COMPLIANCE IS MANDATORY

Ames Safety and Health Manual

Chapter 30 - Asbestos Management Plan

30.1 Overview

The impetus for compiling the NASA Ames Asbestos Management Plan derives from the need to comply with over seven major governmental regulations and guidance documents published by governmental institutions. The NASA Ames Asbestos Management Plan is an effort to streamline these compliance documents into a logical and economically efficient plan. The Ames Asbestos Management Plan integrates applicable Federal, State, and local regulatory agency requirements and NASA policy governing asbestos-related work. It addresses any operation, including maintenance activities, involving potential or actual disturbance of materials that contain asbestos.

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30.2 References

NASA ARC adheres to and enforces this policy and all applicable Federal, State, and local governing regulatory agency laws/guidelines pertaining to asbestos-containing materials and asbestos-related work, including:

1. U.S. Department of Labor, Occupational Safety & Health Administration (OSHA)

2. U.S. Environmental Protection Agency (EPA)

3. Bay Area Air Quality Management District (BAAQMD) Regulation #11, Rule #2 - Asbestos
4. California Labor Code Sections 6501.5, 6501.7, 6501.8, and 6505.5
5. California Code of Regulations (CCR)

6. American National Standards Institute (ANSI)
7. Fundamentals Governing the Design Operation of Local Exhaust Systems (ANSI, Z.9.2)
8. National Electrical Code
9. National Plumbing Code
10. California Business & Professions Code Section 7058.5
11. ASTM Standard 1368-03 Standard Practice for Visual Inspection of Asbestos Abatement Projects

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30.3 Definitions

1. Abatement: Any operation that is designed to permanently remove asbestos-containing materials.

2. Aggressive Method: Removal or disturbance of building material by sanding, abrading, grinding, or other method that breaks, crumbles, or disintegrates intact asbestos-containing material (ACM).

3. Asbestos: Six fibrous magnesium silicate minerals: chrysotile, crocidolite, amosite, and the fibrous forms of actinolite, tremolite, and anthophyllite.

4. Asbestos-Containing Material (ACM): Any material that contains more than one-tenth of one percent of asbestos.

5. Asbestos-Related Work: Any work that involves asbestos-containing material and may result in the release of any quantity of asbestos fibers into the air.

6. Authorized Person: Any person authorized by the employer and required by work duties to be present in regulated areas. An authorized person shall have at least a two-hour orientation on the hazards of asbestos along with a medical exam and respirator training.

7. Category I Nonfriable Asbestos-Containing Material: Asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing products.

8. Category II Nonfriable Asbestos-Containing Material: Asbestos-containing material, excluding Category I nonfriable asbestos-containing material, that, when dry and in its present form, cannot be crumbled, pulverized, or reduced to powder by hand pressure (Transite Trademark (TM), cement products, stucco).

9. Certified Asbestos Consultant (CAC): Any person who contracts to provide professional health and safety services that relate to asbestos-containing construction material that comprises 100 square feet or more of surface area. The activities of an asbestos consultant include building inspection, abatement project design, contract administration, sample collection, preparation of asbestos management plans, clearance monitoring, and supervision of site surveillance technicians.

10. Certified Industrial Hygienist (CIH): An individual certified in the comprehensive practice of industrial hygiene by the American Board of Industrial Hygiene.

11. Class I Asbestos Work: Activities that involve the removal of Thermal System Insulation (TSI) and surfacing ACM and Presumed ACM (PACM).

12. Class II Asbestos Work: Activities that involve the removal of ACM that is not TSI or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.

13. Class III Asbestos Work: Repair and maintenance operations where ACM, including TSI and surfacing material, is likely to be disturbed. If the amount of ACM or PACM disturbed is likely to exceed that which can be contained in one glove bag or waste bag no larger than 60 inches square the disturbance becomes classified as Class I work.

14. Class IV Asbestos Work: Maintenance and custodial activities during which employees contact, but do not disturb, ACM or PACM, and activities to clean up minimalwaste and debris that contains ACM or PACM - (must not exceed the OSHA PEL or EL. If work is expected to release airborne asbestos fibers, which may cause the employee exposure in excess of the OSHA PEL or EL, work must be considered Class III work. The Safety Office shall determine this potential.)

