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For owners and operators of commercial buildings, staying on top of asbestos training can be time consuming confusing and costly. In addition to Occupational Safety and Health Administration regulations to protect workers, the Environmental Protection Agency (EPA) also has numerous regulations designed to address asbestos-containing materials (ACM) management.
Due to the many considerations building operators must be aware of when coordinating ACM training for workers such as custodians and maintenance staff, the EPA recommends implementing an O&M Program as one way to manage ACM in place. These recommendations are not intended for asbestos abatement workers, but ONLY for workers that have may accidently or incidentally be exposed to asbestos during their regular work.. The EPA defines three types of work that are appropriate for an O&M Program:
- Work that is not likely to involve direct contact with ACM, such as routine cleaning of surfaces where ACM is not present.
- Work that may cause accidental disturbance of ACM, such as routine maintenance work in an area that may have ACM like areas above suspended ceilings.
- Work that involves relatively small, short-term disturbances of ACM, such as when repairing a pipe in a boiler room or changing light fixtures.
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If these three factors apply, an O&M Program can be created with the following components:
- Appointment of an Asbestos Program Manager (APM) with appropriate authority, knowledge and education to oversee all ACM-related activities including training. EPA recommends The Asbestos Program Manger be EPA accredited under the Asbestos Hazard Emergency Response (AHERA) or state certified as a Building Inspector/Management Planner.
- Develop an Asbestos Policy for the company.
- Have the building inspected by an accredited inspector including sampling and analysis of suspect material, an ACM inventory, and assessment of ACM condition and potential for disturbance.
- Create the O& M Plan based on inspection findings (if large-scale ACM work is required, this work must be performed by trained and accredited asbestos abatement professionals).
When creating the O&M Program, EPA maintains it should include not only staff, but also subcontracted custodial and maintenance workers and contractors such as electricians and plumbers that could conceivable become exposed to ACM in the building. To accomplish this, EPA recommends the O&M Program contain a “work permit system” that requires contractors to obtain a permit from the APM prior to commencing work in the building. This provides the APM with the opportunity to inform the contractor of ACM exposure potential as well as special instructions to minimize exposure and ensure the work is performed appropriately.
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The O&M Program should also contain provisions for periodic notification of building tenants and EPA encourages APMs to consider requiring by legal agreement or understanding, that tenants notify the APM prior to beginning even small renovations that could result in disturbing ACM and subsequent exposure. Moreover, the O&M Program should include steps to be taken when a renovation or remodeling activity is upcoming to assess potential exposure to ACM. These should include review of original inspection records and sampling analysis, re-inspection and additional sampling and analysis if necessary, and a means of ensuring no new ACM is introduced to the building during the work.
In the event that ACM must be removed before a remodeling or renovation activity, additional steps will be required. According to the Asbestos National Emissions Standards for Hazardous Air Pollutants (NESHAP) ACM removal is required for projects that would break up at least 160 square feet of surfacing or miscellaneous material, at least 260 linear feet of material on pipes, or at least 35 cubic feet on facility components not measured prior to stripping. Again this level of ACM management requires accredited asbestos abatement professionals and should not be performed by O&M staff.