mm) thick over gypsum wallboard. Material has a rough surface and is similar in appearance to acoustic plaster but is not designed for sound absorption. Delamination Separation of one layer from another. Disposal Bag Properly labeled 6 mil (0.15 mm) thick (or thicker) leak-tight plastic bags used for transporting asbestos waste from work and to disposal site. Drop Cloth A layer of polyethylene on the floor of a work area to protect the floor below from contamination and to facilitate the clean-up of dust or debris generated during the work. Encapsulate A material that surrounds or embeds asbestos fibers in an adhesive matrix, to prevent release of fibers. Enclosure The construction of an air-tight, impermeable, permanent barrier around asbestos-containing material to control the release of asbestos fibers into the air. EPA U.S. Environmental Protection Agency Excursion Limn (EL) The OSHA term used to define a maximum airborne concentration of asbestos in fibers per cubic centimeter as averaged over a sampling period of thirty minutes. Fiber Release Any uncontrolled or unintentional disturbance of ACBM resulting in visible emission. 276 Appendix E - Glossary 1992 NIBS Fireproofing Material 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") Giovebag A polyethylene or polyvinyl chloride bag-like enclosure affixed around an asbestos-containing source (most often, TSI) 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 asbestos- containing building material on structural components, structural members or fixtures,such 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 the 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 Gean Air Act NIOSH The National Institute for Occupational Safety and Health, which was established by the Occupational Safety and 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.m., Monday through Friday). OSHA Occupational Health & Safety Administration 277 Appendix E - Glossary 1992 NIBS Penetrating Encapsulant An encapsulant that is absorbed by the in situ asbestos matrix without leaving a discrete surface layer. Personal Air Samples An air sample taken with a sampling pump directly attached to the worker with the collecting filter and cassette placed in the worker's breathing zone. These samples are required by the OSHA asbestos standards and the EPA Worker Protection Rule. Phase Contrast Microscopy (PCM) a method of analysis using a light microscope, used to find die concentration of airborne fibers. Does not distinguish among asbestos and other fibers. Used by OSHA to find personal exposures, and by EPA to find area levels for AHERA project clearance. Plenum Any space to convey air in a building or structure. The space above a suspended ceiling is often used as an air plenum. This term is also used in the work practices to refer to spaces above a ceiling not used to convey air. Polarized Light Microscopy (PLM) a method of analysis using a light microscope to find the chemical or mineral types of samples, including the concentration of asbestos in bulk materials. Used by EPA for AHERA and NESHAP, and by OSHA to see if asbestos is involved in a project Protection Factor The ratio of the ambient concentration of an airborne substance to the concentration of the substance inside the respirator at the breathing zone of the wearer. The protection factor is a measure of the degree of protection provided by a respirator to the wearer. Regulated ACM (RACM) As defined by NESHAP in the November 20. 1990 Federal Register, regulated asbestos-containing material (RACM) means (a) Friable asbestos material (b) Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category n nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by this subpart (Not*: Regulated ACM is an EPA NESHAP concept. OSHA makes no distinction between friable and nonfriable asbestos). "Cutting" means to penetrate with a sharp-edged instrument and includes sawing, but does not include shearing, slicing or punching. "Grinding" means to reduce powder or small fragments and includes mechanical clippping or drilling. Friable asbestos material means any material containing more than 1 percent asbestos as determined using the method specified under AHERA (40 CFR Part 763, Sub part F, Appendix A, section 1, Polarized Light Microscopy) that when dry, can be crumbled, pul verized, or reduced to powder by hand pressure. If the asbestos content is less than 10 percent as determined by a method other than point counting by polarized light microscopy (PLM), verify the as bestos content by point counting using PLM. 278 a Appendix E - Glossary a 1992 NIBS ----Ty- -- iirrfmiiiiv. ` nr *UXi . Category I 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 II 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 (Sec 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 materia] 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 Electron Microscopy (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 asbestos- related 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 Appendix F References EPA Regulations United States Environmental Protection Agency, Asbestos Abatement Projects; Worker Protection; Final Rule ("Worker Protection Rule") 40 CFR 763.120-126, Washington D.C., 1987. United States Environmental Protection Agency, National Emission Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 61.140-157, Washington D.C., 1984, revised 1990. United States Environmental Protection Agency, Asbestos-Containing Materials in Schools; Final Rule and Notice (Asbestos Hazard Emergency Response Act AHERA) 40 CFR 763.80-99, Washington D.C.. 1987. EPA Guidance Documents (Order by Calling TSCA Assistance Hotline in Washington, DC at: (202) 554-1404). United States Environmental Protection Agency, Managing Asbestos in Place ("Green Book") EPA Publication 02OT-2OO3, Washington D.C., 1990. United States Environmental Protection Agency, Guidance for Controlling Asbestos-Containing Materials in Buildings ("Purple Book") EPA publication 0560/5-85-024, Washington D.C., 1985. United States Environmental Protection Agency, A Guide to Respiratory Protection for the Asbestos Abatement Industry ("White Book) EPA publication 056O-OPTS-86-OO1, Washington D.C., 1986. United States Environmental Protection Agency, Simplified Sampling scheme for Surfacing Materials (Pink Book") EPA publication 056OZ5-85-O3Oa, Washington D.C., 1985. United States Environmental Protection Agency, EPA Guidance for Service and Maintenance Personnel, EPA publication 0560/5-85-018, Washington D.C., 1985. United States Environmental Protection Agency, Model training course materials for accrediting Asbestos Building Inspectors and Management Planners in accordance with AHERA, Washington D.C., 1987. United States Environmental Protection Agency, Abatement ofAsbestosContaining Pipe Insulation, Asbestos-in-Buildings Technical Bulletin 1986-2, Washington D.C., 1986. 280 Appendix F - References 01992 NIBS OSHA Regulations Occupational Safety and Health Administration, Asbestos Regulations for the Construction Industry 29 CFR 1926.58, Washington D.C., 1986. Occupational Safety and Health Administration, Respiratory Protection 29 CFR 1910.134, 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. Asbestos (Air monitoring guidance, etc.) Information Center ' Miscellaneous References Institute for Environmental 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 of Asbestos Keyes, Dale L. and Chessoo, Jean. Guide to Monitoring Airborne Asbestos 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 O&M Program Elements References Element Regulations A Guidance Documents Green Book Guidance APM Appointment A Training Worker Training Building Impaction A Assessment Occupant Notification A Communication Heard Communication Program Worker Protection Program Respiratory Protection Program Uedtcal Surveillance Work Permit System Waste Disposal Recordkeeping Fiber Releases Periodic Surveillance A Relnspectkxts Air Monitoring Confined Spaces General Safety Hazards Purple Book, AHERA, White Book Pgs. 7 A 23 - 25 Purple Book, AHERA, White Book Purple Book, AHERA. Pink Book Pgs. 23 - 25 Pg.7 AHERA Pgs. 12 - 13, 28 - 29 OSHA 29 CFR 1910.1200 A OSHA 29 CFR 1926.59. OSHA 29 CFR 1926.58 Pg.22 Pgs. 17 - 18, 38 White Book, OSHA 29 CFR 1910.134, 1926.58 Pgs. 17 - 18 OSHA 29 CFR 1926.58 -- EPA NESHAP 40 CFR 61.145,150 OSHA 29 CFR 1910.1200, DOT 49 CFR Parti 171 A 180. AHERA Purple Book, AHERA Purple Book, AHERA Pg.27 Pg. 15 Pg. 28 Pg.22 Pgs. 20 - 21 Pg. 14 Purple Book, AHERA OSHA 29 CFR 1926.58 Federal Register June 5, 1989 OSHA Proposed Rules While Book Appendix D OSHA 29 CFR Part 1926 Pgs. 10. 14 IS 282 Appendix F References 1992 NIBS Appendix G General Safety Considerations (This section Is reprinted from Appendix D of the EPA's White Book for use by personnel performing 0 & M activities.) 263 Appendix G General Safely Considerations 01992 NIBS General Safety Considerations Ronald L. Stanevich NIOSH Division of Safety Research This guide wu primarily developed to provide recommendatione concerning worker respiratory protection within the asbestos abatement industry. However, employers must not lose sight of the safety hazards their employees are exposed to in performance of their work. Asbestos abatement operations can take place in a variety of industrial, commercial and public settings. Each has unique potential satety hazards that the employer must control However, nearly all abatement operations have some common safety hazards. With proper job planning and supervision, the employer can control both the health hazards and the safety hazards faced by their workers. The more common safety hazards associated with abatement operations and general recommendations to control them are discussed below. Sources for more specific safety information are listed to supplement and support the applicable OSHA regulatory standards. 1. Elevated Work Surfaces The nature of asbestos abatement tasks usually requires workers to work from ladders, scaffolds, manlifts, or other elevated surfaces, which creates the potential for fall injuries. Slips and falls from ladders, scaffolds, and other elevated surfaces result in a major portion of the construction industry injuries. Many of these can be prevented by implementing a few control measures: A. General (1) Avoid use of makeshift work platforms by providing portable ladders and scaffolds. (2) Ensure that job-built elevated work surfaces are inspected by a competent person other than the individual who erects it. (3) Avoid working from elevated surfaces where possble. Consider use of wands for spraying amended water or scrapers with extended handles. B. Ladders Eighty percent of ladder-related accidents result from improper use or application. (1) Workers should face the ladder when climbing up, down, or working from it (2) Workers should not cany objects in their hands while ascending or descending ladders. While working from a ladder they should hold on with at least one hand. (3) Ladders should not be used as a substitute for planks, runways, or walkboards. (4) Ladders should be maintained in good condHion. Defective ladders should be destroyed so that no one uses them by mistake. (5) Ladders should have safety feet in good condition to keep the ladder from slipping and cutting through polyethylene floor covers. (6) Ladder rungs/steps should be kept free of contaminates such as amended water and buildup of asbestos waste. (7) Employees should work no higher than the fourth step/rung from the top of the ladder. (8) Employees should not attempt to 'reach* distant objects from a ladder; other platforms should be used. 284 Appendix G General Safety Considerations 1992 NIBS ^ ' ' , y rrr fl~ ' (9) Wood or fiberglass ladders should be provided to help control exposure to electrical hazards. (10) Employees Should not straddle the space between a ladder and another object (11) Employees should make a visual inspection o( ladders before each shift Additional 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 8665 National Safety Council 444 North Michigan Avenue Chicago Illinois 60611 Environmental Health and Safety Division Georgia Tech Research Institute Georgia Institute of Technology Atlanta, Georgia 30332 C. Scaffolds Fads 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 the work surface regardless of scaffold height (2) securing scaffold decks against slippage (3) keeping scaffold uprights venical 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 dimensions (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 Appendix G - General Safety Considerations Q 1992 NIBS (9) keeping mobile scaffoldmg height lese than four timee the minimum bate dimension and with cross-bracing . . (10) never interchanging ecaffolding pans from different unite (11) never using defective scaffolding (12) designating only 'Competent* persons to perform scaffolding repairs. . Additional information sources: `Manually Propelled Mobile Ladder Stands and Scaffolds* ANSI A92.1 1977 `Manually Propelled Elevating Work Platforms" - ANSI A92.3 - 1980 `Self-Propelled Elevating Work Platform' -- ANSI A92.6 American National Standards Institute, Inc. 1430 Broadway New York, NY 10018 .. IL Electrical Hazards Asbestos abatement is often related to renovation or remodeling activities. Normally the equipment, machinery, overhead lighting fixtures; and auxiliary furnishings are removed to facilitate the abatement work. However, H is becoming more common that industrial and commercial buildings remain paniaKy occupied while abatement operations are performed. In either situation, the abatement operator must taka positive actions to protect employees from accidently coming into contact with energized electrical circuits. A. General (1) Perform a pre-work walk-through of the abatement area to look for pre-existing electrical hazards involved with the work. (2) De-energize as many circuits as possfele. (3) Verify that the circuits have been de-energized with a `Reid Current Sensing Device* circuit tester. Either lock out/tag out all de-energized circuits to prevent them from accidentally being energized. (4) Use non-conductive tools such as scrapers and vacuum attachments made of wood, plastic, or rubber. (5) Provide workers with non-conductive rubber boots and/or gloves when work must be done around energized wiring or equipment . (6) Prohibit accumulation of puddles of water on die floor. Workers should be trained in the intelligent use of amended water. No water should be used around energized circuits. B. Permanent Building Circuitry (1) Ensure that all permanent circuits are provided with a grounding system. This can be determined with a portable ground tester. (2) Ensure that electrical outlets are tightly sealed and taped to avoid water spray. 266 Appendix G General Safety Considerations 8 1992 NIBS (3) Determina 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 woric. (6) Consider dry removal methods in the vicinity of electrical equipment which must remain energized. C. Temporary Power (1) 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. 0. 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 lighting. (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 C2-1984 '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 60611 287 Appendix G - General Safety Considerations 1992 NIBS III. Houskeeplng Asbestos abatement operations present continuous housekeeping problems. The accumulation of asbestos and other debris on polyethylene-covered floors create employee slipping and tripping hazards. It is essential that accumulation of such debris be bagged and removed from the floor as soon as posable. Even though this activity may initially require more effort, it will make final cleanup easier and the work area safer. Additional information source: . `Supervisors Safety Manual* National Safety Council 444 North Michigan Avenue Chicago, Illinois 60011 IV. Emergency Planning The abatement operator should develop emergency procedures for fires or severly injured employees. Since abatement work areas must be sealed off. thereby blocking normal exits, the operator must familiarize the workers with procedures for safe exit in case of fire. Furthermore, the operator should develop plans for obtaining emergency aid in case of severe employee injury. The plans should be compatible with decontamination procedures yet provide for quick medical aid. Additional information source: Environmental Health and Safety Division Georgia Tech Research Institute Georgia Institute of Technology Atlanta, Georgia 30332 ' 288 Appendix G General Safety Considerations 1992 NIBS i 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 the 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. 