Environmental Health & Safety Office

I.  Purpose

To provide guidance to all University of North Carolina at Charlotte (UNCC) employees and contractors in such a manner so as to prevent employees, contractors, or members of the general public from being exposed to an airborne concentration of asbestos fibers in excess of established limits.

To ensure UNCC, as an owner/operator of buildings and facilities which may contain asbestos containing material (ACM) and/or presumed asbestos containing material (PACM) complies fully and completely with not only the letter but the spirit of applicable local, state and federal regulations.

   II.  Scope

This program applies to all buildings and facilities owned or occupied by UNCC. In addition, all employees, contractors, students and visitors to UNCC are bound by the requirements contained herein to the extent, if any, to which they are applicable in a given situation.

  III.  Responsibilities

1.  The Safety Director is responsible for the overall management and oversight of the UNC Charlotte Occupational Safety and Health Program which includes the requirements of this document.
   
   

2. The Staff Industrial Hygienist is a technical resource for all asbestos-related activities. Further, he/she is responsible for periodic review of this program, job site inspections, containment approval and document review/audits.
   
   

3. The Asbestos Abatement Program Manager (Physical Plant Engineering and Planning Director) shall implement, manage and maintain this program as dictated.
   
   

4. All Physical Plant Supervisors have the direct held responsibility for enforcing the requirements of this program as they apply to their area and verifying the compliance of their employees.
   

 IV.  Definitions

1. ACM (Asbestos Containing Material): Any material containing more than 1% asbestos.
   
   

2. Friable: Material that when dry can be broken, crumbled, pulverized, or reduced to powder by hand pressure, and includes previously non-friable material after such material becomes damaged to the extent that when dry it can be crushed, pulverized, or reduced to powder by hand pressure.
   
   

3. HEPA (High Efficiency Particulate Air): A filter capable of trapping and retaining at least 99.97% of 0.3 micrometer diameter mono-disperse particles.
   
   

4. Large Scale Individual Abatement Project: Any single asbestos removal project which involves more than 3,000 square feet (281 square meters), 1,500 linear feet (462 meters), or 656 cubic feet (18 cubic meters) of regulated asbestos-containing material.
   
   

5. Negative Exposure Assessment: A demonstration by the employer which complies with 29CFR1926.1101(f)(2)(iii), that employee exposure during an operation is expected to be consistently below the PEL’s.
   
   

6. Non-scheduled Permitted Abatement Project: An asbestos removal; required by the routine failure of equipment, expected to occur within a given calendar year based on past operating experience but for which an exact date cannot be predicted, when the cumulative amount total of asbestos removed for all projects so described exceeds 35 cubic feet (1 cubic meter), 160 square feet (15 square meters) or 260 linear feet (80 linear meters) of regulated asbestos-containing material.
   
   

7. PACM (Presumed Asbestos Containing Material): Thermal system insulation, sprayed on or troweled on surfacing material and debris in work areas in buildings constructed prior to 1980 until such time as that material is proven, by adequate and proper testing, to be non-asbestos containing. Additionally, all 9-inch by 9-inch floor tiles and their associated adhesive shall be considered asbestos containing until tested and proven otherwise.
   
   

8. PEL (Permissible Exposure Limit): An exposure limit that is published and enforced by OSHA as a legal standard. The current PEL for asbestos is 0.1 fibers per cubic centimeter (f/cc) as an 8-hour time weighted average (twa) and an excursion limit of 1.0 f/cc as averaged over a sampling period of 30 minutes. 
   
   

9. Permitted Individual Abatement Project: Any single asbestos removal project which involves more than 35 cubic feet (1 cubic meter), 160 square feet (15 square meters) or 260 linear feet (80 linear meters) of regulated asbestos-containing material.
   
   

10. Regulated Asbestos Containing Material (RACM): Asbestos-containing material that is friable or may become friable due to removal or demolition.
    
