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ASBESTOS COMPLIANCE WITH APPLICABLE REGULATIONS

Asbestos Surveys Asbestos surveys are conducted prior to any building renovation or demolition projects in compliance with the regulations set forth in the OSHA Construction Standards 29 CFR 1926.1101. The purpose of these surveys is to determine the presence, location and quantity of ACM. During the survey, representative samples of each suspect material are taken and analyzed at an independent laboratory. If no sample information is available for thermal system insulation (TSI), sprayed- or troweled-on surfacing materials, or asphalt and vinyl flooring installed before 1981, these materials must be identified as asbestos containing. Copies of completed surveys are kept in each building to which they pertain along with a master copy housed in the Office of Environmental and Occupational Safety. This data will be maintained for as long as the university relies upon it.

Training Training is required for all employees who perform Class I through IV asbestos work. The training must meet the requirements of the EPA Model Accreditation Plan (MAP) asbestos abatement workers training. No untrained workers are to disturb any amount of asbestos. No student workers are to disturb any amount of asbestos. Contact the Office of Environmental and Occupational Safety office for training details. The following are the basic training requirements for the different types of abatement work:

Class I asbestos work involves the removal of TSI and surfacing ACM and presumed asbestos-containing material (PACM). Training for Class I work is either 32 hours in order to be accredited at the worker level, or 40 hours in order to be accredited at the contractor/supervisor level and function as a competent person. An annual 8-hour refresher course is required for both the worker and contractor/supervisor level of training.

Class II asbestos work involves the removal of ACM which is not thermal system insulation or surfacing material. This includes the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics. Training for Class II work may be the same as for Class I work (asbestos worker or contractor/supervisor) or may be 8 hours of training, including hands-on training, in the specific type of material to be removed. Removal of the following materials falls under the 8-hour class listing: roofing materials, flooring materials, siding materials, ceiling tiles, and transite panels. An annual refresher is required for all workers.

Class III asbestos work involves repair and maintenance operations where ACM including TSI and surfacing ACM and PACM may be disturbed. Training for Class III work is 16 hours with an annual 4-hour refresher course.

Class IV asbestos work involves maintenance and custodial activities during which employees contact but do not disturb ACM and PACM. An initial two-hour asbestos awareness training with an annual refresher is required for all custodial, maintenance, housekeeping and service personnel who work in buildings that may contain asbestos. The annual refresher training will be available on-line through the Office of Environmental and Occupational Safety website.

Housekeeping All vinyl and asphalt flooring should be treated as ACM unless evidence exists to prove otherwise. The following restrictions exist for the care of ACM flooring: no sanding is permitted, stripping should be conducted using low abrasion pads at speeds lower than 300 rpm and wet methods, and burnishing or dry buffing may be performed only on flooring which has sufficient finish so the pad doesn’t contact the flooring material. Broken ACM floor tiles should only be removed by properly trained personnel.

Ceiling tiles should not be moved or replaced until it is confirmed that they are not ACM. Only trained personnel can replace or otherwise disturb ACM ceiling tiles.

Medical Surveillance The University maintains a medical surveillance program for all employees who are engaged in Class I-III work for a combined total of more than 30 days per year or are exposed at or above the permissible exposure limit. This medical surveillance consists of a review of medical and work history, a physical exam directed to the pulmonary and gastrointestinal systems, a chest roentgenogram, and a pulmonary function test. This exam is offered annually. For employees otherwise required to wear a negative pressure respirator, a physician will determine that the employees are able to perform the work and use the equipment. For further information on medical surveillance, contact the Occupational Health Department at Olin Health Center.

All university employees must be provided with proper protective clothing and respirators when assigned to work in Class I-III asbestos work or Class IV work that takes place in a regulated area. The university maintains a respiratory protection program for its employees in accordance with OSHA 29 CFR 1910.134. Contact the Office of Radiation, Chemical, and Biological Safety (ORCBS) for information on MSU’s respirator program

Regulated Area All Class I-III asbestos work should be conducted within a regulated area with signs posted to demarcate the area. The purpose of a regulated area is to limit access to only authorized persons and to protect people outside the area from exposure to airborne asbestos. All Class I work should have a decontamination area adjacent to the work area that includes an equipment room, a shower room and a clean room. All Class II and III work should have, at a minimum, an equipment room adjacent to the work area for the decontamination of employees and their equipment. A regulated area should be supervised by a competent person.

Competent Person A competent person is required to supervise all work sites where Class I-III asbestos work takes place. The competent person’s duties include ensuring the safety and health of all workers, ensuring the proper set-up and integrity of the regulated area, ensuring that work is conducted according to all applicable regulations, and ensuring that notification requirements are met.

Exposure Assessments and Monitoring Air monitoring is conducted by an independent consulting firm during Class I-III asbestos work. This monitoring typically consists of samples from the breathing zones of employees performing the work, samples from the area surrounding the regulated area, and clearance samples after the work is completed. Additional samples will be collected at the discretion of the air-monitoring firm on-site or at the request of MSU Environmental Safety personnel. The air-monitoring firm will perform phase-contrast microscopy (PCM) analysis of all samples on-site to ensure that airborne fiber levels are well within the regulatory guidelines. The data regarding airborne fiber levels and worker exposure levels are maintained by the physical plant and Office of Environmental and Occupational Safety.

Communication of Hazards Before any asbestos-related work is performed, the employer performing the work will notify the building owner, the employees performing the work, and the employees working in adjacent areas of the quantity and location of ACM at the site. Any ACM discovered in the course of a renovation or demolition should be reported to the Office of Environmental and Occupational Safety and the Physical Plant immediately upon discovery.

The university will ensure that signs are used to properly demarcate a regulated area and any area containing ACM and/or PACM that may be frequently encountered such as boiler/mechanical rooms.

Notification to the State of Michigan Asbestos abatement contractors are required to submit notification to the Michigan Department of Labor and Economic Growth (MDLEG) and the Michigan Department of Environmental Quality (MDEQ) if the quantity of ACM being removed meets the threshold limits. All notifications must be signed by an Office of Environmental and Occupational Safety representative or a Physical Plant representative before being sent to the applicable department. Copies of notifications are maintained in the Physical Plant and the Office of Environmental and Occupational Safety and should be posted at the job site.

Definitions

Asbestos Management Program Table of Contents