I. Statement of Policy & Intent to Comply with Applicable Regulations

Compliance with Applicable Regulations:
It is the policy of Columbia University to comply with the applicable City, State, and Federal regulations pertaining to asbestos containing material (ACM). In order to achieve this goal the University has developed a comprehensive in-house protocol to address the identification, in-place management, and abatement of ACM.

The University supports stringent compliance with promulgated regulations in conjunction with cost minimization.

Departments and other administrative units of the University are required to provide a copy of this document to employees involved with the planning and/or scheduling of construction, maintenance, and other projects where the potential to impact ACM exists. In addition, such Columbia personnel are responsible for Contractor and sub-Contractor compliance with this policy.

To summarize, ACM (friable and non-friable) shall only be removed or otherwise impacted by a licensed asbestos abatement Contractor utilizing licensed workers. ACM or other asbestos contaminated debris/waste shall be properly labelled and transported off-site by a licensed waste hauler to a registered landfill, where proper Manifesting procedures ("cradle to grave" documentation) shall be utilized.

The Office of Environmental Health and Radiation Safety shall provide technical assistance in achieving the goals of this policy.

Review of Applicable Regulations:
In the City of New York there are multiple regulatory agencies which have jurisdiction over asbestos containing materials (ACM) in buildings including the New York State Deptartment of Labor (NYS DOL), the New York City Department of Environmental Protection, (NYC DEP), The New York City Department of Health (NYC DOH), the federal Occupational Safety and Health Administration (OSHA), and the Federal Environmental Protection Agency (EPA). Each agency has promulgated regulations which address the various aspects of maintenance and handling of ACM in order to protect building occupants from asbestos exposure and to protect the ambient air.

NYS DOL regulations
The New York State Department of Labor has adopted Industrial Code Rule 56 (ICR-56) to address the proper identification, handling, removal, and disposal of ACM in public buildings (superseded by NYC DEP regulations in NYC only).

NYC DEP regulations
In a similar manner the New York City Department of Environmental Protection adopted Local Law 76 which was later revised as Title 15 Chapter 1. These regulations also address the proper identification, handling, abatement, and disposal of ACM in public buildings and in NYC only (i.e.. Nevis and LaMont campuses must follow NYS ICR-56), supersede NYS DOL ICR-56 regulations as per order of the NYS DOL. In NYC (i.e.. Main and Uptown campuses), State Inspectors may only issue violations for licensing deficiencies (not work practice related issues); City Inspectors have jurisdiction over all engineering control/work practice relate issues.

NYS DOH regulations
NYC Department of Health Code Rule (sections 3.09-3.11) require the abatement of damaged ACM which may pose a health and/or nuisance hazard to building occupants.

Federal OSHA regulations
Federal Occupational Safety and Health Administration regulation address both in-house and Contractor worker protection an notification. The 8/10/94 "OSHA Final Rule on Occupational Exposure to Asbestos" amended OSHA standards 29CFR1910.1001/1101 and introduced the concept of "negative exposure assessments" and mandates labelling of accessible ACM.

Federal EPA regulations
The federal Environmental Protection Agency has promulgate regulations under the Asbestos Hazard Emergency Response Act (AHERA), National Emissions Standards for Hazardous Air Pollutant regulations (NESHAPS), and the Toxic Substances Control Act (TSCA) The AHERA regulations address asbestos issues in schools (grades K-12). EPA NESHAPS regulations prohibit "visible emissions" of asbestos and specify off-site disposal procedures to be utilized.

** The above listed agencies may impose fines of $1000 to $100,000 per day and prosecute negligent Building Owners for non-compliance with the applicable regulations.

The above listed regulations are available on CD ROM for review a the EH&S office.Go to Top

II. Asbestos Policy Responsibilities

a. Role of EH&S office:
The role of Environmental Health and Safety is to assist the various departments and other administrative units in complying with the applicable regulations and this asbestos policy. In order to insure compliance with this policy the EH&S office shall conduct routine inspections/audits of abatement and other construction projects. When outside environmental Consultants are retained for large capital projects, EH&S shall be responsible for compliance with this policy as well as technical review. EH&S , in consultation with the University Office of the General Counsel, shall be responsible for regulatory agency correspondence as it relates to asbestos projects.

