Asbestos Abatement Program
01. POLICY STATEMENTS
01.01 In a good faith effort to comply with federal and state regulations and in consideration of the health and safety of the campus community and its visitors, Facilities must assess and authorize all facility modifications, remodeling, renovations, demolition and new construction contracts related to buildings, structures or furnishings, and any repairs to existing facilities or furnishings at Texas State University-San Marcos.
01.02 A published asbestos policy is a required condition to meet Texas Asbestos Health Protection Rules promulgated by the Texas Department of State Health Services (TDSHS) and comply with all federal standards referenced in Section 02. This policy describes standard operating procedures with which Facilities must comply when accomplishing abatement projects. An Asbestos Operations and Maintenance (O&M) Contractor-Restricted License is required to conduct asbestos abatement activities with Facilities staff.
02. REFERENCES FOR MANDATORY COMPLIANCE
02.01 In order to establish a policy that insures full compliance with state and federal regulations, the university adopts the following publications for reference. Compliance with the requirements of the referenced regulations is mandatory.
f. 29 CFR 1926.58, Occupational Safety and Health Administration (OSHA) Construction standard, Asbestos, Tremolite, Anthophylite, and Actinolite, with specific reference to Appendix G, Work Practices and Engineering Controls for Small Scale, Short Duration Asbestos Renovation and Maintenance Activities
03.01 Asbestos Containing Materials (ACM) – Materials containing more than 1% asbestos fibers from analysis by a laboratory licensed or registered with the TDSHS. Analysis is determined using polarized light microscopy (PLM). Cement products, acoustical plaster, fireproofing textiles, wallboard, ceiling tiles, vinyl floor tiles, thermal insulation, roofing felts, caulking and other materials may contain asbestos.
03.02 Asbestos Abatement – An approved method for handling asbestos containing materials (i. e., removal, encapsulation, enclosure). Persons must possess an appropriate license or registration from the TDSHS to engage in asbestos abatement or any asbestos-related activity.
03.03 Asbestos O&M Contractor-Restricted License – A license, issued by the TDSHS, Occupational Health Division, that is required to engage in any removal or encapsulation of asbestos materials for maintenance or repair purposes within any building according to its public access category or occupancy type.
03.04 Resilient Floor Covering Certification – Personnel certified by the Resilient Floor Covering Institute (RFCI) may remove resilient flooring containing asbestos under special circumstances.
03.05 Operations and Maintenance Program (O&M) – A program which addresses the in-place management of asbestos-containing materials to insure compliance with all regulatory programs and protected human health (involves periodic re-inspection and air sampling).
04. PROCEDURES FOR PROJECT AUTHORIZATION
04.01 All university departments must submit a written request for project authorization to the director of Facilities Management prior to commencing with any activities outlined in this policy as referenced in Section 01.01.
04.02 All Facilities personnel will contact the director of Facilities Management prior to commencing with any activities outlined in this policy in Section 01.01.
04.03 Documentation will be as follows:
a. During construction, renovation or repair of a Texas State building, a TAHPA-licensed person or a Texas licensed professional engineer may compile the information from material safety data sheets (MSDS) of all products used in the building’s construction or renovation and, finding no asbestos in any of those products, prepare a signed certification that states that none of those products contain ACM; therefore, the building materials do not contain asbestos. This certification, together with the MSDS and copies of previous surveys may comprise an asbestos survey. In lieu of the above certification, a comprehensive survey for ACMs with sampling conducted by a firm licensed to analyze “suspect” ACMs to confirm or deny the presence of the ACMs can substitute for the certification.
b. The architect or owner contract specifications will require this documentation. The department overseeing the project (normally the Office of Facilities Planning, Design and Construction, or Facilities) must procure these documents.
c. The director of Facilities Management must receive this documentation before the university will accept any new or newly-renovated campus structure or facility.
05. RESPONSIBILITIES AND DUTIES
05.01 The director of Facilities Management is the person designated to meet the requirements for licensing with the TDSHS. The director of Facilities Management will authorize all operations and maintenance activities involving asbestos abatement.
05.02 The director of Facilities Management serves as the designated person for the university asbestos O&M program and assumes responsibility for the operation of the program.
05.03 Duties of the director of Facilities Management as the asbestos program administrator are to insure that the following are carried out:
a. Establish policies as needed to insure no ACM is used in new construction or newly-renovated facilities;
b. Survey to determine if asbestos is present;
c. Establish a special O&M program;
d. Conduct and administer small scale, short duration abatement actions if necessary;
e. Maintain all building records for the asbestos program;
f. Interpret asbestos building surveys;
g. Propose a written action schedule for asbestos control in facilities; and
h. Advise clients for O&M or asbestos abatement in accordance with applicable regulations.
05.04 Asbestos O&M Supervisor - Restricted – All operations and maintenance asbestos abatement projects will be under the direct supervision of the Crew Supervisor, Steam Distribution. Supervisors will insure compliance with personal protective equipment, handling procedures, and equipment installation as specified in the referenced regulations.
05.05 Asbestos abatement workers will comply with specified regulations and follow prescribed procedures as outlined in this policy statement and as trained. Asbestos abatement workers will report to the project supervisor any known or perceived violation of abatement procedures. Workers certified for removing resilient floor covering may remove the resilient floor covering.
05.06 Environmental Health, Safety, and Risk Management (ESHRM) identifies potential or existing hazards and provides recommendations to Facilities when repairs or renovations could impact ACM. ESHRM will identify the need for bulk or air sampling.
06. REQUIREMENTS FOR TRAINING
06.01 Prior to undertaking removal or encapsulation of asbestos containing materials, repairs, maintenance, or other asbestos-related activity, personnel must receive training in accordance with TAHPA rules and regulations.
06.02 Facilities sections who have a need to qualify personnel as asbestos workers will request qualification requirements through the Facilities training coordinator who will maintain training, physical examination, and state licensing records.
06.03 All university departments who employ personnel or students who may perform tasks as those described in Section 01.01 of this policy or who perform service or maintenance on university facilities as part of their job duties must be included in the Facilities Asbestos Awareness Program. The program includes asbestos awareness training for new employees as part of their orientation process and awareness refresher training annually. Departments affected are to contact the Facilities training coordinator at (512) 245-8042 to schedule training for their employees.
07. REQUIREMENTS FOR REGISTRATION AND LICENSING
07.01 Facilities will maintain an Asbestos O&M Contractor-Restricted License from the TDSHS. Annual renewal of the Asbestos Management Planner License, Supervisor Licenses, and Workers Registration will be coordinated through the Facilities training coordinator.
08. PROCEDURES FOR RECORDKEEPING
08.01 The Facilities Administration Office will maintain asbestos records for thirty years after separation with Texas State unless otherwise specified. The university will, as a minimum, maintain the following records:
a. For each project, a complete record will show:
1) Name of project supervisor;
2) Location and description of operations;
3) Description of abatement procedures;
4) Description of personal safety practices;
5) Name and address of disposal site;
6) Dates of participation; and
7) Roster of registered asbestos workers employed.
b. A copy of each violation and make them available to the Environmental Protection Agency (EPA) or the TDSHS upon request.
c. All licenses and registrations of supervisors and workers.
d. Records of the Respiratory Protection Program.
e. Medical surveillance records for all supervisors and asbestos workers (maintained thirty years after termination of employment).
f. Training records reflecting compliance with regulated requirements (maintained for one year after termination of employment).
09. REVIEWERS OF THIS POLICY
09.01 Reviewers of this policy include the following:
University Safety Committee
University Safety Committee Chairman
Director, Facilities Management