9 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. 1926.5 8(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 person, if the operation is small-scale, short-duration. For the purposes of this standard a "small-scale, shortduration" operation is defined as: (1) Maintenance or renovation tasks, where the removal of asbestos- containing materials is not the primary goal of the job (e.g., repairing a valve which entails the removal of asbestos, installing electrical conduit which niust be fastened to asbestos cement siding, etc.) (2) Activities where the employees* exposures to asbestos can be kept below the action level1 via worker isolation techniques, such as glove bags or other methods described in Appendix G4 . (3) An operation which has been included in the employer's asbestos maintenance program (as required in Appendix G) of all employers who are claiming an exemption from the requirements of 29 C.R.R. 1926.58(e)(6). (4) Nonrepetitive operations (viz.: not' a series of small-scale jobs, which if performed at one time would have resulted in a large-scale removal). . OSHA Instruction CPL 2-2.40 (September 1,1987). D.OSHA's Proposed Revisions to the Current Definition NOTE: This sections describes proposed rules that are not legally binding as of September 1992. OSHA may change this definition in the final rules. (1) Regulated Areas OSHA has proposed to require regulated area protections for all maintenance work covered under the construction asbestos standard, including small-scale, short-duration operations, regardless of measured exposure levels. (55 Fed. Reg. 23,752 (1990). (2) Proposed Definition of Small-Scale, Short-Duration Operations OSHA's proposed definition first sets forth general criteria,,then lists specific operations that fall within those criteria. (55 Fed. Reg. 29,717.) Hie genera] criteria are that the operations are: non-repetitive; affect small surfaces or volumes of material containing asbestos, tremolite, anthophyllite, or actinolite; and will be completed within one work day; and are not expected to expose bystanders to significant ' amounts of asbestos." (Id.) The proposal includes the following as illustrations of small-scale, shortduration operations: repair or removal of asbestos on pipes that is less than 21 linear feet (6.4 m); repair or removal of asbestos . panel that is less than 9 square feet (0.8 mJ); pipe valve repair or replacement of pipe valves containing asbestos gaskets or electrical . work that disturbs asbestos that is completed by one worker in less than four hours; removal of drywall which is completed for the facility within an eight-hour workday; renovation projects involving endcapping of pipes and tile removal that is completed in less than four hours; and installation of conduits that is completed within an eight-hour ; work shift. 290 Appendix H Definitions of S-S/SD 1992 NIBS 55 Fed. Reg. 29,751 (1990). 2. EPA Definitions A. AHERA The 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 abatement1 (2) Removal of asbestos-containing thermal insulation not to exceed amounts greater than those which can be contained in a single glove bag.5 (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 may not exceed amounts greater than those which can be contained in a single prefabricated minienclosure. 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 fobs 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 m) or three square feet (0.3 m1) of friable asbestos" or an emergency project. 40 C.F.R. 5 763.124. 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 (40 C.F.R. 763.91). Paragraph (0. 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 m1) 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 nonschcduled 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 removed or stripped during a calendar year of January 1 through December 31 exceeded: ' (1) At least 80 linear meters (260 linear feet) on pipes or at least 15 square meters (160 square feet) on other facility components, or (2) At least 1 cubic meter (35 cubic feet) off facility components where the length or area could not be measured previously. NESHAP also requires: (1) A thorough inspection of die affected facility, or part of the facility where the demolition or renovation operation win occur, for the presence of asbestos, inducting Category I and Category n nonfriable ACM. (See Appendix E for definitions). b. A local exhaust ventilation system designed and operated to capture the particulate asbestos material produced by the stripping and removal of the asbestos materials. c. A glovebag system is used. <L Leak-tight wrapping is used to . contain all RACM prior to dismantlement See 40 CFR 61.145 (c) (3) for specific details on these options. (4) A person trained in the NESHAP provirions on-rite during stripping, removal, or other handling or disturbance of ACM in a NESHAP regulated facility. (5) RACM handling, waste packaging and waste tracking requirements. (2) Written notification to die EPA prior to the start of operations regulated under NESHAP (40 CFR 61.145(b)). (3) Wetting RACM when it is stripped from a facility component while it " remains in place in the facility during the stripping operation. In renovation operations, wetting is not required if: (6) If the asbestos content of a material is determined by Polarized light Microscopy (using 40 CFR Part 763, Section 1. Appendix A. subpart F method) to be less than . 10 percent, verify the asbestos content by point counting using Polarized Light Microscopy. Alternatively, the material may be assumed to be, and treated as, ACM. a. Prior written approval isobtained from the EPA if wetting would unavoidably damage equipment or present a safety hazard.1 2 3 1. OSHA'i proposed reviaoo* to the cooctructioa aibeeto* Kaodard would require protection* io place reaardleta of rawed fiww levele. See 11>. ' 2. This requirement parallel* perefrapb e.l. of At OSHA oomplience directive.' 3. Thi* requiraiMot parallel* (be raeooBcadatioot of the EPA Craao Book ad the HEI Report oa eibeetoe, `Aibeeto* la Public and Commercial Buildin|*: A Literature Review and Synlhcde of Current Knowledge,* Health Eftecta Iaatituta - Aabcetoa Reaaarch 3-4S (1991). 292 Appendix H Definitions o( S-S/SD 01992 NIBS *>-* lav^rifarflrmi niiiiiftni^irtfuniMi^ Appendix I Regulations Note: This information is reproduced from 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), the National Institute of Building Sciences (NIBS), or EPA environmental assistance centers, for updated information on these requirements. OSHA Regulations 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 0 & 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 (17cc) of air based on an 8-hour TWA sampling period. This is the 293 Appendix I Regulations 1992 NIBS maximum level of airborne asbestos, on average, that any employee may be exposed to over an 8-hour period (normal work shift). 2. Excursion limit (EL) - 1.0 flee as averaged over a sampling period of 30 minutes. These levels trigger mandatory requirements, which include the use of respirators and protective clothing, the establishment of "regulated areas," the posting of danger signs as well as the use of engineering controls and specific work practices. OSHA regulations also establish an "Action Level": 0.1 flee for an 8-hour TWA. Employee training is required once the action of 0.1 flee and/or the "Excursion Limit" is reached. This training must include topics specified by the OSHA rules. If an employee is exposed at or above the action level of a period of 30 days or more in a calendar year, medical surveillance is required according to OSHA construction industry asbestos standard. OSHA also requires medical examinations under its "General Industry Standard" for any employee exposed to fiber levels in the air at or above the OSHA "action level" (0.1 flee) and/or the "excursion limit" (1.0 f/cc). In both cases the action level and excursion limit - the OSHA medical examination requirement applies if the exposure occurs for at least one day per year. The OSHA "Construction Industry Standard" (29 CFR 1926.58) for asbestos, is generally applicable for the workers who carry out the kinds of work discussed in this O & M guidance document. The OSHA construction industry asbestos standard applies to demolition and asbestos removal, enclosure or encapsulation projects, as well as to repair, maintenance, alteration, or renovation if ACM is involved. ACM spills or emergency clean-up actions are also covered by this regulation. According to these regulations, participation in a medical surveillance program is required for any employee who is required to wear a negative pressure, air-purifying respirator. Preplacement, annual, and termination physical exams are also required for these employees. However, a termination exam is only necessary under the construction industry standard (which applies to custodial and maintenance employees) if a physician recommends it While not mandatory, EPA and NIOSH recommend physical examinations, including cardiac and pulmonary tests, for any employee required to wear a respirator by the building owner. These tests determine whether workers will be unduly stressed or uncomfortable when using a respirator. Additional requirements of the OSHA asbestos standards, such as the use of air filtration systems and hygiene facilities, involve procedures which are most applicable to large-scale asbestos abatement projects. However, these rules also include a number of recommendations for procedures which might be appropriate for a variety of O&M programs for buildings. Small-scale Short-duration Projects (OSHA) Appendix G of OSHA regulation 29 CFR 1926.58, discusses work practices and engineering controls for small-scale, short-duration asbestos renovation and maintenance activities. The OSHA regulation requires negative pressure enclosure and full scale decontamination when asbestos is disturbed and either the OSHA Permissible Exposure Limit or Excursion Limit is exceeded or may 294 a Appendix! - 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 0X1X0 or (j)(2XD ((ull 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. Examples may 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 fullscale 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, mini enclosures, 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 (if 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 295 Appendix I - Regulations 1992 NIBS owner or manager; 2. Description and location of the building 3. Estimate of the approximate amount of friable ACM present in the facility; 4. Scheduled starting and completion dates of ACM removal; 5. Nature of planned demolition or renovation and method(s) to be used; 6. Procedures to be used to comply with the requirements of the regulation; and 7. Name, address, and location of the disposal site where the finable asbestos waste material will be deposited. The notification requirements do not apply if a building owner plans renovation projects which will disturb less than the NESHAP limits of 160 square feet (IS mJ) of friable ACM on facility components or 260 linear feet (80 m) of friable ACM on pipes (quantities involved over a one-year period). For renovation operations in which the amount of RACM equals or exceeds the NESHAP limits, notification is required as soon as possible. Emission* Control and Waste Disposal The NESHAP asbestos rule prohibits visible emissions to the outside air by requiring emission control procedures and appropriate work practices during collection, packaging, transportation or disposal of friable ACM waste. All RACM must be kept wet until sealed in a leak-tight container that includes the appropriate label. Note: The infonnation below is based on Department of Transportation (DOT) regulations and interpretations. DOT recently revised its hazardous material regulations (HMR; 49 CFR 171-180), and will amend it further as conditions warrant Packaging of ACM must meet general HMR requirements and be protective, marked and labeled, except as noted below; Small quantities; Samples over 1 ounce (30 grams) each are subject to the HMR. A "small quantity" shipment of samples is exempt from the HMR if the samples are each 1 ounce (30 grams) or less in cushioned, securely sealed and packed inner containers of plastic (at least 8 mil (0.2 mm) thick), glass, metal or earthenware. The entire, strong package must weigh 64 pounds (29 kg) or less, and be marked as required. Limited quantities: A "limited quantity" shipment is exempt from marking if it is 66 pounds (30 kg) or less with inner packagings up to 11 pounds (5 kg) each in the strong outer packaging. It is also exempt from labeling and placarding if it is not being shipped by air. Labeling; Packages must generally have a class 9 label, unless excepted. Marking: Packaging, except for limited quantities, must be marked with "RQ" (for waste), "waste" or the EPA hazardous waste marking (for waste), the shipping name, UN identification number, and, usually, the consignee or consignor's name and address. See below for details. Placards: Starting October 1, 1994, bulk packaging, freight containers, and transport vehicles must have "class 9" placards, except for "small quantity" and "limited quantity" shipments, and motor vehicle or freight container shipments less than 1001 pounds (454 kg). 296 Appendix I - Regulations 1992 NIBS [ : -. . i X I C& Shipping limitations: Shipping "blue" or "brown" asbestos (as defined below), other than "small quantity" shipments, is forbidden from aircraft or passenger-carrying railcars, and "white" asbestos is limited to 440 pound (200 kg) shipments by such modes. The HMR defines chrysotile, actinolite, anthophyllite and tremolite asbestos as "white asbestos," crocidolite asbestos as "blue asbestos," and amosite and mysorite asbestos as "brown asbestos." Vehicle marking: A vehicle transporting asbestos-containing waste must be marked with asbestos danger signs during loading and unloading of the waste. Waste shipment record: The record must be completed for each shipment of ACM waste. A copy signed by the transporter must be given to the building owner or operator (e.g., maintenance or abatement contractor) when the waste leaves the building site, and a copy signed by the disposal site must be received in 45 days. Exceptions: The HMR does not cover asbestos immersed or fixed in a binder material such as cement, plastic, asphalt, resins or mineral ore (e.g., nonfriable ACM that has not become crumbled, pulverized or reduced to powder), manufactured products containing 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 packaging specifications for Packaging Groups II and III. 