15. Clean Room: An uncontaminated room that has facilities for the storage of employees' street clothing and uncontaminated materials and equipment.

16. Competent Person/Certified Supervisor: An individual who is capable of identifying asbestos hazards in the workplace and who has sufficient experience, training, and authority to take prompt corrective measures to eliminate them.

17. COTR: Contracting Officer's Technical Representative.

18. Critical Barriers: One or more layers of at least six-mil-thick fire-retardant polyethylene sheeting sealed over all openings into a work area or any other similarly placed physical barrier sufficient to prevent airborne asbestos in a work area from migrating to an adjacent area.

19. Decontamination Area (D-Con): An enclosed area adjacent and connected to the regulated area and consisting of an equipment room, shower area, and clean room, which is used for the decontamination of workers, materials and equipment that are contaminated with asbestos.

20. Demolition: Any operation that involves the wrecking or removal of any load-supporting structural members of a facility.

21. Demolition/Renovation Surveys: A survey conducted by an EPA-accredited asbestos building inspector to check for the presence of asbestos-containing materials prior to any demolition/renovation activities.

22. Disturbance: Contact with any material that contains ACM or PACM that causes release of fibers. This term includes activities that disrupt the matrix of ACM or PACM, render ACM or PACM friable, or generate visible debris. Disturbance includes cutting away small amounts of ACM and PACM.

23. Emergency Demolition: Demolition carried out pursuant to an order of a State or local Government agency because the building is structurally unsound and in danger of imminent collapse.

24. Emergency Renovation: Renovation that is not planned but results from a sudden, unexpected event. This includes operations necessitated by equipment failures and unanticipated findings of ACM or the conversion of previously nonfriable ACM to friable material during the course of a renovation. Renovations due to fire, water, or earthquake damage, or where an imminent danger to the public health may exist, are included.

25. Employee Exposure: The exposure to airborne asbestos that occurs or would occur - if the employee were not using respiratory protective equipment.

26. Encapsulation: A method that utilizes sealers, paints, or special bridging/encapsulating compounds to control airborne asbestos fibers.

27. Enclosure: An airtight, impermeable, permanent barrier constructed to surround asbestos-containing materials and prevent the release of asbestos fibers into the air.

28. EPA-Approved Building Inspector: An individual who has successfully completed an EPA-approved building inspector course for collecting asbestos bulk samples and conducting AHERA quality surveys. An EPA building inspector is not a construction inspector; primary responsibilities include collecting bulk samples for asbestos analysis and conducting surveys for asbestos.

29. Fiber: A particulate form of asbestos, 5 micrometers or longer, with a length-to-diameter ratio of at least 3-to-1.

30. Friable Asbestos-Containing Material: Any material that contains more than one-tenth of one percent asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

31. High Efficiency Particulate Air (HEPA) Filter: A high-efficiency particulate air filter capable of removing particles 0.3 micrometers in diameter or larger with 99.97-percent efficiency.

32. Homogenous Area: An area of surfacing material or thermal system insulation that is uniform in color and texture.

33. Intact: ACM that has not crumbled, been pulverized, or otherwise deteriorated so that it is no longer likely to be bound with its matrix.

34. PEL: Permissible Exposure Limits established by the Occupational Safety and Health Administration. According to OSHA, the employer shall ensure that no employee is exposed to a airborne concentration of asbestos in excess of 0.1 fiber per cubic centimeter (f/cc) of air as an eight (8) hour time-weighted average (TWA), as determined by the National Institute of Occupational Safety and Health (NIOSH) method 7400 Phase Contrast Microscopy (PCM). In addition, the employer shall ensure that no employee is exposed to an airborne concentration of asbestos in excess of 1.0 f/cc as averaged over a sampling period of 30 minutes, as determined by NIOSH method 7400 PCM, known as the excursion limit (EL).