    

11.  Regulated Area: An area established by the employer to demarcate areas where asbestos removal is conducted and any adjoining area where debris and waste from such asbestos work accumulates; and any area within which airborne concentrations of asbestos exceed or there is a reasonable possibility they may exceed the permissible exposure limit (PEL).
    
    

12. Small Scale, Short Duration (SSSD) Abatement Project: The removal of small quantities of ACM only if required in the performance of another maintenance activity not intended as asbestos abatement; removal of asbestos-containing TSI not to exceed amounts greater than those which can be contained in a single glove bag; minor repairs to damaged TSI which do not require removal; repairs to a piece of asbestos-containing wallboard; and repairs involving encapsulation, enclosure or removal, to small amounts of friable ACM only if required in the performance of an 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 mini-enclosure.
    
    

13. Surfacing Material: Material that is sprayed, troweled-on or otherwise applied to surfaces (such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing and other purposes).
    
    

14. TSI (Thermal System Insulation): Material applied to pipes, fittings, boilers, breeching, tanks, ducts or other structural components to prevent heat loss or gain.

   V.  Procedure

1. General Requirements

  1.  Identification

1. The presence, location and quantity of ACM/PACM in all buildings and facilities under the control of UNCC shall be identified to the greatest extent practicable.
   
   

2. All records and information pertaining to the identification of ACM/PACM shall be maintained for the duration of building facility ownership and passed on to subsequent owners.
   
   

3. All employees and contractors who work with, or around ACM/PACM shall be informed of its presence in writing.
   
   

4. Any employee, or contractor, who discovers ACM/PACM not previously identified shall convey information concerning the presence, location and quantity of such material to the Safety Office within 24 hours of the discovery.

2.   Signs

1. All areas in which employees reasonably can be expected to enter and which contain ACM/PACM  shall have signs posted at all entrances which identify the material present, its location and appropriate work practices which, if followed, will ensure the ACM/PACM will not be disturbed.
   
   

2. Warning signs shall also be posted at all approaches to regulated areas so that necessary precautions can be taken by personnel prior to entry; or so they are allowed sufficient time to avoid the area altogether.
   
   

3. Labels specified under 29CFR 1910.1001(J)(4)(ii) shall be affixed to all raw materials, mixtures, scrap, waste, debris and all other products containing asbestos fibers (>1%) or to their containers. Where feasible, installed asbestos products shall contain a visible label.

3.   Training

1. All employees and contractors shall be trained, at a minimum, to a level consistent with the requirements of 29CFR1910.1200 as that regulation pertains to ACM/PACM and their specific job description.
   
   

2. Additional training shall be provided as required by 29CFR1910.1001(j)(7) to all employees who have, or may be exposed to airborne concentrations of asbestos at, or above the PEL and/or excursion limits.
   
   

3. All employees actively involved in asbestos removal work shall be trained in accordance with 29CFR1926.1101(k)(8).
   
   

4.  Employees who perform housekeeping operations in a facility, or building which contains ACM or PACM shall receive an asbestos awareness training course as specified in 29CFR1910.1001(J)(7)(iv).
   
   

5. All contractors involved in asbestos abatement activities shall  have their training and accreditation verified by the UNCC Asbestos Abatement Program Manager via visual inspection of their NC State issued photo ID accreditation cards.

4.   Housekeeping

1. All surfaces shall be maintained as free as practicable of accumulations of asbestos containing dust and wastes.
   
   

2. All spills and/or sudden releases of ACM/PACM shall be reported immediately to the Safety Office and cleaned up as soon as possible in accordance with directions given by that office.
   
   

3. Surfaces contaminated with ACM/PACM may not be cleaned with compressed air.
   
   

4.  HEPA-filtered vacuuming equipment shall be used for all vacuuming operations.
   
   

5. Shoveling, dry sweeping and dry cleanup methods cannot be used without the express, written consent of the UNCC Safety Director.
   
   

6. All waste, scrap, debris, bags, containers, equipment and clothing contaminated with asbestos shall be collected and disposed of in sealed, impenetrable container.
   