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 MIXTURE (Shipping name; the DOT asbestos descriptions; listed in "shipping limitations," above) (For asbestos mixed with a binder or filler, etc.) (Class 9, Miscellaneous Hazardous Materials, includes asbestos) 297 Appendix I Regulations 1992 NIBS UN2590 (or UN2212, or UN2212), PG m (or It, or I). LTDQTY, (United Nations Identification numbers for the 3 DOT asbestos descriptions) (Packaging Groups for the 3 DOT asbestos descriptions; II and ni are medium and minor; use II if mixed shipment) (Limited quantity, if applicable) 20 OZ (Total quantity of material described; may abbreviate unit) When asbestos of two or more DOT descriptions ate mixed in a shipment, each is listed, for example, "RQ, Waste blue and white asbestos, 9. UN2212 and UN2590, PG n. Ltd Qty, 2 lbs." Where uncertainty exists in a particular situation, regulatory advice should be obtained. ' 298 Appendix I 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 chairman urged 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 the 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 Minority Opinion Subject Minority Opinion Subject Walter D. Anderson; Resilient Floor Covering Institute G. William Bain; Woodmont Managements, Inc. Cheryl J.R.Hershey; Armstrong World Industries, Inc. Sarah Hospodor; National Realty Committee Work Practice Levels (page 8) Objection The work practice levels do not provide meaningfol guidance to users of the Manual on how to comply with the OSHA asbestos standards. Rationale The levels are not based on the quantitative exposure criteria in the OSHA standards. Rather, 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 roofing/siding removal work practices, the assignment of work practice levels and their examples is based on little or no air monitoring data to determine OSHA compliance. As a result, the work practice levels generally do not fulfill their stated intent of assisting Manual users in complying with current OSHA asbestos regulations. Recommended Alternatives The Manual should be organized to include work practice levels clearly based on the OSHA asbestos standard. James August; American Federation of State, County and Municipal Employees Jim E. Lapping; The Building and Construction Trades Department, AfL-CIO Nora Leyland; Sherman, Dunn, Cohen, Leffer A YelUg John B. Moran and Bill Kojola; Laborers' Health & Safety Fund of North America Scott Schneider; Occupational Health Foundation OSHA permissible exposure limits (PELS) Objection When referencing the OSHA permissible exposure limits, the Manual fails to advise the reader that these limits do not eliminate significant risk to workers, but rather, were set at the limit of technological feasibility existing in 1986. Rationale OSHA stated clearly in the Preamble to the 1986 construction asbestos standard that (1) significant risk is not eliminated at the PEL of 0.20 f/cc, and (2) selection of that level as the PEL was based on evidence that the 0.20 f/cc limit is the lowest limit that can be achieved by the use of engineering controls and work practices. OSHA also found significant risk to workers at the action level of 0.10 f/cc, and the agency reiterated this finding in 1990, when it proposed lowering the PEL to 0.10 f/cc. Both findings have been upheld by the Federal court. The reader cannot make an informed decision about whether simply meeting the OSHA limits is sufficient, without having the above information as to the exact meaning of and basis for those limits. Recommended Alternative: Whenever the OSHA permissible exposure limits are referenced, the Manual should note that these were set at the level which was deemed technologically feasible in 1986, and that it is OSHA's and the Federal court's opinion that these levels do not eliminate significant risk to those exposed to asbestos. 300 Appendix J - Minority Opinions a 1992 NIBS ... r,-, ,, - tt |.^w^-,.--f....J.- ,M 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 fails 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 the 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. The 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 Book" (the companion 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 Rationale The definition of Level 1 involving potential exposure to asbestos 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 The minimum training recommended by the Manual is "Awareness" training which is intended to make building service representatives recognize activities that disturb, or may disturb ACM and therefore should be avoided. Awareness training does not instruct personnel how to actually perform tasks training for any task that disturbs, or may disturb ACM. The amount and content of the 0 & M training should correspond to the type of ACM to be encountered and should emphasize hands-on methods. Respiratory protection should be recommended for most situations that are now being classified as Level 1. that disturb, or may disturb ACM. 301 Appendix J - Minority Opinions 1992 NIBS ) Subject Subject Worker Genend Procedures; W14 page 47, W17 - page 50. Objection The Worker General Procedures do not address the minimum number of worlcers-needed. Rationale A second worker is . necessary to perform proper . decontamination. A second worker provides assistance with glovebag tasks and should be available to deal with emergency leaks. > ! The O & M Manual is inconsistent with the Model Guide Specifications published by NIBS. ! ; Recommended Alternatives Work practices referencing either W14 or W17 should recommend a minimum of; two workers. . ; : Inappropriate Level 1 work practices Cleaning asbestos-containing chips and Objection Level 1 is not appropriate for the following work practices; SI, 53. S4. S10. M2, M4, and M29. Level 1 may be inadequate for the following work practices: M6, M8, M9, and M10. dust generated during M4 constitutes a minor fiber release episode. AHERA ; requires that personnel performing ; cleanup of minor fiber release episodes (M29) have a minimum of 16 hours of i training and wear protective equipment.; The same level of precaution is ; Rationale When encountering an warranted in public and commercial ; unknown situation such as SI, S3, & ' buildings. 54, it is .prudent to assume a higher level of precaution until it is proven unnecessary. The SI summary clearly states that contamination of ACM dust and/or debris may be encountered: The OSHA construction standard requires that maintenance staff performing , small-scale, short-duration operations ' Studies have shown that floor cleaning ; and maintenance operations (M6 & M8) can produce significantly elevated , asbestos fiber levels. ! The conditions which the worker will ; encounter in M9 are hidden until the ! work actually begins. be instructed to wear respiratory Aside from visible suspect debris, there protection and clear, the area. r is no way for a custodian or Repairing damaged surfacing ACM (S10) is an intentional disturbance of maintenance person to know if a carpet! is contaminated (M10). ACM which most likely wilfbe friable. Recommended Alternatives Delete The worker will not know the condition of ACM backing until after work begins on M2. Respiratory and other protective measures are . necessary. ' / Level 1 for SI. S3. S4, S10, M2. M4. and M29. Work areas should be ; cleared for M6 & M8. M6.M8, M9, & M10 should begin at Level 2 and : only be downgraded when there is ; validation the Level 1 is appropriate. 302 Appendix J - Minority Opinions 1992 NIBS iA''.l 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 future, 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 Qearance 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 0 & M practices. Recommended Alternatives 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 0 & 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 1992 NIBS Subject Subject Subject regarding the meaning of dust sampling results in terms of health risk to the general public or to workers. Until agreement is reached on the significance of settled, dust' sampling,maintenance of such data serves no useful purpose to the building owner. It may be appropriate for research institutions to gather and maintain experimental data but it is unreasonable to expea. or imply, that building owners in a competitive environment should maintain records of questionable value. Recommended Alternatives Settled dust sampling is mentioned on page 11. All other references to and discussions of settled dust sampling should be deleted. SS - Attach item to ceiling finished with ACM (page 73) S7 Cut or drill hole in surfacing ACM (page 80) Objection Both work practices are excessive. Rationale The Manual includes a Level 1 for S6 which is similar work to S3 and S7 but neither has a Level 1 work practice. Data are available to demonstrate that minor objects can be attached while maintaining fiber counts wen below the OSHA Action Level.' Additional data demonstrated that track closet doors can be attached at Level 2 using wet methods and local HEPA vacuum control. Experienced workers can drill small holes using wet methods and local HEPA control at Level 1. Data validating this conclusion are available. Recommended Alternatives Include s Level 1 for S3 and S7. Downgrade Example C in S3 from Level 3 to Level 2. M10 - Clean potentially asbestoscontaminated carpet (page 178) Objection The work practice is excessive. Rationale It is not necessary to HEPA vacuum carpet without visible or analytical confirmation of the presence of ACM. This Level 1 procedure is in consistent with the logic of S9 & M34. Recommended Alternatives Delete Level 1; downgrade Level 2 to Level 1. Design of O & M program (pages 10 & 13) Objection Inappropriate statements are made to the effect that some building owners may choose to simply achieve regulatory compliance while others may establish programs with more precautionary criteria; and users of the Manual may have operations and maintenance program objectives more protective than the minimum regulatory requirements. Rationale The statements misstate the "desires of some building owners", they promote the "state of the art" myth, and provide no measurable standards in a constantly changing set of program parameters. Building owners and operators need measurable standards and clear guidelines to evaluate and execute O & M activities. Such statements imply that O & M programs striving to comply with recognizable applicable standards are less than adequate. Recommended Alternatives Delete the objectionable statements and state that other objectives regarding the building environment may also be considered. 304 Appendix J Minority Opinions 1992 NIBS Subject Subject Subject Health effects of asbestos Objection There is no mention of health effects of asbestos and how they might relate to risk assessment in the Manual. Rationale The purpose of the 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 conducted 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 Adda 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 or 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 inside the respirator is common practice, (page 21) Objection NIOSH does not have a "maximum permissible exposure limit" 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 Subject Minority Opinion Subject lengthy to add here. It would be more < useful to delete the sentence rather than. have inaccurate or potentially confusing statements. . Recommended Alternatives Strike the sentence or add a discussion about risk assessment that includes currently ; available information. M24 Cut or drill asbestos-containing . drywall, plaster or drywall compound (page 228) Objection No clear distinction is made between asbestos containing drywall and drywall that does not contain asbestos separate and apart from the drywall taping mud. There should be a allowance for Level 1 procedures where the drywall core does not contain asbestos. Rationale There is much less potential for fiber release where only the taping mud contains asbestos and the drywall core does not contain asbestos. Also, no data was presented demonstrating that wet methods and HEPA vacuums are not effective in controlling small amounts of ACM dust when removing small sections of drywall. There is no ! basis for not adding a Level 1 . procedure for removing small sections of drywall, especially where the'ACM ; is limited to joint compound and ACM is not contained in the core of the drywall Recommended Alternatives Change the Level 2C example to Level 1. Make a clear distinction between asbestos containing drywall and drywall that : does not contain asbestos in its core. . James Fite; White Lung Association Potential health effects information and training (page 12) , Objection The absence of information on health risk and hazards for ! maintenance and custodial personnel who will be performing these work practices. Rationale workers should be given : clear warning of the health risks which have been linked to working on asbestos-containing materials. The adverse health effects related to , asbestos exposure have been discussed in medical literature for well over five decades. Asbestosis, mesothelioma, and lung, stomach, throat and other cancers have all been associated with asbestos exposures. The so-called "third-wave" epidemiological studies prove that custodial and maintenance workers are at significantly higher risk than the general population, unless they are adequately protected. The U.S. government requires that asbestos-handling workers in schools : be taught that there is no known safe level of asbestos exposure. Workers using this Manual must understand that: asbestos of all types is hazardous and dangerous and that failure to adhere to 1 the work practices will be harmful to themselves and others. Worker training should identify and explain the potential health risks to all maintenance and custodial workers who may be exposed to asbestos fibers by disturbing asbestos containing building materials. 306 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 by 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 Leytand; Sherman, Dunn, Cohen, Leifer & Yellig John B. Moran and BiU 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. 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. Recommended Alternative In addition to confined spaces and situations in which 307 Appendix J - Minority Opinions 1992 NIBS Subject Subject Definition of Level 1, and Scope of , The second major problem is that many Level 1 in Specific Work Practices for of the Level 1 work practices call for Friable Materials Level. 