The EH&S office shall generate an "approved asbestos Contractor's list" which shall indicate those vendors (Contractors and Consultants) approved to work on asbestos projects at Columbia University. Only those firms included on the approved list may be participate in asbestos abatement projects at Columbia.

b. Role of the Asbestos Coordinator:
Within the EH&S office the position of Asbestos Coordinator has been created to provide the technical assistance described above. The Asbestos Coordinator is under the direct supervision and advisement of the Director of EH&S .

c. Notification of the EH&S Department:
All projects and other events which may potentially involve asbestos shall be reported directly to the EH&S office immediately by phone or utilizing the appropriate form. Examples of such situations are the following:

• Maintenance projects (plumbing & HVAC)
• General construction & renovation
• Emergency pipe breaks and floods
• Electrical work above suspended ceilings
• Any work in the steam tunnels, Powerhouse, or other mechanical equipment areas
• Building demolition

When the following materials/building components may potentially be impacted the EH&S office shall be notified:

• Thermal system insulation (pre-1975) including pipe insulation, boiler jackets, etc.
• Trowelled-on wall & ceiling plaster (pre-1940)
• Acoustical ceilings (pre-1975)
• Floor tiles/rolled linoleum (pre-1980)
• Suspended ceiling tiles (pre-1980)
• Spray-on fireproofing (pre-1975)
• Roofing (field and flashing)
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When there is any potential for an asbestos containing material be impacted the EH&S office shall be notified immediately (212)854-8749. All Contractors and Consultants are required to notify the EH&S office directly of all pending work no less than 24 hours prior to commencement of work. Failure to satisfy the notification or any other requirement of this policy may jeopardize the vendor's position on the approved list.

In order to legally and properly classify a Material as ACM or non-ACM bulk sampling and laboratory analysis (by a NYS ELAP certified laboratory) must be conducted. Friable samples such a pipe insulation shall be analyzed using the Polarized Light Microscopy (PLM) Method. Roofing, transite, floor tile and other non- friable samples are analyzed using the Transmission Electron Microscopy (TEM) Method.

d. Submittal of "Project Notification and Inspection Request" form:
The EH&S Department shall be notified of asbestos related events using the Project Notification and Inspection Request form. The Project Notification and Inspection Request form will be forwarded to the Asbestos Coordinator for project scheduling. If any questions arise regarding these notification procedures, refer to "Guidelines for Completing the Project Notification and Inspection Request Form" or EH&S shall be contacted at (212)854-8749.

It should be emphasized that outside Consultants and Contractors are not exempt from satisfying the notification and other requirements of this policy. The Facilities Management Project Managers, Directors, Supervisors, Area Managers, and other involved personnel are responsible for informing the Contractors and Consultants which they retain of the terms and conditions of this policy. Failure to inform outside Contractors and Consultants of this policy shall be considered non- compliance with this policy.

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III. Review of Asbestos Terminology

In order to provide as much clarity as possible, listed below are a few key definitions:

1. Abatement
   
An approved method for handling asbestos containing materials (i.e. removal, encapsulation, enclosure). 

2. Air Monitoring
   Collection of "asbestos in air samples" by a 3rd party according to method NIOSH 7400 protocol to evaluate the hazard potential of asbestos exposure. 
   
3. Asbestos Building Survey
   The identification, evaluation, and quantitation of ACM in a building. 
   
4. Asbestos Encapsulation/Wrap & Repair
   The covering of an asbestos containing material which a bridging or penetrating encapsulating agent or covering the asbestos containing material with a wettable canvas material impregnated with a latex encapsulating agent. 
   
5. Asbestos Enclosure
   The physical enclosure of the asbestos containing material on the area where the material is present with a hard permanent barrier. The insulated vertical heating risers located behind exterior/perimeter walls and above hard plaster Ceilings may be considered to be enclosed if the walls are not demolished or otherwise penetrated.
   
6. Asbestos Containing Material
   (by NYCDEP) any material that has been determined by laboratory testing to contain 1% or greater asbestos. 
   
7. Asbestos Removal Project
   The physical removal of asbestos containing materials by a licensed Contractor employing trained and licensed personnel and following the applicable regulations. 
   