   

7. Asbestos containing flooring material shall not be sanded, burnished, or dry buffed. Stripping of finishes is allowed using only low-abrasion pads at less than 300 rpm.
   
   

8.  Dust and debris in any area containing TSI, or surfacing ACM/PACM, or visibly deteriorated ACM shall not be dusted, swept dry, or vacuumed without using a HEPA filter.

5.    Medical Surveillance

1. All employees actively engaged in asbestos removal shall be included in a medical surveillance program that meets the requirements of 29CFR1926.1101(e).
   
   

2. All employees who are, or may be exposed to airborne concentrations of asbestos fibers at, or above the 8-hr-TWA and/or excursion limit shall be included in a medical surveillance program that meets the requirements of 29CFR1910.1001(e).
   
   

3. All contractor abatement employees shall have their medical surveillance records verified by the Asbestos Abatement Program Manager prior to the start of work.
   

6.    Non-Permit Abatement Operations

1. Small Scale Short Duration (SSSD) Asbestos removal operations of regulated ACM or any operation involving the removal of non-regulated ACM may be performed by non-state accredited UNCC employees of contractors without an approved NC State Asbestos removal permit, or a Mecklenburg County NESHAP Notification permit provided the following conditions are met.
   

(1) The removal project must meet the SSSD definition or the material must be non-regulated ACM.

(2) At least 10 working days prior to the start of work, The Asbestos Abatement Program Manager shall provide a scope of work to the UNCC Safety Office that contains at a minimum:

-         Location of work
-         Quantity and type of material
-         Start date
-         Estimated completion date.
-         Employees assigned (by name).
-         General description of work including removal methods.
-         Proposed PPE and containment requirements.
-         Posting requirements.

(3)  The Safety Office will either approve the Scope of Work, or
       contact the Abatement Manager for resolution of issues.

(4)  Once the Scope of Work is approved, the Safety Office will
       assign and arrange for air sampling, or generate a negative
       exposure assessment in lieu of sampling.

(5)  Air Sampling will be performed, if required, and must meet the
       following criteria:

 -  At least one 8-hr. TWA and one 30-min. Excursion
     worker  breathing zone sample will be collected and
     analyzed per job IAW the requirements of
     29CFR1910.1101.

 -   Prior to area release, at least one clearance sample will be
      collected and analyzed by an accredited air monitor IAW
      NC State regulation 15A NCAC 19C.0607

 (6)  The Abatement Program Manager must have an approved
        scope of work with either a sampling plan or a negative
        exposure  assessment attached, prior to the start of work.

(7)   If containment is involved, the containment structure or device
        must be approved by the Safety Office prior to the start of
        work.

(8)   All employees assigned to the project must meet the training
        requirements and the medical surveillance requirements.

(9)  All respiratory protection devices utilized under this procedure
       must be obtained and managed through the UNCC
       Respiratory Protection  Program.

7.  Permit Abatement Operations  

All asbestos work which requires a permit issued by the North Carolina Department of  Environment and Natural Resources and Mecklenburg County shall be performed by a qualified Abatement Contractor under the guidelines established herein. UNCC employees are not allowed to conduct permitted asbestos removal without the express written consent of the UNCC Safety Director.

1. Individual permitted abatements will require the Abatement Program Manager to complete the NC State Asbestos Permit Application and Notification for Demolition/Renovation Form and a Mecklenburg County NESHAP Notification of Demolition and Renovation Form.
   
   

2. The completed permits must be forwarded to the Safety Director for review, approval and submittal to the appropriate agencies so that the following schedules may be met.

(1)  Applications must be received by the respective state and
       county agencies no later than 10 working days prior to the
       indicated start date.   If mailed, day one (1) of the ten
       working days will be the date postmarked.

(2)  Applications for emergency removals must be postmarked, or
       received by the respective agencies as early as possible
       before, but not later than the next working day. Emergency
       applications must have a letter of explanation accompanying
       them explaining the circumstances surrounding the emergency.