1 workers to package and label Objection Level 1 should.not include , asbestos waste and/or clean tools, activities involving the intentional equipment and work areas by wet disturbance of friable materials. , wiping or HEPA vacuuming. The OSHA standard requires training, ; Rationale The fact that the current defini respiratory protection, protective tion of Level One, as well as the Scope' clothing, engineering controls, and a . of Operations for many Level 1 tasks,' vacated area for these activities. Again; permits the accidental or intentional - ' -:i this Manual requires none of these : disturbance of friable asbestos, is at odds protections for Level 1 activities. j with the lack of training and protections afforded Level 1 Workers, as well as Recommended Alternatives First. Level bystanders on Level 1 jobs. Such 1 activities should be restricted to work training and protections are mandated by practices "intended to avoid a the OSHA construction asbestos standard disturbance of ACM and release of for jobs such as these where a full scale asbesms fibers," consistent with the negative pressure enclosure and foil scale EPA Green Book. Second, Level 1 decontamination are not used. procedures in the work practices listed below should be performed as Level 2 The first major problem with many of procedures. these work practices is that the worker ? cannot know in advance whether he or Alternatively, Level 1 protections must' she will be exposed to asbestos. For include: (1) O&M training for Level 1: example, work practice SI permits a workers; (2) respirators and personal j worker to lift a ceiling tile below a - protective equipment for Level 1 plenum space that has exposed surfacing workers; (3) notification of personnel 1 ACM. Because the worker has no way that Level 1 asbestos work will be of knowing whether the ACM has performed in the area; and (4) vacating deteriorated and is lying on top of the the area in which Level 1 work will be panel to be moved, the worker cannot \ performed. , know in advance, whether asbestos will In addition to SI, other Level 1 work ; be disturbed in this process. practices which permit the possibility of The OSHA construction asbestos ; intentional disturbance of asbestos with standard mandates that the worker may no protection to the worker, and to not engage in this activity without which this recommendation Should 1 wearing the proper respiratory protection, apply include: S3, S4, S6, S8, S10, S12, clearing the area of other people, and . M10, M22 (Note: Level 1 should not be observing asbestos removal waste performed on damaged roofing. ; disposal procedures. The Manual, ! Damage of this material usually connote however, requires none of these . friability), M29,.and M34. j protections. ' - Scope of Work Practices For Non-Friable by the work practice. In these Materials ' situations, the work practice should not Objection It is difficuit to predict in advance whether some non-friable begin as a Level 1 procedure, with no; protections in place. materials will actually be rendered friable 306 Appendix J Minority Opinions 1992 NIBS j 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 the inherent backing separates from the wear layer, difficultly in predicting, before a job this operation should absolutely not be begins, whether or the operation will downgraded to a Level One: tie 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. operation should be Level 2 until it is Recommended Alternative Our recommendation, therefore, would be to have these jobs begin as Level 2 established that the carpet is not adhered to resilient asbestos flooring), Ml 1, Ml3, M26, M27, M30. operations, which can be downgraded to Level 1 (respirators removed, etc.), after the work has commenced and it has been Explicit 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 Q, 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 Appendix J Minority Opinions 1992 NIBS Subject Minority Opinion Subject Minority Opinion Subject Maintaining Asbestos in Place versus vigilance as the asbestos eventually Removal of, Asbestos. deteriorates. The appropriate resources Objection The Manual fails to discuss the must 1* committed to the proper relative burdens of maintaining asbestos management of the asbestos and proper in place versus simply removing the ;r protection of those workers who must, deal with the in-place materials. Rationale One of the major arguments ,, against asbestos abatement has been that asbestos can be managed in place with , less risk to workers and the environment than may be caused by abatement Managing asbestos in place entails a good deal of cost, attention to detail, and Recommended Alternatives The Manual should recommend that owners evaluate whether removal by an experienced, j reliable contractor would be less ; burdensome than the cost, time and vigilance required of those owners who chose to manage asbestos in place and who do so properly. Marilyn F. Mueller; Supradur Manufacturing Corporation Work Practice Levels (Page 8) intended to assist in meeting the > Objection The Manual's work practice current OSHA regulations applicable to levels do hot conform at all with the Q&M work. As currently written, OSHA regulations governing worker ' there 'is no correlation between OSHA exposure to asbestos. As written, there regulations and die Manual's work { is no measurable criterion upon which practice levels; therefore, this Manual to base a decision concerning die is not meeting its own stated choice of work practice levels; : objectives. therefore, subjective interpretation is Recommended Alternatives Revise the necessary and this will likely ' Manual to set forth work practice exacerbate the confusion already ; levels and guidelines which include existing in the field. and correspond to the baseline standard Rationale One of the Manual's stated for asbestos exposure to workers as : objectives is that the work practices are promulgated in the OSHA regulations. B. J. Pigg; Asbestos Information Association/North America Definition of Work Practice Levels, , (Page 8) Objection The definitions of work practices, which are key to implementation of the Manual's procedures, have no relation ; whatsoever to OSHA asbestos standards. The definitions are completely subjective and left to the interpretation of the user of the Manual. They provide no baseline or standard for implementation of the ' genera] procedures set forth. ; 310 Appendix j Minority Opinions 1992 NIBS 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 a&estos-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 useful so that building owners and asbestos program managers can know the legal baseline before they choose to consider more than just the OSHA regulated exposure levels. ; In the work practice levels shown in Figure 1 (page 9) the Manual does not clearly inform users of what is currently allowed and required by OSHA's asbestos construction standard. The Manual does not use federal regulatory requirements as one of the essential elements of developing an O&M program. ' The Manual recommends work ' ' practices that greatly exceed OSHA. regulatory requirements. The Manual sets forth time work practice levels keyed to "fiber release potential." For all but Level 1 operations, the work practices are comparable to those required for large-scale, long-duration asbestos abatement projects. Many activities involving certain types of ACM, such as surfacing materials, and all activities involving thermal system insulation, are never assigned Level 1, and are precluded from the less rigorous standards of that level. The proliferation of "yeses" indicated for work practices for Levels 2 and 3 in Figure 1 (setting forth the work . practices required for various operation levels) demonstrates how burdensome and unrelated the Manual is to the OSHA standards. Recommended Alternatives Add two OSHA-based work practice levels to complement the existing three levels in the Manual. This five level approach would be more useful because it sets forth: (1) work practices required by law; and (2) recommended work practices that could be applied in particular situations regardless of exposure level. The proposed additional levels are defined as follows: OSHA Level 1: Work practice is not expected, given protective measures in place and according to exposure monitoring or objective data, to expose any employee to an airborne concentration of asbestos fibers in : excess of 0.2 fiber per cubic centimeter of air as an 8-hour time-weighted average as determined by methods : prescribed by OSHA. OSHA Level 2: Work practice is expected, despite protective measures in place and according to exposure monitoring, to expose an employee to an airborne concentration of asbestos fibers in excess of 0.2 fiber per cubic centimeter of air as an 8-hour timeweighted average as determined by methods prescribed by OSHA. The following table summarizes the engineering controls and practices recommended for this alternative. These would be the two additional levels of the five level approach. , { Safe Buildings Alliance's Alternative: Guidelines For Levels of Work Practices ITEM OSHA LEVEL 1 OSHA LEVEL 2 Fiber Release Potential Less than 0.2 f/cc More than 0.2 f/cc Training (APM5) As instructed for work practice O&M HVAC System Off (W3) No No Vacate Area (W4) No No Critical Barriers (W4) No If Feasible 312 Appendix J Minority Opinions 1992 NIBS JL 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 Optional No Yes No No No 313 Appendix J - Minority Opinions 1992 NIBS Minority Opinion Authors & Organizations Walter D. Anderson Resilient Floor Covering Institute 966 ,,Hunger,ford. _Dn.ve Rockville, MD 20850 301/340-8580 James August American Federation of State, County & Municipal Employees, AFL-CIO ' 1625 L Street, NW Washington. DC 20036 202/429-1215 G. William Bain Woodmont Managements, Inc. _. . 1050 Ralston Avenue Belmont, CA 94002 415/592-3960 James Fite White Lung Association P. O. Box 1483 Baltimore, MD 21203-1483 410/243-5864 Cheryl J. R. Hershey Armstrong World Industries, Inc. P. O. Box 3511 Lancaster, PA 17604 717/396-5507 Sarah E. Hospodor National Realty Committee 1250 Connecticut Ave., NW, Suite 630 Washington, DC 20036 202/785-0808 The Resilient Floor Covering Institute (RFCI) is a national trade association the members of which are manufacturers of vinyl tile and sheet vinyl. 1* , 1! ! The American Federation of State, County and Municipal Employees (AFSCME) is a labor union of more than 1.2 million members. AFSCME represents employees of state and local governments, school districts, public and private i hospitals, universities and non-profit agencies who . work in a cross section ofjobs ranging from blue collar to clerical, professional and paraprofessional. Woodmorit Managements, Inc. provides property management services for multi-family apartments and commercial buildings. . . The White Lung Association is a national, non profit association which represents former asbestos workers and other persons with asbestos-related health problems and legal claims. Armstrong World Industries, Inc. is a manufacturer ; of interior furnishings, including interior furnishings, including resilient floorcovering, ; acoustical ceilings, ceramic tile, and furniture, headquartered in Lancaster, PA. National Realty Committee serves as a roundtable in Washington for public policy issues vital to real estate. NRC members are real estate owners, advisors, builders, investors, lenders, and managers. 1 314 Appendix J Minority Opinions 1992 NIBS .L-.` -?>- - ---f John B. Moran and Bill Kojola Laborers' Health and Safety Fund of North America 905 16lh 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 tlic 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, AJT.-CIO. Marilyn F. 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 riding shingles. The 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 16lh 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 John F. Welch Safe Buildings Alliance 655 15th Street. NW. Suite 1200 Washington, DC 20005 202/879-5120 Founded in 1984 to promote a scientific approach to the issues of asbestos in buildings, the Safe Buildings Alliance is an association of companies which formerly manufactured asbestos-containing materials. 316 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 III IV V VI VII Work Practice (if applicable):Level: 1 2 3 Comment/recommendation: Supporting data or information:. 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 1Steering Committee Members Chairman: 1 William H. Hoffman, QuestCo, Inc. Vice-Chairman: * Richard P. Peduto, The Port Authority of NY & NJ Secretary: s Roger G. Morse, A1A, Entek Environmental & Technical Services, Inc. Vicki Ainslie - Georgia Tech Research Institute/Environ. Science & Tech. _ Peter F. Allard P.E., CIH Scott, Allard & Bohannan, Inc. Walter D. Anderson - Resilient Floor Covering Institute Charles L. Anderson, P.E. - SSM/Spotts, Stevens & McCoy, Inc. Robert Angione Asbestos Disposal Agency, Inc. Bruce Atlas - NYC DepLof 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, PH. - Management International Walter F. Brian - Armstrong World Industries, Inc. Joseph R. Bridgewater, P.E. - Bridgewater & Associates * James O. 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 5 Zachary S. Cowan, III - 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. 5 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 Project Committee 1992 NIBS Joseph D. Green, CIH, CSP - Occupational Health and Hygiene Corporation of America Philip Hagan - George Washington University Medical Center Jack L. Halliwell, P.E. Halliwell Engineering Associates, Inc. Gary L. Hamper - Pott of Seattle Olaf H. Hansen - The Hahn Company * Richard L. Hatfield - Law Associates, Inc. Paul Heffeman - Paul Heffeman Consulting 5 Cheryl J. R. Hershey - Armstrong World Industries, Inc. Richard W. Holmes EnviroSafe Corp. Sarah E Hospodor - National Realty Committee Craig F. Hull, AICP - Engineering Management Corporation James A. Hutchison, in, P.E. - JAED Corporation Henry G. Irwig - Beacon Construction Company Wade Jensen Naval Facilities Engineering Command Cheryl L. Johnson - West Virginia Univ. Inst for Safety & Health Training Norbert W. Kaleta - Gold Bond Building Products Tim Kelleher - Hygienetics, Inc. Marvin Kennebeck - American Welding Society Homer Charles Knox, III Susquenita, PA - School District Bill Kojola - Laborers' Health and Safety Fund of North America John P. Kungis - Directorate of Engineering and Housing, U.S. Army Garrison *J. Brent Kynoch Asbestos Abatement Services, Inc. Mr. Lynn L. Lammer - Midwest Asbestos Consultants, Inc. Jim E. Lapping AFL-CIO/Building & Construction Trades Department Nora H. Leyland - Sherman, Dunn, Cohen, Leifer & Yellig Lance L. Luke - Lance L. Luke & Associates, Inc. J. Robert Matthews, P.E. - Bellcore Timothy J. McCormick - Michigan State University Physical Plant Maintenance Michael McGuinness, CIH RK Occupational & Environmental Analysis, Inc. Cullen B. McWhite, III - Anderson, S.C. - School Districts 2,3,4,5 Marilyn F. Mueller - Supradur Manufacturing Corporation Thomas S. Norman Stewart Environmental Consultants, Inc. Lester A. Obst John S. McQuade Company Kyle E. Parker, P.E. - Volkert Environmental Group, Inc. B. J. Pigg Asbestos Information Association/North America Rita D. Pittillo Department of Veterans Affairs Chris A. Purvis Northeastern Analytical Corporation (NAC) Robert D. Rader - Dorchester County, MD - Board of Education Robert J. Repas - Harck, Inc. Robert E. Robb, Jr. - Environmental Training Center of Southern Ohio & Kentucky Nancy Roisum - Arlington County, VA - Government David M. Rook - Cook County, IL - Dept of Construction, Maint. & Opers. Gordon L. Rosby, AIA - AEC, Inc. Environmental Consultants Robert D. Schmitter - Georgia Tech Research Institute/Environ. Science & Tech. 1 Scott Schneider, CIH - Occupational Health Foundation 320 Project Committee 1992 NIBS Kenneth M. Sedor Real Estate Support Services, Inc. 5 James 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 * William A. lippin, 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 Consulting Engineers, Inc. 