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 (ACMs) 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 ACMs in place. These recommendations are not intended for asbestos abatement workers, but ONLY for workers who may have accidently or incidentally been 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 the ACM, such as routine cleaning of surfaces where the ACM is not present.
- Work that may cause accidental disturbance of the ACM, such as routine maintenance work in an area that may have the ACM, like areas above suspended ceilings.
- Work that involves relatively small, short-term disturbances of the 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. The EPA recommends the asbestos program manager be EPA-accredited under the Asbestos Hazard Emergency Response (AHERA) or state-certified as a building inspector/management planner.
- Developing an Asbestos Policy for the company.
- Having 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.
- Creating 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, the EPA maintains it should include not only staff but also subcontracted custodial and maintenance workers and contractors such as electricians and plumbers who could conceivably become exposed to the ACM in the building.
To accomplish this, the EPA recommends the O&M Program contain a “work permit system” that requires contractors to obtain a permit from the APM before 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 the EPA encourages APMs to consider requiring by legal agreement or understanding, that tenants notify the APM before beginning even small renovations that could result in disturbing the ACM and subsequent exposure.
Moreover, the O&M Program should include steps to be taken to assess potential exposure to the ACM when a renovation or remodeling activity is coming up. These should include review of original inspection records and sampling analysis, reinspection 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 the 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 before stripping. Again, this level of ACM management requires accredited asbestos abatement professionals and should not be performed by O&M staff.
In tomorrow’s Advisor, we will consider training requirements for applicable O&M workers, plus we’ll present an effective online training resource with courses on dozens of key environmental compliance topics.