8. Friable/Non-Friable
   (by NYCDEP) any asbestos or ACM that can be crumbled, pulverized, or reduced to powder when dry, by hand or other mechanical pressure. 
   
9. Operations and Maintenance Program
   A program which addresses the in-place management of asbestos containing materials to insure compliance with all regulatory programs and protect human health (involves periodic re-inspection and air sampling). 
   
10. PCM
    Phase contrast microscopy is the standard approved method for analysis of "asbestos in air" samples. 
    
11. PLM
    Polarized light microscopy is the standard approved method for analysis of "asbestos in bulk" samples. 
    
12. TEM
    Transmission electron microscopy is the "state of the art" (lowest achievable detection limit) method for analysis of "asbestos in air and bulk samples". 
13. VAT
    Non-friable vinyl asbestos containing floor tile. 
14. NYC DEP ACP-7 "Asbestos Project" Notification Form.
    An ACP-7 must be completed and submitted to the NYC DEP Asbestos Control Department at least seven working days in advance of asbestos abatement projects involving 25 linear/10 square feet or greater of friable ACM per level (in addition, for large projects, the project must be filed with the NYS DOL and EPA NESHAPS division at least 10 calendar days from the start date of the abatement project). 
    
15. NYC DEP ACP-5 "Not an Asbestos Project" Notification Form
    An ACP-5 form has multiple applications; non- friable transite and floor tile as well as "minor" quantities of friable ACM (less than 25 linear/10 square feet) of friable ACM may be removed under an ACP-5; an ACP-5 is also used to provide documentation that, while ACM may be present, it will not be impacted during a renovation project. An ACP-5 form must be signed and stamped by a licensed NYC Asbestos Investigator.

IV. Notification ("Hazard Awareness") for In-House Personnel

a. Definition of asbestos exposure
According to OSHA regulations and in-house bargaining unit contractual agreements, all employees who have been exposed to asbestos shall be notified in writing. It should be emphasized that the term "exposure", by OSHA definition, denotes encountering an elevated airborne concentration (above the 0.01 fibers/cc permissible exposure limit) of a regulated substance such that inhalation is possible. The presence of the substance in the building does not necessarily constitute an exposure hazard. In the case of asbestos, under normal circumstances, only damaged ACM becomes airborne and poses an exposure hazard. According to OSHA protocol personal air sampling must be conducted in order to determine whether and actual exposure hazard exists. While the University is committed to protecting all employees from an airborne exposure hazard, this does not guarantee that all areas shall be deemed "asbestos free."

b. Emergency notification
Since uncontrolled disturbances of ACM may potentially result in the exposure of in-house personnel and other workers to airborne asbestos implementation of this policy to critical. In the event such an uncontrolled release occurs, "emergency" asbestos air monitoring and off-site analysis shall be conducted immediately by EH&S or an authorized representative. The results of such emergency testing shall be reported in writing to those persons affected and their authorized union representatives, if applicable.

c. Routine notification:
For scheduled maintenance and construction projects involving asbestos abatement work all building occupants potentially affected shall be notified in writing seven calendar days prior to the onset of abatement work. For large projects only, the results for all air sampling and analysis events shall be posted on a daily basis in the building and shall be on-file at the EH&S office available for review. Copies of final clearance air sample results shall be forwarded to authorized union representatives as required.

d. Labelling of accessible ACM:
Pursuant to the 8/10/94 "OSHA Final Rule on Occupational Exposure to Asbestos" all accessible ACM (i.e.. not enclosed above hard plaster ceilings/behind walls) shall be labelled with "asbestos hazard" labels such that the material may be avoided by Plumbers, Electricians, and other in-house and Contractor personnel.
Under the OSHA final rule, any material must be considered as ACM unless specifically tested.Go to Top

V. General Asbestos Related Considerations for Planning Construction Projects

Since many campus buildings were constructed prior to 1975, "asbestos containing" material is likely to be present and may be impacted during HVAC, structural, and other renovation projects. In order to obtain plumbing, electrical, demolition and other Building Department permits (requires ACP-5 submittal) and comply with this policy, an asbestos investigation is required.