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 CONSULTATIVE COUNCIL Chairman: Hugh C. MacDonald, MacDonald Masonry Consultants, Falls Church, VA Vice Chairman: Joseph O'Neil, American Council of Independent Laboratories, Washington, DC Secretary: Noel J. Raufaste, Jr., National Institute of Standards and Technology, Gaithersburg, MD Erv Bales, Ph.D., Building Engineering Architecture Research Center, New Jersey Institute of Technology, NewarkJW James Beyreis, P.E., Underwriters Laboratories, Inc., Northbrook, DL Francis W. Biehl, P.E., Bichl Engineering, Inc., Menomonee Falls, WI James DiLuigi, AIA, Universal Designers and Consultants, Silver Spring, MD G. Day Ding, School of Architecture & Environmental Design, California Polytechnic Institute, San Luis Obispo, CA Earl L. Flanagan, Alexandria, VA John C. Gerard, National Fire Protection Association, Alexandria, VA Whayne H. Haffler, AIA, Washington, DC Steve M. Hays, P.E., CIH, Gobbell Hays Partners, Inc, Nashville, TN Arlie Heald, International Brotherhood of Electrical Workers, Washington, DC Ward C. Hitchings, National Forest Products Association, Washington, DC William Hoffman, Quest Co., Inc., Bethesda, MD Donald M. Holmes, P.E., Clapp & Holmes Consulting Engineers, Harrisburg, PA William R. Lawson, AIA, HTB, Inc., Washington, DC Ted S. Lundy, Tennessee Technical University, Center for Manufacturing, Cooksville, TN Henry J. Mader, HJ. Mader & Associates, Pittsburgh, PA Kenneth D. Mentzer, Mineral Insulation Manufacturing Association, Alexandria, VA Lester A. Obst, John S. McQuade Company, Philadelphia, PA Thomas R. Rutherford, P.E., Directorate of Engineering and Construction, Office of Secretary of Defense Falls Church, VA Kenneth M. Sedor, Real Estate Support Services, Inc., Minneapolis, MN Lloyd H. Siegel, FAIA, Office of Architecture & Engineering, Department of Veterans Affairs, Washington, DC John H. Slayter, Newberry Building Systems Corp., Newbeny, MI Robert W. Spangler, Council of American Building Officials, Falls Church, VA William Tangye, Southern Building Code Congress International, Inc., Birmingham, AL James A. Thomas, ASTM, Philadelphia, PA William A. Ttppin, IV, EnviroControl, Inc,, Alexandria, VA Jon S. Traw, P.E., Inti. Conference of Building Officials, Whittier, CA Frank Walter, Manufactured Housing Institute, Arlington, VA Leroy E. Worley, Inti. Association of Bridge, Structural & Ornamental Ironworkers, Washington, DC H. Glenn Ziegenfuss, Ph.D., American Welding Society, Miami, FL Joel P. Zingeser, AIA, Building Technology, Inc., Silver Spring, MD BOARD OF DIRECTORS Chairman: Robert C. Gibson, P.E., President & CEO, Clark, Nexsen, Owen, Barbieri & Gibson, P.C., Norfolk, VA Vice-Chairman: John C. CanestTO, 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 Bruce E. Vogelsinger, P.E., 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, HI, 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 M National Institute of BUILDING SCIENCES pr 1201 L Street, NW, Suite 400 Washington, DC 20005 Dear Customer As a purchaser of Guidance Manual: Asbestos Operations & Maintenance Work Practices, wc are offering you S30 off the regular membership fee when you join the National Institute of Building Sciences. The reomunendations 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 the efforts of the 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 the introduction of technology, and facilitate the development and dissemination of pertinent construction criteria and standards. The Institute, a non-government, non-profit organization authorized by an act of Congress in 1974, is the only organization of its kind designed to bring together members of all segments of the nation's building and bousing communities to address conflicts and problems and to develop workable solutions. In addition to this publication, NIBS publishes the Asbestos Abatement and Management In Buildings, Model Guide Speciflcations along with a wide range of 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 of design criteria and industry information), an annual report, a calendar of building community events, seminars and more-----These activities are designed to enhance the flow of information on regulatory and technical issues and design criteria. Simply complete the membership application on the back of this letter and return the application with you payment to the above address. We will acknowledge your membership and send you more NIBS infonnation without delay. Sincerely, NATIONAL INSTITUTE OF BUILDING SCIENCES ALSO AVAILABLE FROM NIBS ASBESTOS ABATEMENT AND MANAGEMENT IN BUILDINGS, MODEL GUIDE SPECIFICATIONS, SECOND EDITION Member Price: SI 15 Non-Member Price: S145 This guide offers authoritative advice and guidance in the design and execution of abatement of asbestoscontaining materials (ACM). It was revised in 1988 to include the 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 of the 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 5 1/4" floppy diskettes for use on MS-DOS or PCDOS based micro-computers in 6 formats (sold below). Please note, the diskettes can not be purchased separately. [485 Pages/1988] Model Guide Specifications Mb 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. national compilation oftechnical protocols, practices, and procedures on testing,abatement, workerprotection, clean up, and disposal of LBP in residential structures. The Interim Guidelines, previously published in the April 18, 1990edition ofthe Federal Register, are offeredhere in the 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 to reducing radonlevelsinnewoneandtwo-family dwellings andother residential structures three stories or less in height. Guidelines are provided on such techniques as sub-slab depressurization, sealing of foundations, and reducing stackeffect DevelopedbyNIBS' RadonProjectCommittee underacooperativeagreementwith the U.S.Environmental Protection Agency (EPA), these guidelines are based largely onradonmitigation experiencesinsingle-familyresidences anda small number ofschoolsand non-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 PUBUC AND INDIAN HOUSING Member Price: $45 Non-Member Price: $55 The original draft for these guidelines was prepared by NIBS'Lead Based PaintProjectCommitteeofdistinguished experts in the field of lead-based paint (LBP) under a contract with the U.S. Department of Housing and Urban Development (HUD). This document represents the first This unique publication was designed tohelp dieconstruc tion industry comply with new federal metricprocurement requirements. By September 30, 1992 agencies of the federal government are required to use the metric system ofmeasurement, to the extent feasible, in all procurement, grants, and business-related activities. The Metric Guide was created by NIBS under the direction of public and privatemembers oftheInteragencyConstruction 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] I rf i 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. See available formats below. Don't waste another minute ... Order your diskette version of Guidance Manual, Asbestos Operations & Maintenance Work Practices for only $75 ORDER FORM Please send me Guidance Manual, Asbestos O&M Work Practices on Computer Diskettes. Available formats: (check one) [ ] WordPerfect [ ] WordStar [ ] MicroSoft Word [ ] Multimate [ ] Displaywrite [ ] ASCII format on [] 3 1/2" or [] 5 1/4" diskettes. SHIP DISKETTES TO: NameTide FirmTelephone ( ) Street Address. City/State/ZIpcode Diskettes are not sold without the purchase of a hardcopy. Original order form must be used to obtain diskettes. Payment enclosed in the amount of $75 for each set of diskettes. No. of sett ordered: Q Please charge my order to: [ ] MasterCard [] Visa [ ] American Express Account No.Exp. Date Name as it appears on card SignatureDate Make check payable to N.I.B.S. and mail completed form to: National Institute of Building Sciences, 1201 L Street, NW, Suite 400, Washington, DC 20005, Phone: 202-289-7800, Fax: 202-289-1092 VI. Miscellaneous Materials Work Practices nwt!;------'linurninr---------- nrnnr.T-%^^3-.^-^ -----------------------------------------------------------,: . I-' - ---......................... Figure 9: Miscellaneous Materials Location Illustration 142 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIRS A 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......... 132 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 floor 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 1 2 Remove and replace asbestos cement siding.................. 205 M19 12 3 Remove high-temperature resistant (HTR) asbestos cement panels............................................................208 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-containingdrywall...........................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 with exposed ACM............................... 243 M29 1 2 Clean up debris from minor Gber 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 The following general notes should be reviewed by users of die miscellaneous ACM work practices: 1. Resilient floor tile and vinyl sheet are based on work practices developed by the resilient floor covering manufacturers (RFCM) for the removal of asbestos and non asbestos-containing resilient flow covering materials. Work practice levels that incorporate the RFCM practices are noted as (RFCM Proetdurts). In accordance with terminology used by the RFCM, the term "vinyl" is used only to refer to sheet flooring. The term "resilient" is used to refer to both floor tile and sheet flowing, since many tile products contain resilient binder materials other than vinyL The RFCM have submitted to OSHA airborne exposure data on removal of resilient flow tile, asphaltic cutback materials, and sheet vinyl flooring. OSHA has stated that it will accept the RFCM data for consideration as historical data to support a claim for an exemption from die need to conduct initial air monitoring under the OSHA regulation 29 CFR 1926.58(0(2X0. Historical data exemptions notwithstanding, if applicable OSHA exposure limits are exceeded other provisions and requirements of the OSHA asbestos regulation remain in full force and effect. In considering the initial air monitoring exemption claim, the local OSHA compliance officer determines whether the recommended wwk practices are being strictly followed, the work conditions at the job site are similar to those in the study, and OSHA's field data (if any) are below OSHA's action level and excursion limit Resilient flow covering is classified by the EPA NESHAP as Category 1 non-friable ACM. If Category 1 ACM has become friable, w will become friable, w has been subjected to sanding, grinding, cutting w abrading, it is defined as Regulated ACM by NESHAP. The user should consider the use of Levels 2 w 3 to perform O&M activities under such conditions. Information in the NIBS Asbestos Abatement Guide Specifications sections 02085 and 02087 discusses the removal of resilient flow covering. , 2. Careful work practices should be the primary means used to prevent releases of asbestos fibers during O&M work. Such practices include control measures such as wetting and local exhaust that control w collect fibers at the source. The goal of all asbestos O&M work should be to prevent any exposure of the worker and unnecessary contamination of the work area, drop cloths, mini enclosures and other secondary control devices. Mini-enclosures should never be used to excuse sloppy work or creation of "bigger" messes. 144 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS 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 the possibility of a chemical reaction that could be caused by water, surfactants and/or other substances mixing with chemical residues during O&M vrorfc , 145 Miscellaneous ACM Asbestos O&M Work Practices 01992 NIBS Ml Summary Replacement of resilient asbestos floor tiles Summary This work practice covers the O&M procedures for removing small amounts of asbestos-containing floor tile and/or mastic. The Level 1 work practice is based on the RFCM procedures. Examples Level 1: A. Replacement of several floor dies 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 tfle and/or mastic that is not likely to become friable. Level 2l A. Replacement of an area of dies that are sufficiently damaged that the die and/or mastic will become friable during removal. Level 3: A. Remove die and mastic with an aggressive mechanical method which renders it friable. Related Work Practices M3 Penetrate flooring covered with ACM. Worker One worker for Level 1 work. One or two workers for Level 2 depending upon Recommendations sa^cty "d efficiency considerations. Two workers for Level 3. A person with air monitoring training might be required. This person can be a worker. 146 Miscellaneous ACM Asbestos O&M Work Practices 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 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 1431 if HEPA vacuum needs maintenance, or ifbag orfilter needs to be replaced. Warning: Do not sandflooring or backing. Work Practice \ 1. Perform Pre-work activities on Level 1 checklist. 2. Additional tools, equipment and materials: (sec General Procedure Wl for standard tools, equipment and materials list). Weighted scraper with long handle Wall scraper 2-3" (30-73 mm) wide stiff blade w/short handle Commercial-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 3B) - approximately 1 lb (0.5 kg) per sq.ft (0.1 m1) 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 SB. 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 01992 NIBS Ml Level 1-.eontlnu*d handle with a hammer using blows of moderate force while maintaining the scraper at 25 to 30 degree angle to the floor. If you encounter areas where even the above methods will not remove the tile, the removal procedure can be simplified by thoroughly heating the tiles with a hot-air blower or a radiant heat source until die 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. B. Dry ice tile removal procedures: Caution: The use of dry ice produces carbon dioxide that can result in an oxygen deficiency in the work area. Dry ice can also causefrostbite to workers and damage building materials. Spread crushed dry ice over tiles to be removed. Let dry ice freeze mastic and release die. Use short-handled scraper to pry up dies. 7. When the die is removed, place it, without breaking it, in disposal bags or containers which will be used for disposal. Removed tiles can be placed in empty tile cartons first and then placed in the disposal bags. To prevent tearing of the bag, place a maximum of one fun carton of removed die in a bag. 8. If new resilient floor tile is to be installed over a concrete subfloor using an asphaltic adhesive, die residual asphaltic "cutback" adhesive (mastic) must be left so that no ridges or puddles are evident and what remains is a thin, smooth film. This can be accomplished by wet-scraping the residual adhesive as follows: A. Start by adequately wetting the area where tilefs) were removed using amended water. Wet-scrape with a stiff-bladed wall or floor scraper, removing ridges and any loose adhesive. B. Place loosened adhesive residues into disposal bags or other containers. C. Wet vacuum standing water with the HEPA vacuum cleaner. D. Continue steps A through C until what remains of the residual asphaltic "cutback" adhesive is a thin, smooth film. 9. Clean the affected floor area with the HEPA vacuum cleaner using the metal floor tool to remove debris before applying new asphaltic adhesive or installing new resilient floor tile. 10. Perform required clean-up and tear-down steps on Level 1 checklist to complete work. 148 a Miscellaneous ACM a Asbestos O&M Work Practices a 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 Lend 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. ' Work Practice Use caution to prevent afire in the work area if heat sources are used.1 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 barrier tape. See General Procedure W4. A plastic drop doth 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 force 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 0&M Work Practices 01992 NIBS Ml Level 2~contln(d 7. When the tile is removed, place it, without breaking it, in disposal bags or containers which will be used to disposal. Removed tiles can be placed in empty tile cartons first and then placed in the disposal bags. To prevent tearing of the bag, place a maximum of one full carton of removed tile in a bag. 8. If new resilient floor tile is to be installed over a concrete subfloor using an asphaltic adhesive, the residual asphaltic "cutback" adhesive must be left so that no ridges or puddles are evident and what remains is a thin, smooth film. This can be accomplished by wet-scraping the residual adhesive as follows: A. Start in the removal area farthest from the entrance door and adequately wet an area approximately 3' x 10' (lm x 3m) with amended water to aid in wetting fire adhesive. Wet-scrape with a stiff-bladed wall or floor scraper removing ridges and any loose adhesive. B. Place loosened adhesive residues into disposal bags or other impermeable containers. C. Wet vacuum standing water with the HEPA vacuum cleaner. D. Continue steps A through C until what remains of the residual asphaltic "cutback" adhesive is a thin, smooth film. 9. Clean the affected floor with the HEPA vacuum cleaner using the metal floor tool to remove debris, followed by wet wiping, before applying new asphaltic adhesive or installing new resilient floor tile. 10. Install new floor tile and perform required clean-up and tear-down steps on Level 2 checklist to complete work. 150 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 WJ, W9 and a betel 3 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 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). 