3. Revisions to applications shall be made in writing, on the same forms as the original application, by the Asbestos Abatement Program Manager  and forwarded to the Safety Office for review, approval and dissemination to the appropriate agency such that the following  schedules are met.

 (1)  Revision to a start date for a project that will begin after the
       start date stated in the original permit must be received by the
       Agency on, or before the originally stated start date.

(2)  Revision to a completion date that will be extended beyond
       the completion date stated in the approved permit must be
       received by the Agency before the originally approved
       completion date.

(3)  Revision to a completion date that will be earlier than the
      completion date stated in the approved permit must be
      received by the agency prior to the new completion date.

(4)  Revision to permits other than start or completion dates, such
       as a change ± 20% to the amount of material involved, or a
       change to work schedule such as back shift, or weekend
       work addition must be submitted to the agency as soon as
       possible, but in no case later  than the start of the work
       affected by the change.

4. The Asbestos Program Manager shall be responsible for contracting with an accredited Supervising Air Monitor who will be responsible for the following.

(1)  Performing ambient, worker and clearance air samples as
       required by NC State chapter 15A NCAC 19C.0607 and
       29CFR1926.1101.

(2)  Ensures Ambient Air Sampling results are on site within 24
       hours if sample collection and analysis by PCM and within 48
       hours of sample collection and analysis by TEM.

(3)  Personal inspection of the Abatement area at least once if the
       project exceeds 10 working days but is less than 30 working
      days  in length.

(4)  Personal inspection at least once in the first 30 working days
      and at  least once each 30 working days thereafter for
      projects that exceed 30 working days.

(5)  Perform and document a formal visual inspection prior to
      clearance air sampling.

(6)  Prepare a written, signed, and dated report to UNCC
      documenting all site visits and Air Sampling results.

5. The following shall be maintained on site during removal activities and be immediately available for review.

(1)   A copy of the removal permits and all revisions with the
      confirmations of receipt.

(2)   Photo identification cards for all accredited personnel. Copies
      are unacceptable.

(3)  Copy of the abatement design.

6. All asbestos removal operations which do not require a permit issued by either the NC Department of Environment and Natural Resources, or Mecklenburg County, but do not meet the SSSD project definition, may be performed by either contractors, or UNCC employees under the following conditions:

(1)   The employees, or contractors shall be accredited by the State
      of North Carolina 15ANCAC 19C.0602 of the NC Asbestos
      Rules, Regulations and Procedures and possess a current
      photo ID card issued by same.

(2)   At least one person on site at all times must be an accredited
      supervisor.

7. All large-scale individual Abatement Projects must  meet the following stipulations:

 (1)  An Asbestos Abatement design must be prepared by an
        accredited Abatement Designer.

 (2)  An Abatement Project Monitoring Plan must be prepared by
        the supervising Air Monitor.

 (3)  Both documents must be on site and available during the
       Abatement process.

8. Permitted non-scheduled Asbestos removals must meet the definition of Section IV and may be performed as such under the following stipulations:

(1)   These removals must be permitted if the annual cumulative
        total for all non-scheduled asbestos removals exceeds the
        limits established in the definition.

(2)   Permit applications for non-scheduled removals must be
       completed by the Asbestos Abatement Program Manager
       and received by the Safety Office such that they can be
       received by the applicable agencies at least ten (10) working
      days before the start of the calendar year.

(3)   Quarterly reports as required by the State shall be prepared
        by the Asbestos Abatement Program Manager and
        forwarded to the Safety Office such that it can be received
        by the Agency no later than the 20^th of the month following
        the Reporting Quarter.

(4)   In addition to the above, all the requirements for air sampling,
        training and medical surveillance as outlined apply.

B.    Records

1. Medical records shall be retained for the duration of employment plus 30 years.
   

2. Training records shall be retained for the duration of employment plus 5 years.
   

3. Air sampling records shall be retained for the duration of employment of the people involved plus 30 years and for the duration of building ownership; whichever occurs last.
   

4. All documentation in reference to this document shall be retained for the duration of building ownership and transferred to the new owners.