The information in today’s Advisor comes from our sister publication, Environmental Daily Advisor.
Commercial buildings that contain any of the many forms of asbestos-containing materials (ACM) used in construction pose challenges to owners and managers. When overseeing the day-to-day O&M management of ACMs in the workplace, there are two primary areas of training that must be considered:
- The Occupational Safety and Health Administration (OSHA) regulations at 29 CFR 1910.1001 and
- The Environmental Protection Agency’s regulations at 40 CFR Part 763.
The OSHA regulations require a worker training program for employees exposed to fiber levels (either measured or anticipated) at or above the permissible exposure limit (0.1 fibers per cubic centimeter (f/cc) as an 8-hour, time-weighted average (TWA) and/or the excursion limit (1.0 f/cc as a 30-minute TWA), except for workers in construction and shipbuilding who are covered under separate regulations. This training program consists of an initial training period, the duration of which is determined by the type of work the employee performs, and annual refresher training.
The EPA’s regulations were written specifically for managing asbestos in schools, however, the agency highly recommends all building owners and operators use the regulations when determining how best to manage on-site, in-place ACM. Specifically, when training for operations and maintenance workers not involved in major renovation or demolition projects, there are two levels of training that should be considered, implemented, and maintained.
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Type 1 is Awareness Training that should be provided to custodial and maintenance staff who perform general tasks such as cleaning, minor repairs, and other small projects that could accidently expose them briefly to the ACM. This is commonly known as Two-Hour Awareness Training and normally includes a range of topics, including:
- Basic information about asbestos and the ACM
- The health impacts associated with ACM exposure
- Different worker protection programs
- An overview of the locations of the ACM in the building or buildings they work within
- How to recognize damaged and/or deteriorated ACM
- The O&M Program for the building or buildings they work within
Type 2 is Special O&M Training that is considerably more extensive and is for O&M workers that will be exposed to the ACM while conducting their general job duties such as maintenance and repair of the ACM. Examples of this type of work might include repairing or replacing a small section of damaged insulation or installation of equipment in an area where the ACM is already known to be present.
Special O&M Training generally lasts about 14 hours and includes all of the information contained in Awareness training as well as the following:
- A review of applicable federal, state, and local asbestos regulations;
- Best practices for ACM-related work;
- How to properly handle the ACM, including methods for waste handling and disposal;
- How to use a respirator, including equipment care and fit testing;
- Appropriate protective clothing donning, care, and disposal practices;
- Hands-on exercises for proper use, care, and maintenance of such things as glove bags and HEPA vacuums; and
- Explanations of proper and appropriate decontamination procedures.
Unlike Type 3 Abatement Worker Training, which is highly specialized and accredited by the EPA or a state, Awareness and Special O&M Training can be provided by a company’s Asbestos Program Manager (APM) if he or she has the knowledge and education necessary. As an alternative, an outside training provider can be used, although in all cases, the respirator training portion should be provided by either an industrial hygienist or a trained and accredited asbestos professional. In addition, the health effects training should also be provided by a health professional.
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