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. 151 Miscellaneous ACM a Asbestos O&M Work Practices 01992 NIBS p M2 Summary Replacement off vinyl sheet flooring with ACM backing Summary this work practice covers the O&M procedures for the replacement of small amounts of vinyl sheet flooring with ACM backing. Wet scraping of residual felt is included in ail three Levels. Examples Level 1: A. Replacement of loose or perimeter-adhered vinyl sheet flooring with ACM ; backing. - 1 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. Level 2: A. Replacement of vinyl sheet flooring with ACM backing which is sufficiently damaged to be friable. / Level 3: A. Removal of vinyl sheet flooring with ACM backing using an'aggressive u mechanical method which renders the material friable. Related Work Practices Ml Replacement of resilient asbestos floor tiles. x V4 Install new resilient flooring or carpet over resilient asbestos flooring. M9 Remove carpet over resilient asbestos flooring. Worker Two workers. A person with air monitoring training might be required. This Recommendations person can be a worker. i< !' \ 152 Miscellaneous ACM Asbestos O&M .Work Practices n 01992 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 to be replaced.1 2 3 4 Work Practice 1. Perform Pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 far 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 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 the felt). The sliced strip should be rolled around a core which will control the stripping angle to create a uniform tension. Tie or tape the removed material securely and place in disposal bags or containers for disposal. 153 Miscellaneous ACM Asbestos O&M Work Practices 01992 NIBS M2 Level l-continuad E. Remove and dispose of each snip in die above manner. Avoid walking on the,exposed felt as much*s possible. F. Occasionally, paits of the flooring will stick to the subfloor. Ibis can often be eliminated by peeling in die opposite direction. The stiff-bladed scraper may aid in die removal or peeling of the flooring. If any residual felt backing remains on the subfloor, remove it using wet scraping methods set forth in step 6G. , G. Wet-scraping residual felt: 1. Adequately wet the residual felt with amended water. Wait for a few minutes to allow the amended water to soak into the felt 2. Use die stiff-bladed scraper to scrape up die wet felt 3. Rewet the felt if the amended water has not completely penetrated, if drying occurs, or if dry felt is exposed during scraping. Pick up the scrapings as they are removed from the floor and place in disposal bags or containers. Wet-scrape felt from affected floor area. 4. When this floor area has been cleaned free of felt vacuum up any dirt . using the HEPA vacuum cleaner with the metal floor tool. Position the vacuum cleaner so that the discharge air does not blow on die area being cleaned. , 5. If HEPA vacuum filter or bag needs to be changed, use work practice . M31. .. - i 6. Allow substrate to dry before installing new flooring. 5. Perform required clean up and tear-down steps on Level 1 checklist to complete work. ; 6154 Miscellaneous ACM Asbestos O&M Work Practices n 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 friable. 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. Warning: Do not sandflooring or backing.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). 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: 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. 0. 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 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 flow (do not stand on thefelt). 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. E. Remove and dispose of each strip in the above manner. Avoid walking on the exposed felt as much as possible. F. Occasionally, parts of the flooring will stick to the subfloor. This can often be eliminated by peeling in the opposite direction The stiff-bladed scraper may aid in the removal or peeling of the flooring. If any residual felt backing remains on the subfloor, remove it in accordance with step 6G. 155 Miscellaneous ACM Asbestos 0&M Work Practices 01992 NIBS M2 Level 2~contiMMd G. Wet-scraping residual felt: 1. Adequately wet the residual felt with amended water. Wait for a few minutes to allow the amended water to soak into the felt 2. Stand on the remaining floor covering (not the felt) and use the stiff- bladed scraper to scrape up the wet felt 3. Rewet the felt if die amended water has not completely penetrated, if drying occurs, or if dry felt is exposed during scraping. Pick up the scrapings as they are removed from the floor and place in disposal bags or containers. Wet-scrape felt from affected floor area before proceeding further. 4. When floor area has been Cleaned free of felt, vacuum up any dirt using the HEPA vacuum cleaner with die metal floor tool. Position the vacuum cleaner so that the discharge air does not blow on the area being cleaned. 5. If HEPA vacuum filter or bag needs to be changed, use work practice W31. 6. Allow substrate to dry before installing new flooring. 6. Perform requited dean up and tear-down steps on Level 2 checklist to complete work. . 156 a Miscellaneous ACM a Asbestos O&M Work Practices a 01992 NIBS 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 Work Practice 771tis work practice must be used in conjunction with General Procedures Wi, W9 and a herd 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 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (Set 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. 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. - 5. Enter enclosure and remove flooring per procedures under step 6. 6. Removal Procedure, 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 8" (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) the 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). He or tape the removed material securely and place in disposal bags or containers for disposal. E. Remove and dispose of each succeeding strip in the above manner. Avoid walking on the exposed felt as much as possible. 157 a Miscellaneous ACM a Asbestos 04M Work Practices a 1992 NIBS M2 Level 3_coruoud F. Occasionally, parts of the top layer will stick to the backing. This can often be eliminated by peeling in the opposite direction. The stiff-bladed scraper might aid in the removal or peeling of the wear layer. G. Wet-scraping residual felt backing: 1. Adequately wet the residual felt with amended water. Wait for a few minutes to allow the amended water to soak into the felt 2. Stand on the remaining floor covering (not the felt) and use the stiff- bladed scraper to scrape up the wet felt 3. Rewet the felt if the amended water has not completely penetrated, if drying occurs, or if dry felt is exposed during scraping. Pick up the scrapings as they are removed from the floor and place in disposal bags or containers. Wet-scrape felt from affected floor area. 4. When floor area has been cleaned free of felt vacuum up any dirt using die HEPA vacuum cleaner with the metal floor tool. Position the vacuum cleaner so that the discharge air does not blow on the area being cleaned. 5. If HEPA vacuum filter or bag needs to be changed, use work practice W31. 6. Allow substrate to dry before installing new flooring. ' 7. Perform clean-up and tear-down steps on Level 3 checklist to complete work. 158 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M3 Summary Penetrate resilient asbestos flooring and subfloor Summary This work practice covers the procedures for drilling or cutting holes in resilient asbestos flooring and the subfloor below. If the flooring is badly damaged it may be advisable to remove it, rather than drilling holes in it Note: AHERA states that maintenance staff employees should be instructed not to drill holes in ACM. Only properly 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 Ml 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 01992 NIBS M3 Level 1 Penetrate resilient asbestos flooring and subfloor Example Level 1: A. Remove small amount of resilient asbestos floor covering to drill hole(s) In subfloor to attach object to floor or install a pipe or conduit Notes ~ Work Practice This work practice must be used in conjunction with General Procedure WI and a Level I Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Use Work Practice M31 IfHEPA vacuum needs maintenance, or Ifbag orfiber needs to be replaced 1. Perform Pre-work activities on Level 1 checklist 2. Additional tooW equipment and materials: (See General Procedure Wl for standard tools, equipment and materials list). Scraper Drill ' Hook Knife 3. Place tools, equipment and materials needed in work area. 4. Cut out a piece of resilient asbestos flooring larger than the hole to be drilled using utility or hook knife. Use scraper to pry up a piece of flooring. Place flooring piece into disposal bag, adequately wet mastic or residual felt using amended water and scrape up using Ml Level 1 step 7 procedures for tile and M2 Level 1 step 4F for vinyl sheet flooring. 5. Drill hole into subfloor as needed. 6. Clean up dust and debris using HEPA vacuum. . 7. Perform maintenance work required and clean-up and tear-down steps on j Level 1 checklist to complete work. 160 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 This work practice must be used in con/unction 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 mayfall on ceiling below. See work practices SI, Mil, M13 or M24.1 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). Drill or hole saw with HEPA vacuum attachment < Small stiff-bladed scraper 3. Prepare work area with drop cloth covering work area except where boles 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 that may fall to floor below. 4. Place tools, equipment and materials 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 underside. 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 M3 Level 3 Penetrate resilient asbestos flooring and subfloor Example 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. Notes This work practice must be used in conjunction with Gerund Procedures Wl, W9 and a Inert 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. : Work Practice Coordinate work with proper O & M work practicefor accessing type ofceiling present in work area if debrisfrom work mayfoil on ceiling below. See work practices, SI, Mil, M13 or M24.1 1. Perform Pre-work activities on Level 3 checklist. 2. Additional tools, equipment and materials: (See General Procedure W1for tUmdard toolSp f^aymaf ttkd MAtorisIt Ust)* ' Drill or saw with HEPA vacuum attachment * Small stiff-bladed scraper 3. Prepare work area with mini-enclosure and set up negative pressure system or HEPA filtered local exhaust ventilation. Do not cover floor where holes are to be drilled or cut See General Procedure W9. If hole being drilled or cut is to penetrate through floor, an enclosure wfll be needed on the underside to catch any dust or debris that may fall to floor below. 4. Place tools, equipment and materials needed into enclosure. 5. Enter enclosure, and adequately wet area where penetration must be made using amended water. If desired, cut out a piece of flooring larger than the bole to be made using utility knife and scraper. , 6. Using drill or saw with wetting or attached HEPA vacuum, perform drilling or cutting operation. Wet ail dust or debris generated using amended water. 7. Gean 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 , underside. Package debris or dust as ACM waste. 9. Perform maintenance work requited and clean-up and tear-down steps on Level 3 checklist to complete work. 162 a Miscellaneous ACM a Asbestos O&M Work Practices a 01992 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 mi - 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 flowing. 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 61992 NIBS M4 Level 1 Install new resilient flooring or carpet over resilient asbestos flooring Example , Level 1: A. New caipet being installed over well-adhered resilient asbestos tile or vinyl sheet flooring with ACM backing in good condition. 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. Review manufacturer's recommendations concerning installation ofnew flooring over existing before proceeding with this work. Coordinate this work with floor stripping work practice M6 as required in step 5. Use Work Practice M31 ifHEPA vacuum needs maintenance, or ifbag orfiber 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: (sea General Procedure Wlfor standard tools, equipment and materials list,% 1 Scraper 2-3" (50-75 mm) wide stiff blade 3. Place tools, equipment and materials needed into work area. . 4. HEPA vacuum area where flooring will be installed. 5. Strip wax/finish from existing floor using O&M work practice M6. 6. Level off any minor high spots on floor using scraper. Do not sand or grind flooring. 7. Fill any low areas using manufacturers recommended underiayment or Leveling compound. 8. Install new flooring or caipet as recommended by manufacturer. 9. Perform clean-up and tear-down steps on Level 1 checklist to complete work. 164 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M5 Summary Install partition over resilient asbestos flooring Summary This work practice describe the 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 remove flooring 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 the partition installation. Related Work Practices Ml Replacement of resilient asbestos flow 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 partition. A person Recommendations With air monitoring training might be required. This person can be a worker. 165 Miscellaneous ACM Asbestos O&M Work Practices 1992 NISS M5 Level 1 Install Partition over resilient asbestos flooring Example Level 1: A. Install partition over resilient asbestos flooring that is well-adhered and in good condition. 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 Mil 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). Anchoring devices and equipment Non-asbestos adhesive 3. Place tools, equipment and materials needed in work area. 4. Install base plate of wall on full bed of adhesive and attach to floor using appropriate anchoring devices. 5. HEPA vacuum any chips or dust generated during fastening operation. 6. Complete installation of wall. 7. Perform cleanup and tear down steps on Level 1 checklist to complete work. 166 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 the partition installation. Notes This work practice must be used in conjunction with General Procedures WI, W9 and a herd 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 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). 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. Levd off any minor high spots on floor using scraper. Do not sand or grind flooring. 