In order to avoid delaying general construction, it is highly recommended that asbestos related phases of projects (asbestos abatement is usually always included in Phase I demolition work) be scheduled as soon as possible once the project is budgeted. If extensive interior demolition work is scheduled, enclosed/concealed ACM running behind walls and above ceilings may be exposed and should be considered in defining the scope of work.

The Asbestos Coordinator shall review the available project drawings in order to determine whether ACM may potentially be impacted.

a. Review of asbestos survey & abatement work conducted previously
Over the past ten years asbestos sampling and analysis work has been conducted for various construction and maintenance projects. The documentation for such previous survey work is available for review at the EH&S office. Upon request the Asbestos Coordinator shall search the "Asbestos Building File" for relevant information. Any information retrieved shall be reviewed for integrity and forwarded to the appropriate Facilities Project Manager and/or Department Manager. In some instances additional representative bulk sampling and analysis is required to verify the previous survey work.

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b. Asbestos building surveys/hazard assessments:
For major construction and other projects where no previous sampling and analysis data is available an asbestos survey/hazard assessment is required. Such a survey involves collection of representative bulk samples such that various materials may be classified as ACM or non-ACM. Wherever possible the locations of ACM shall be marked on a project drawing.

Protocol for asbestos building surveys
In order to accurately assess the building and follow EPA AHERA protocol for asbestos building surveys the following sample collection frequency shall be utilized for asbestos building surveys:
     3 samples per homogeneous area/material for surfaces <1000 sq.ft.
     5 samples per homogeneous area/material for surfaces 1000-5000 sq.ft.
     7 samples per homogeneous area/material for surfaces >5000 sq.ft.

For thermal system insulation (TSI) the general procedure to satisfy the above listed criteria is to collect three samples of each type of homogeneous material per mechanical room/riser area. The procedure for floor tile is self explanatory (3 samples per 1000 sq.ft. tile + mastic), however confirmatory TEM/NOB (non organically bound) analysis is required. The material type which requires the greatest number of samples to accurately characterize due to its inherent inhomogeneity and large surface area is wall and ceiling plaster. For example, plaster found on exterior and structural walls is commonly not of the same composition as interior partition wall plaster. In order to provide results which reflect this lack of uniformity a relative large number of samples are required to accurately characterize this material.

Selection of laboratory methodology
The standard methodology for analysis of "asbestos in friable bulk samples" is the PLM method. For analysis of non-friable floor tile and roofing asphalt samples the more expensive NOB/TEM method is required by the applicable regulations and shall be utilized. For analysis of wall/ceiling plaster samples the TEM analysis method shall be utilized for plaster samples which are shown by the PLM method to contain 0-5% asbestos content in order to achieve reasonable accuracy.

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Quality control samples
At the discretion of the EH&S Asbestos Coordinator and/or Director additional "blind duplicate" quality control samples may be collected and submitted to a second approved independent laboratory for analysis.

Asbestos air sampling & analysis/exposure monitoring
In addition to the bulk sampling and analysis mentioned above baseline air sampling may be specified to evaluate the hazard potential of asbestos exposure in a particular area.

Estimation of quantities and abatement costs
The estimated quantity of ACM identified and associated abatement costs shall be listed in the building survey report. Abatement Contractor estimates of quantities without verification shall not be considered acceptable for filing or budgeting purposes.

c. "Negative exposure assessments"/ACP-5's:
If, after the asbestos building file search and survey work mentioned above, it is determined that no asbestos may potentially be impacted, a "negative exposure assessment" report (as defined by the most recent OSHA regulations) shall be issued. In addition to the negative exposure assessment, an ACP-5 may be completed and filed with the Building Department as required. It should be emphasized that completion of either a "negative exposure assessment" or ACP-5 is contingent upon no disturbance of ACM for a particular project; it does not require that a building or area be "asbestos free".

d. Management of outside Contractors & sub-Contractors:
It is the responsibility of the Facilities Project Manager and/or Department Manager to insure that all outside Contractors and sub-Contractors comply with this policy and the applicable regulations. As the legal "Building Owner" Columbia University may be liable for all environmentally related incidences regardless of Contractor negligence. A statement regarding compliance with this asbestos policy should be incorporated into contracts with outside firms. Furthermore, the contracts should indicate such that non-compliance may result in withholding payments.