7. Remove any damaged vinyl asbestos flooring in area of work using O & 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 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M6 Summary Wet strip floor wax from resilient asbestos flooring Summary This work practice covers die procedures for stripping floor wax or finish from resilient asbestos flooring. Do not strip damaged flooring. Any loose or damaged flooring should be repaired or replaced before stripping is started. Wet stripping, if performed properly, should not cause damage to resilient flooring. If any flooring damage occurs during stripping, stop work and make repairs using applicable work practicefsj. Do not dry strip, scrape, sand, or grind resilient asbestos flooring to remove any blemishes or imperfections. This procedure is based on EPA's recommended Interim Guidance Memorandum for Maintenance of Asbestos-Containing Floor Coverings, January 25,1990. Example Level 1: A. Stripping floor wax or finish coat from resilient asbestos flooring that is well adhered and in good condition. Related Work Practices Ml - Replacement of resilient asbestos floor tiles. M4 Install new resilient flooring or carpet over resilient asbestos flooring. M7 Buffing resilient asbestos flooring. M8 Cleaning resilient asbestos flooring. Worker One worker trained in wet stripping procedures for resilient asbestos flooring. A Recommendations person with air monitoring training might be required. This person can be the worker. 168 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M6 Level 1 Wet strip floor wax from resilient asbestos flooring ExamptO Level 1: A. Strip floor wax or finish coat from resilient asbestos flooring that is well- adhered and in good condition. Notes Work Practice This work practice must be used in conjunction wish General Procedure WI and a Level 1 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. 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: (sec General Procedure Wl for standard tools, equipment and materials list). "Caution - Wet Floor" signs Floor stripping machine Stripping Pads (least fcbrasive 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. 8. 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 Miscellaneous ACM Asbestos O&M Work Practices a 1992 NIBS M7 Summary Dry or spray buffing resilient asbestos flooring Summary This workpractice covers flie procedures for spray buffing the polish to restore gloss on resilient asbestos flooring. Do not buff damaged flooring. Any loose or damaged flooring should be repaired or replaced before buffing is started. This practice assumes that die floor has adequate coats of polish, and that the flooring itself will not be damaged or contacted by the buffing equipment If any flooring damage occurs during buffing, stop work and make repairs using applicable work practice^). If polish is in poor condition, use work practice M6 or M8. Example Level 1: A. Dry or spray buff die pOUsh on resilient asbestos flooring to remove minor surface imperfections and restore gloss. Related Work Practices IM Strip floor wax from resilient asbestos flooring. M8 Cleaning resilient asbestos flooring. Worker One worker trained in spray buffing procedures for asbestos flooring. A person Recommendations with air monitoring training might be required. This person can be the worker. 170 Miscellaneous ACM Asbestos O&M Work Practices 01992 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 Lerel 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. Perform applicable pre-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure W1 for standard toots, 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 with 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 with manufacturer's recommended pad or brush at recommended RPM. 6. Perform applicable steps on Level 1 checklist to complete work. 171 Miscellaneous ACM Asbestos O&M Work Practices 01992 NIBS M8 * Summary Gleaning resilient asbestos flooring Summary This work practice covers die procedures for cleaning (or scrubbing) the polish on resilient asbestos flooring prior to buffing or application of additional polish. Do not polish loose or damaged resilient flooring. Any damage should be repaired before cleaning begins using the applicable work practicef*). Stop work if any damage occurs during cleaning and make repairs needed. Example Level 1: A. Clean or scrub resilient asbestos flooring with adequate coats of floor polish on flooring before buffing or application of additional polish. Related Work Practices M6 Wet strip floor wax from resilient asbestos flooring. M7 Dry or spray buffing resilient asbestos flooring. Worker One worker trained in cleaning procedures for asbestos flooring. A person with Recommendations airmonitoring training might be required. This person can be the worker. 172 Miscellaneous ACM a Asbestos O&M Work Practices n 1992 NIBS M8 Level 1 Cleaning resilient asbestos flooring Example Level 1: A. Clean 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" (50-73 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 Flow" 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 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 O&M Work Practices 01992 NIBS *: 1 M9 . Summary Remove carpet over resilient asbestos flooring Summary > ` This workpractice describes the procedures to be used for removing a small area of carpet installed over resilient asbestos flooring for O&M work. These procedures assume that the carpet adhesive or mastic does not contain asbestos, and that contamination is not present on the top side of the carpet If a large area is involved, the work might require that abatement procedures be used. If carpet - mastic contains asbestos, m Weri Practice Ml. Removal of well-adhered carpet i can pull up resilient asbestos flooring beneath the carpet Examples Level 1: A Remove carpet that is non-adhered or weakly adhered to resilient asbestos flooring. * v': ' '' " .. - ! * . `-1 *' ` 1 Level 2: A Remove carpet adhered to good condition resilient asbestos flooring where ; mastic and/or a small number of tiles may be pulled up, or flooring may be ; pulled up without separation of backing and wear layer. Resilient flooring ? mastic may or may.not contain asbestos. ; Levels: A Remove carpet-adhered to poor condition or loose resilient asbestos flooring' and/or mastic that will break, tew or become triable during removal. Related Ml Replacement of resilient asbestos floor tiles. Work Practices M2 -Replacement of vinyl sheet flooring with ACM backing. ___________ _________ M4 - Installation of new resiUent flooring or carpet over resilient asbestos i 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 . 1 worker. . ' ,, - ' ' . . ' * ' | 174 Miscfillanenus ACM Achednc ORM Work Pmrfiroe /ft 1000 Mine M9 Level 1 Remove carpet over resilient asbestos flooring Example Level 1: A. Remove carpet that is Don-adhered or weakly adhered to resilient asbestos flooring. NotoS This wort 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. If asbestos-containing adhesive must be removed, refer to wet-scraping procedures in Work Practice Ml. Use Work Practice M3I ifHEPA vacuum needs maintenance, or ifbag orfilter needs 10 be replaced.1 2 3 4 5 6 7 8 9 1. Perform Re-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Metal straightedge for use when cutting carpet Scraper 2-3" (30-75 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 corners 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 m1]) 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 m1). 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 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M9 Level 2 Remove carpet over resilient asbestos flooring Example Level 2r A. Remove carpet adhered to good condition resilient asbestos flooring where ; : mastic and/or a small number full tiles may be pulled up, or flooring might be pulled up without separation of backing and wear layer. Resilient flooring mastic may or may not contain asbestos. ' Notes This work practice must be used in conjunction with General Procedures Wl, W4 and a Level T Worker Checklist. The worker checklist includes tasks that must be performed : before these work practices are begun. . : Review manufacturer'srecdmmendation concerning installation ofnew carpet over otdflooring and/or adhesive before proceeding with this work, ifasbestos-containing adhesive must be removed, refer to wet-scraping procedures in Work Practice Ml. Avoid foot traffic on any exposed mastic. ;1 2 3 4 5 6 7 8 9 10 Work Practice 1. Perform Pre-work activities on Level 2 checklist 2. Additional t00is, equipment and materials: (see General Procedure Wl for ftiflldbnf lOolSp 4UHi gMflwfalI ,! Scraper 2-3" (5D-73 mm) wide stiff blade Metal straightedge for use when cutting carpet / 3. Prepare work area. Sea General Procedure W4. . 4. Place tools, equipment said materials needed into work area. ; 5. Hod a seam or corner wherever carpet removal can begin. If no seams or corners exist, a cut will need to be made around the piece to be removed. Wet the areas that need to be cut using amended water. Cut carpet using utility krdfo with a new blade. 6. Pry up corner or seam of carpet using scrapier. Pun back a section large enough (approximately one square foot [0.1 m*]) to hang onto while removing carpet. Adequately wet flooring and adhesive exposed. ; 7. Pufl carpeting back Slowly and spray amended water on flooring and adhesive as they are exposed. Remove carpet in pieces no larger than approximately j 200 square feet (18.6 m1). , , | 8. If carpet are! adhesive are non-ACM, roil up carpet and dispose of as non- ACM waste. If portions of asbestos-containing flowing remain attached to carpet backing, dispose of carpet as ACM. Loose vinyl asbestos flooring shall be (fisposed of in disposal bags or containers. . 9. 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. 10. Perform clean-up and tear-down steps on Level 2 checklist to complete work. 176 a Miscellaneous ACM a Asbestos OSM Work Practices a <s> i<w> NIRR itiT Vi, iir.iiar.'iiitV'iiatw 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 Wl, 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. If asbestos-containing resilient flooring 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" (30-73 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. Pntw enclosure and find a seam or comer where carpet removal can begin. If no seams or corners 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 nonACM 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 Asbestos 0&M Work Practices 1992 NIBS Clean potentially asbestos-contamiriated carpet Summary _ This work practice describes the O&M procedures to be used for cleaning small areas of asbestos-contaminated carpet If contamination is present due to a fiber release, U work practice U29. Note: ERA'S Great Book indicates that routine use ofa special cleaning work practice is not required ifasbestos-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 . ; Examples Level 1: A. Clean potentially asbestos-contaminated carpet that has no visible contamination or analytical confirmation of asbestos contamination. ACM In room is in good condition. \ Level 2: A. Gean carpet thathas some visual or analytical evidence of asbestos contamination. . Related Work Practices M9* Remove qupet over resilient asbestos flooring. M4-install new resilient flooring or carpet over resilient asbestos flooring. ' Worker One worker., A person with air montorihg training might be required. This Recommendations person can be the worker. j* - 178 Miscellaneous ACM n Asbestos O&M Work Practices 1992 NIBS M10 Level 1 Clean potentially asbestos-contaminated carpet Example Level 1: A. Clean potentially asbestos-contaminated carpet that has no visible 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 Oust work practices are begun, EPA's Green Book indicates that routine use ofa soecial cleaning work oractice is not required jfasbestos-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 l 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 if bag 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). 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 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M10 . Level 2 Clean potentially asbestos-contaminated carpet Example Level 2: A. Clean carpet that has some visual or analytical evidence of asbestos contamination. ' Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W4 and a Lewd 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 Genera! Procedure Wl for standard loots, ointment and materials list). ' HEPA vacuum with beater bar or carpet steam cleaning equipment 3. Prepare work area with critical barriers. See General Procedure W4. 4. Place tools, equipment and materials needed into work area. 5. Clean carpet using one of die following'procedures: . , A. With HEPA vacuum, vacuum contaminated area in parallel passes with ; each pass overlapping the previous by one half the width of the beater bar. Vacuum the area a second time, in the same manner, in passes at right ; angles to the first passes. B. With steam cleaning equipment,'clean carpet in accordance with I manufacturer's equipment instructions. Clean in overlapping passes In one direction, and then a second time In overlapping passes at right angles to the first passes. Water froim cleaning operation shall be disposed of in accordance with applicable regulations. See General Procedure WI& 6. Perform clean-up and tear-down steps on Level 2 checklist to complete work. 180 a Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS Mil Summary Remove asbestos-containing ceiling panels in lay-in ceiling system Summary This work practice covers die 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 T (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, tee 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 2: 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 the 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-conlaining ceiling panel below a plenum space that has exposed surfacing ACM. M12 Replace asbestos-containing ceiling tiles attached with adhesive. M13 Replace asbestos-containing ceiling tiles in spline ceiling system. 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. 181 Miscellaneous ACM Asbestos O&M Work Practices a 1992 NIBS Mil Level 1 Remove asbestos-containing ceiling panels in lay-in ceiling system Example 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. Notes This 'rk practice must be used In conjunction with General Procedure W1 and a Level l Wotier Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. i , Work Practice Coordinate work with O AM 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 W1 for MM& JRtfteriflll Hit)* ' Non-asbestos replacement ceiling panels, if needed. 3. Place tools, equipment and materials needed in work area. 4. Set up ladder or scaffold in work area. * 5. If panel will be replaced, remove ceiling panel and {dace into disposal bag. If panel will be reinstalled, remove carefully and store for rdnstallation. 6. HEPA vacuum area where tile was installed and any suspension system components exposed where die was removed. 7. Perform maintenance work and reinstall existing panels or install new panels. .8 Perform dean-up and tear-down steps on Level 1 checklist to complete work. 182 s Miscellaneous ACM a Asbestos 04M Work Practices a 199? NIRfi Ml 1 . Level 2 Remove asbestos-containing ceiling panels in lay-in ceiling system Example Level 2: A. Remove several asbestos-containing ceiling panels to perform maintenance work on or above ceiling where the panel(s) offer resistance to being moved antVor the edges are or will be abraded. 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 Coordinate work with O AM Work Practice SI ifsurfacing ACM is present above ceiling.1 1. Perform Pre-work activities on Level 2 checklist. 2. Additional special tools, equipment and materials: (tee General Procedure Wl 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 adequately wet ceiling panel(s), if panel(s) will be replaced. 5. If panel(s) will be 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 C 1992 NIBS Mil Level 3 Remove asbestos-containing ceiling panels in lay-in ceiling system Example Notes Level 3: A. Remove damaged, broken, or soiled asbestos-containing ceiling panels alone or in conjunction with maintenance work above ceiling., - - , i_________________________________________________' ( This work practice must be used In conjunction with General Procedures WI, W9 and a Lewd 3 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Work Practice Coordinate work with O dAf Work Practice SI ifsurfacing ACM is present above ceiling. 