It is the responsibility of the University to notify outside Contractors of the presence of ACM in the areas which they work.Go to Top
VI. Procedures for Managing Asbestos Abatement Projects

a. Preparation of asbestos project specifications/selection of abatement alternative
To summarize, the most common EPA approved asbestos abatement alternatives may be described as the following:

It is the policy of the University to select the most cost effective abatement alternative. However, the need for upcoming renovation work (i.e. replacement of the HVAC system) may dictate removal as the most feasible abatement option since it does offer a permanent solution. In many circumstances it is recommended that the Project Manager solicit price quotations for several alternatives such that they may be compared.

For projects in excess of $10,000 asbestos abatement bidding specifications shall be prepared and presented at a pre-bid meeting which the Faculty and other building occupants are invited to attend. For smaller asbestos projects a brief "work plan" shall be prepared by the EH&S Asbestos Coordinator which outlines the procedures to be utilized.

In addition to asbestos abatement procedures the requirements for 3rd party air monitoring and analysis (including sampling frequency and analytical methodology) shall be outlined in the project specifications. A copy of the project specifications may be forwarded to the appropriate union representatives upon request.

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b. Selection of approved licensed Contractor and Project Monitor
If a proposal for asbestos abatement work is approved, a licensed asbestos abatement Contractor and 3rd Party Asbestos Air Monitoring Firm must be retained. Both parties shall be selected from the "Columbia Approved Asbestos Contractor List" on-file at the EH&S and Facilities Management offices. Standard Facilities Management bidding/contracting rules shall be applied to asbestos abatement projects. Sufficient time should be allotted for the contracting process since the cost of "rush" (i.e. less than 10 days notice) is substantially higher than standard projects.

c. Regulatory agency filing requirements/waiting periods
The NYC and NYS asbestos regulations clearly state that it is the abatement Contractor's responsibility to notify the appropriate regulatory agency of the impending abatement project. However, failure to file asbestos abatement projects subjects both the Contractor and the Building Owner to fines.

The filing requirements in NYC are summarized according to the following:

It should be mentioned that applicable and special variances to deviate from the regulations normally require three to six weeks to obtain. All variance applications shall be pre-approved by EH&S prior to submittal to the DEP.

Copies of asbestos project filings shall be posted in the buildings, on-file at the EH&S office, and be submitted to affected union authorized representatives.

The NYC DEP ACP-7 form must be signed and dated by the Contractor, the Building Owner Authorized Representative, and the Project Monitor.

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d. Additional air samplinq/exposure monitoring required to satisfy union contract requirements:
In addition to the asbestos air monitoring requirements specified in the applicable regulations (only require air monitoring when >10 sq./25 ln.ft. of ACM is disturbed) the University bargaining unit contract may require asbestos air monitoring when any amount of ACM is disturbed. Such additional air monitoring shall be coordinated by the EH&S office.

e. Responsibilities of Facilities Project/Construction Managers during abatement projects (see attached checklist):
In order to simplify the construction management aspects of asbestos abatement projects as much as possible an Asbestos Project Management Checklist has been prepared. The items included on the list have been shown to be "critical pathways" to achieving in successful (i.e. no DEP or other violations, content building occupants) projects in a cost effective and timely manner.

* Asbestos Project Management Checklist
In order to efficiently manage asbestos abatement projects Facilities Project and Construction Managers should confirm that the following Issues are addressed:

Bidding issues
(1) Has the abatement Contractor's scope of work been clearly defined?; the project specifications/work plan should provide clear instructions on how to conduct the project (including how the Contractor should file, what engineering controls should be used, etc.)

(2) Have the quantities of ACM, which the cost of the project is primarily based upon, been verified by someone other than the Contractor (i.e. Project Engineer, Asbestos Coordinator)?

(3) Is re-insulation of the removal substrate required by NYC Fire/Building Code?; if so, has re-insulation been included in the project bidding specifications

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Pre-project administrative issues
The following should be addressed at least 10 days prior to the start of abatement work:

(4) Selection of licensed asbestos abatement Contractor found on EH&S "approved Contractor list"

(5) Selection of licensed 3rd party asbestos air monitoring firm found on EH&S "approved Contractor list" [asbestos air monitoring is typically 15-20% of the total contract value]

(6) Has the project been filed with the NYC DEP, NYS DOL, and EPA as required?; if required, have variance applications been prepared and submitted?