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (See General Procedure WJfor yftiifrfffrf qm& wioitriois fist}. Stiff nylon bristle brushes . Non-asbestos replacement ceiling panels, if needed 3. Prepare work area with 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 panel(s) and remove. 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. 184 Miscellaneous ACM Asbestos O&M Work Practices a 1992 NIBS _ . ri ini Minina iiin 'Xsu. 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 2l A. Remove ceiling tiles that can be removed as whole tiles without breakage. Small pieces of tile may remain attached to adhesive on ceiling. Level 3: A. Remove ceiling dies 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. ' 185 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS c M12 Level 2 Remove asbestos-containing ceiling tiles attached with adhesive Example Level 2: A. Remove ceiling tiles that can be removed as whole tiles without breakage. Small pieces, of tile may remain attached to adhesive on ceiling. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W9 and a heref 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 WJ for standard toots, equipment and materials list). s Non-asbestos replacement ceiling panels and adhesive ' Scraper or other tools as needed to remove tiles 3. Prepare work area with drop doth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. Set up ladder or scaffold on drop doth. 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. 8. Install new ceiling tiles and perform clean-up and tear-down steps on Level 2 checklist to complete work. 1B6 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS -JL - -=*--r . r^- r ^ Ml2 Level 3 Remove asbestos-containing ceiling tiles attached with adhesive 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 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.1 Work Practice 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). Non-asbestos replacement ceiling panels and adhesive Scraper or other tools as needed to remove tiles 3. Prepare work area with drop doth, 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 endosure. Enter enclosure '** and set up ladder or scaffold inside enclosure. 5. Adequately wet ctiling tiles to be removed. 6. Cut away outer 1/2" (13 nun) 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 1992 NIBS A M13 Summary Remove asbestos-containing ceiling tiles in spline ceiling system Summary This work practice covers the O&M procedure for removing small numbers of ; asbestos-containing ceiling'tiles in'a spline ceiling system. Procedures assume that tile adhesive does not contain asbestos. Examples Laval 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. Laval 2: A. Remove tiles that can be removed as whole tiles without breakage. Laval 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. U12 Remove asbestos-containing ceiling tiles attached with adhesive. M24 - Remove section of asbestos-containing drywall. Worker One or two workers for Level 2 depending upon safety and efficiency Recommendations considerations. Two workers forLevel 3. A person with air monitoring training might be required. This person can be a worker. 188 a 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 l Worker Checklist The checklist includes tasks that must be performed before these work practices are used. Work Practice Coordinate work with OAM Work Practice SI if surfacing ACM is present above ceiling. Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag orfilter needs to be replaced1 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). 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 installed and suspension system components exposed where tiles were removed. 7. Perform clean-up and tear-down steps on Level 1 checklist to complete work. 1B9 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS M13 Level 2 Remove asbestos-containing ceiling tiles in spline ceiling system Example Level 2: A. Remove tiles that can be removed as whole tiles without breakage. Notes This work practice must be used in conjunction with General Procedures WJ, W9 and a heed 2 Worker Checklist. The worker checklist includes tasks that must be performed : ~ before these work practices are begun. . _ . '. 1 Coordinate work with OAM Work Practice SI ifsurfacing ACM Is present above ceiling.1 Work Practice 1. Perform Pie-work activities on Level 2 checklist ; 2. Additional tools, equipment and materials: (see General Procedure Wlfor standard tools, equipment and materials Bs0. ; Non-asbestos replacement ceiling panels and straight pins 3. Prepare work area with drop cloth. See General Procedure W9. 4. Place tools, equipment and materials needed onto drop cloth. 5. Set up ladder or scaffold and adequately wet ceiling tiles to be removed. 6. Cut away outer 1/2" (13 mm) of tiles on edges set on splines. Remove ceiling tiles and place into disposal bags. : 7. HEPA vacuum area where tiles were installed. Wet wipe any suspension system components exposed where tiles were removed. 8. Install new tiles using (tins into adjacent tiles to secure in place. 9. Perform clean-up and tear-down steps on Level 2 checklist to complete work, j 190 a Miscellaneous ACM a Asbestos O&M Work Practices a 1992 NIBS ----- * * -v-nf < **-** --'---^- 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. Work Practice Coordinate work with OAM Work Practice SI ifsurfacing ACM is present above ceiling.1 2 3 4 5 6 7 8 9 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 Altered 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 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 tiles were removed. 8. Install new tiles using pins into adjacent tiles 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 a 1992 NIBS M14 Summary Cut or drill asbestos cement panels Summary This work practice covers the procedures cutting or drilling asbestos cement panels. : .. . Examples Level 2: A. Drill asbestos cement board to install a new electrical panel. Level 3: A. Cut or drill asbestos cement panel to install a vent through panel using power tools. .... . : .' ' | Related Work Practices II15 Remove asbestos cement. '1 . . M23 - Cut or drill asbestos-containing drywall or drywall compound. Worker One worker for Level 2. Two workers for Level 3. A person with air monitoring Recommendations training might be required. This person can be a worker. 192 a Miscellaneous ACM a Asbestos 0M Work Practices a 199? NIRS Ml4 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.1 2 3 4 5 6 7 8 9 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 the 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 Asbestos O&M Work Practices 1992 NIBS M14. Level 3 Cut or drill asbestos cement panels Example . Level 3: A. Cut or drill asbestos cement panel to Install a vent through panel using power tools. Notes This work practice must be used in conjunction with General Procedures WI, W9 and a Level 3 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 3 checklist 2. Additional tools, equipment and materials: (See General Procedure WI for MtOMd&d tooiSf ifppuf frrrrrrrwlf titty Hand or power drill as needed (power tools should have a 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. If accessible, enclose back side of panel to catch dust and debris where hole will penetrate through panel. 4. Place tools, equipment and materials needed into enclosure. 5. Enter enclosure and adequately wet both rides of area to be cut or drilled , using garden sprayer with amended water. Keep water away from any electrical cords or equipment 6. Cut or drill hole(s) using saw or drill. Power tools should have an operating HEPA vacuum attached. Wet cutting area during drilling or cutting 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 rides of the surface and the hole drilled through the sponges. B. A HEPA vacuum hose may be used near die bit of a non-HEPA equipped drill, and on the back side if accessible. C. Shaving cream can be sprayed on both rides of the drilling area to control dust and debris. Shaving cream must be wiped up and disposed of as ACM. 7. Remove panel piece and wet wipe debris off drill or saw using wet disposable towels and place towels and debris into disposal bag. 8. If back side was enclosed, insert wand of garden sprayer with amended water into back ride enclosure and wet dust or debris. Remove back ride 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 3 checklist to complete work. 194 Miscellaneous ACM Asbestos O&M Work Practices 1992 NIBS Ml5 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 condition. 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 Miscellaneous ACM Asbestos O&M Work Practices a 1992 NIBS Ml5 Level 1 Remove asbestos cement panels Example Level 1: A. Remove conugated or flat asbestos dement panels that are painted or in good condition, and have fasteners that can be 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. 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). Tools as needed to remove panel fasteners (slatter's ripper, nan clipper, screwdriver) 3. Place tools, equipment and materials needed in work area. 4. Adequately wet panels to be removed with amended water. Remove fasteners holding panel in place. Clean fasteners if they are to be reused. Dispose of fasteners as ACM if not being reused. 5. Remove panel and wrap in two (2) layers of polyethylene sheet for disposal as ACM. ' 6. Perform maintenance work and clean-up and tear-down steps on Level 1 checklist to complete work. 196 Miscellaneous ACM Asbestos O&M Work Practices 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 EPAjfor this work.1 2 3 4 5 6 7 8 9 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 panel fasteners (slatter's ripper, nail clipper, screwdriver) 3. Prepare work area with drop doth. 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 Miscellaneous ACM Asbestos O&M Work Practices a 1992 NIBS M15 . Level 3 Remove asbestos cement panels Example Level 3: A. Remove corrugated or flat asbestos cement panels in poor conditionwhich have become friable and where dust or powder may be generated during removal. 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. Work Practice Ifactivated electrical equipment is in work area, delete wetting (rfpermitted by EPA)for this wptk. i1 2 3 4 5 6 7 8 9 1. Perform Pre-work activities on Level 3 checklist 2. Additional tools, equipment and materials: (Sen General Procedure Wl for rftrmfartf tootSg wwti antf tTfitfarfiflT ffyf), ' . Tools as needed to remove panel fasteners (slatter's ripper, nail clipper, screwdriver) , 3. Prepare work area with drop doth, mini-enclosure and set up negative pressure system. See Gestured Procedure W9. ' 4. Place tools, equipment and materials needed into enclosure. ; 5. Enter enclosure and adequatdy 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 ait removed. Clean fasteners using water if they are to be reused. . Dispose of fasteners as ACM if not being reused. 1 7. Remove panel and wrap in two (2) layers of polyethylene sheet for disposal as ACM. If panel breaks or chips and small debris results from removal, collect and dispose of in disposal bags or containers. 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 3 checklist to complete work. 198 Miscellaneous ACM 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 condition. 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 01992 NIBS Ml 6 Level 1 Remove asbestos cement cooling tower louvers Example Level 1: A. Remove asbestos cement cooling tower louvers in good condition. Notes ; This work practice must be rued 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. : I Use Work Practice M3I ifHEPA 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 Cement Procedure W1 for standard tools, equipment and materials list). i Tools as needed to remove louvers Non-asbestos replacement louvers 3. Place tools, equipment and materials needed in work area. Verify that cooling tower is shut off and locked out 4. Remove any fasteners holding louvers in place. HEPA vacuum and wet fasteners during removal. Clean fasteners for reuse or dispose of as ACM. 5. Remove louvers and place into disposal bags or wrap in polyethylene sheet for disposal. 6. HEPA vacuum surfaces louvers were contacting and any dust or debris from : louver removal. 7. Perform maintenance work and clean-up and tear-down steps on Level 1 checklist to complete work. 900 u Miscellaneous ACM Asbestos OAM Work Practices 1902 NIBS i Ml6 Level 2 Remove asbestos cement cooling tower louvers Example Level 2l A. Remove asbestos cement cooling tower louvers in poor 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 1. Perform Pre-work activities on Level 2 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for ifffffrfffrrf iooiif tfMqpwiswt gjirf wktttsnols 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 and 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. 201 Miscellaneous ACM Asbestos O&M Work Practices 01992 NIBS Remove or replace asbestos cement roof shingles Summary This work practice covers die procedures for removing or replacing a small number of asbestos cement shingles from the roof of a building to support O&M work. Examples 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. Level 2: A. Replace or remove asbestos cement roof shingles that are damaged and may ; become friable during removal. Related Work PracticeS M14 Cut or drill asbestos cement panels. MIS Remove asbestos cement panels. 1118 Remove and replace asbestos cement tiding. 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. ' 202 u Miscellaneous ACM u Asbestos O&M Work Practices a 01992 NIBS Ml 7 . 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 bag orfilter needs to be replaced. 1. Perform Pie-work activities on Level 1 checklist 2. Additional tools, equipment and materials: (see General Procedure Wl for standard tools, equipment and materials list). Pry bars, sialter's ripper ancVor nail dipper Non-slip boots for roofing work Safety harness Replacement roofing Hammer 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 Asbestos O&M Work Practices 01992 NIBS M17. Level 2 Remove or replace asbestos cement roof shingles Example Level 2: A. Replace or remove asbestos cement roof shingles that are damaged and may become friable during removal. Notes Work Practice This work practice must be used in conjunction with General Procedures Wl, W4, W9 and a Level 2 Worker Checklist. The worker checklist includes tasks that must be performed before these work practices are begun. Use ofa safety harness is strongly recommendedfor working on doped roofs. Roofing removal work shall be completed before anf penetrations are made in the roofdeck. 1. Perform Pre-work activities on Level 2 checklist ' 2. Additional tools, equipment and materials: (tee General Procedure Wl for ttamdari toci$p ifi^pnisf nd wwAtfiob list)* Pry bars, darter's ripper and/or nail dipper Non-slip bools for roofing work Safety harness . Replacement roofing Hammer .. . . ,. Spray encapsulate Of used) * 3. Prepare work area with barrier tape and drop doth. See General Procedures W4 and W9. Drop cloth should be below removal area to catch any debris generated during removal. Seal any roof penetrations, dr intakes or windows in work area with polyethylene. Do not seal over plumbing vent stacks. 4. Place tools, equipment and materials needed into work area. 5. If feasible, safe and desired, encapsulate or adequately wet shingles to be removed. . 6. Starting at top of removal area, remove nails, cut nails or pry up edge of first shingle until edges can be gripped by hand. Spray amended water on back of shingle. Remove shingle and place into disposal bags or polyethylene lined cardboard boxes. ' 7. Continue removing shingles 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 204 Miscellaneous ACM Asbestos O&M Work Practices a 01992 NIBS