(7) Have copies of the filings been forwarded to the EH&S office, the appropriate union representatives, and posted in the building?

(8) Have the appropriate Faculty been notified of the abatement project?

(9) A definite start date for abatement work must be selected (may only be amended one time without monetary penalty from the NYC DEP)

Logistical & scheduling issues
The following items should be addressed at least 24 hours to one week prior to the onset of abatement work:

(10) Has a list of emergency phone/beeper numbers been prepared & distributed?; the following individuals should be included:

(11) Has the Contractor provided a written work schedule; has it been distributed to EH&S , the Faculty involved, the Area Manager, etc.?Go to Top

(12) Does the Contractor have access to the space? Have arrangements been made with Security?

(13) The University is normally responsible for providing a source of water and electricity; the Contractor must identify the source and provide suitable hook-ups/panels; have such arrangements been made?

(14) Is there a service elevator available for use by the Contractor for equipment mobilization and bag-out?

(15) Is there space available for the Contractor to store equipment?

(16) For full containment abatement projects utility lines running through the work area must be de-activated including electrical, steam heat, and fire alarms; have work orders been completed to accomplish this? [failure to de-activate such lines may result in a DEP violation]

Construction phase issues
(17) Are daily air monitoring results being posted in the building, faxed to union representatives, and the EH&S Department within 24 hours of sample collection?

Failure to post results may result in a DEP violation and is a violation of the in-house union contract agreements
(18) Are asbestos hazard signs posted in appropriate locations?

(19) Is the asbestos Contractor posing a nuisance hazard to building occupants by generating excessive levels of noise, dust, chemical hazards, etc.?

(20) The Project/Air Monitor must conduct a final visual inspection and clearance air sampling prior to dismantling of the containment; such events should be documented

Project closeout issues prior to payment of Contractor & Consultant
(21) Has the landfill copy of the waste manifest been returned to the EH&S office?

(22) Has the Project Monitor's final report been submitted to the EH&S office?

(23) Has the work area sustained damages (eg. water damaged carpets, ceiling  tiles) which the Contractor should be backcharged for?

VII. Overview of Standard Removal Procedures

Depending on the size, scope, and location of the project the most feasible removal method varies. For large scale projects a Project Designer should be consulted to select the most cost effective option. For smaller projects the following general procedures should be utilized:

a. Full containment removal (for homogeneous work areas)
The full containment removal work shall be conducted according to following general sequence of events:

1. Restrict area and post asbestos hazard signs
2. Construct "attached" worker decon
3. Seal off all outside openings (isolation/critical barriers)
4. Pre-clean work area
5. Cover walls, floor, ceiling, and immovable objects with poly sheeting
6. Conduct gross removal/lst phase cleaning
7. Conduct 2nd phase cleaning after required waiting period
8. Conduct 3rd phase cleaning after required waiting period
9. Bag-out asbestos waste
10. Conduct final inspection (Project Monitor)
11. Conduct final clearance air sampling (Project Monitor)
12. Encapsulate all surfaces in containment
13. Dismantle containment
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b. Use of glovebag with tent procedure (for "spot removal of pipe insul.)
For removal of pipe insulation at multiple locations (less than 1000 ln.ft. per level) the glovebag with tent method of abatement shall be utilized.

Glovebag with tent removal projects shall be conducted according to the following general sequence of events:

c. Removal of "asbestos containing" floor tile (VAT)
In NYC non-friable VAT may normally be removed under an ACP-5 according to the following general sequence of events:

If the project cannot be conducted under an ACP-5 (i.e. quantity exceeds 10,000 sq.ft.) the full containment method if abatement must be utilized as described above.

VIII. In-Place Management of ACM/O&M Programs

If, upon visual inspection, the ACM is found to be intact (i.e. outer covering not broken, good adherence to substrate) and for non-friable materials such as floor tiles in-place management is a feasible abatement option since the material is not likely to pose an airborne asbestos hazard. ACM which has sustained minor damage and undergoes wrap & repair shall be included in the O&M program. For damaged ACM in-place management is not an acceptable abatement option.

To utilize in-place management an ongoing O&M program including the following general elements must be instituted:

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IX. Asbestos Emergency Response Plan

In the event of an unexpected event such as a pipe break, building collapse, or flood where ACM may potentially be impacted and released to the ambient air the Asbestos Coordinator shall be contacted by pager and proceed to the site immediately.

Fires and medical emergencies take precedence over asbestos exposure and shall be addressed by the appropriate emergency personnel first. Fire and other emergency rescue personnel shall not be prohibited from entering an area, however, they will be advised on proper decontamination procedures. After such issues are resolved the Asbestos Coordinator shall evaluate whether a potential asbestos hazard exists. If such a hazard does exist the area shall be closed to public access pending emergency air sampling, off-site analysis, and possible emergency abatement action.

In the event an asbestos waste bag ruptures in route from the asbestos work area to the hauling truck the abatement Contractor shall be liable for clean-up including immediate containment of the spill and decontamination of all affected surfaces. The area around the spill shall be immediately cordoned off under the direction of the Asbestos Coordinator. Emergency air sampling shall then be arranged by the Asbestos Coordinator to determine if an airborne exposure hazard exists.

An Emergency contact list with names, beeper #'s, and phone #'s is available at  the EH&S office.

X. Asbestos Emergency Procedures

The following are procedures for emergency response action in the case of an asbestos fiber release on campus, either during the course of abatement or during normal, everyday activities.

1. Upon loss of negative pressure or electric power to the negative pressure exhaust during abatement activities.

2. Upon discovery of damage and defects in the decontamination enclosure system/or plastic barriers during an abatement project.     
3. For barrier disturbance, loss of engineering controls for tent/glovebag procedures during abatement.
4. ACM debris found during the course of normal, daily activities (non-abatement)

A.  Upon loss of negative pressure or electric power to the negative pressure exhaust during abatement activities:  Abatement shall stop immediately and shall not resume until power is restored and negative pressure ventilation equipment is operating again.  When power failure or loss of negative pressure equipment lasts or is expected to last longer than one-half hour:

1. The make-up air inlets shall be sealed airtight, and
2. The decontamination systems shall be sealed airtight after the evacuation of workers and/or authorized visitors from the work area, and
3. All adjacent areas shall be monitored for asbestos fiber concentration upon discovery of, and subsequently throughout, the power failure, and
4. The Asbestos Coordinator or representative shall be notified of the power outage, and
5. Areas outside the barriers shall be monitored for asbestos contamination by TEM air sampling, at the discretion of the Asbestos Coordinator or representative.
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B. Upon discovery of damage and defects in the decontamination enclosure system/or plastic barriers during an abatement project:

1. At any time during the abatement activity, if visible emissions are observed, or elevated asbestos fiber counts outside the work area are measured, or if damage occurs to barriers, abatement shall stop.
2. The source of the contamination shall be located, the integrity of the barriers shall be restored, and
3. Visible residue shall be cleaned up using appropriate HEPA vacuuming and wet cleaning procedures immediately, and
4. The Asbestos Coordinator or representative shall be notified of the situation, and
5. Areas outside the barriers shall be monitored for asbestos contamination by TEM air sampling, at the discretion of the Asbestos Coordinator or representative.

C. For barrier disturbance, loss of engineering controls for tent/glovebag procedures during an abatement:

1. The enclosed surfaces shall  be wet cleaned using rags, mops or sponges, and
2. Be permitted sufficient time to dry, prior to HEPA vacuuming all substrates, and
3. Be lightly encapsulated to lockdown residual asbestos, and
4. The Asbestos Coordinator or representative shall be notified of the situation, and
5. Areas outside the tent shall be monitored for asbestos contamination by TEM air sampling, at the discretion of the Asbestos Coordinator or representative.

D. ACM debris found during the course of normal, daily activities (non-abatement):

1. Isolation  barriers and negative pressure exhaust will be constructed as per the Asbestos Coordinator or representative, and
2. The area to be cleaned by HEPA vacuuming and wet methods will be determined, by the Asbestos Coordinator or representative, and
3. TEM air sampling shall be used to determine the initial exposure count as per the Asbestos Coordinator, and
4. PCM air sampling shall be sufficient during clean up activity, but
5. The area will be closed until clearance by TEM air sampling, as per the Asbestos Coordinator.