35. Presumed Asbestos-Containing Material (PACM): All thermal system insulation and spray-on or troweled-on surfacing materials in buildings or substrates constructed before 1980, and all resilient flooring material including associated mastic and backing, regardless of age, shall be identified as asbestos-containing, unless an industrial hygienist or certified asbestos consultant determines that it is not ACM using recognized techniques.

36. Regulated Asbestos-Containing Material (RACM):

• Friable asbestos-containing material,
• Category I nonfriable ACM that has become friable,
• Category I nonfriable ACM that will be or has been ground, sanded, cut, or abraded, or
• Category II nonfriable ACM that has a probability of becoming or that has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by the asbestos NESHAP.

37. Removal: All operations where ACM and/or PACM is taken out or stripped from structures or substrates, including demolition operations.

38. Renovation: Any operation that involves altering a facility or one or more facility components in any way.

39. Surfacing Material: Material that is sprayed, troweled-on, or otherwise applied to surfaces (such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, and other purposes).

40. Thermal System Insulation (TSI): ACM applied to pipes, fittings, boilers, breaching, tanks, ducts, or other structural components to prevent heat loss or gain.

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30.4 Responsibility

30.4.1 Safety Health and Medical Services Division

1. Oversee development and implementation of the Ames Asbestos Management Plan.
2. Provide Certified Asbestos Consulting services for asbestos-related work activities as requested. This service will be implemented on a budget-reimbursable basis to the Center.
3. Review and evaluate the impact of regulatory changes on the Center.
4. Review and evaluate asbestos-abatement plans, specifications, and abatement contractor submittals prior to abatement.
5. Verify that personnel who perform asbestos abatement work on NASA property have appropriate training and credentials to perform their assignment.
6. Approve the selection of accredited laboratories used to analyze asbestos bulk/air samples.
7. Determine the need for baseline air monitoring in occupied buildings.
8. Periodically inspect the abatement area and contractor/subcontractor for compliance with the Ames Asbestos Management Plan.
9. Establish criteria for post-abatement clearance testing and approve re-occupancy of buildings/areas upon successful clearance testing.
10. Maintain a central location for all asbestos management documentation.

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30.4.2 Health Unit

1. With the exception of incidentally exposed employees, provide pre-placement, periodic, and termination of employment medical examinations to Ames employees who are or may be exposed to asbestos as required by Cal-OSHA and NASA Headquarters Environmental Health Program.
2. Offer incidentally exposed employees a complete baseline examination, but no periodic examinations.
3. Schedule Ames employees for medical examinations in accordance with Cal_OSHA initially, within 10 days of exposure or potential asbestos exposure, at least annually thereafter, and at least 30 days after termination of employment.
4. Only asbestos workers who have been exposed to airborne asbestos in excess of the permissible exposure limit (0.1 fibers/cc of air as an 8-hr. TWA), or the excursion limit (1.0 fiber/cc averaged over 30 minutes) require chest x-ray surveillance.

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30.4.3 ARC Project Managers, COTRs

1. Ensure that a survey to determine the presence, location, and quantity of asbestos-containing material has been conducted prior to the start of any work.
2. All Project Managers must be knowledgeable and competent of asbestos work procedures and plans as established in this chapter and applicable federal, state, and local regulations. At a minimum they should have completed Asbestos Awareness training.
3. Notify the Safety, Health and Medical Services Division of construction before the 30-percent design review phase, or ten days prior to maintenance related asbestos work.
4. Enforce the Ames Asbestos Management Plan before, during, and after each asbestos-related work activity, including maintenance activities.
5. Coordinate with the Safety, Health and Medical Services Division to ensure that a Certified Asbestos Consultant monitors any asbestos-related work activity.
6. Provide the Certified Asbestos Consultant with accurate drawings and relevant information depicting the locations that will be affected by any demolition/renovation or maintenance activities.
7. Ensure that all construction specification documents that relate to asbestos specify the material, quantity, type, and location(s) of any asbestos-containing material to be removed.
8. Provide notification to all building occupants prior to all asbestos-related work conducted in occupied buildings.
9. Ensure that the following documents are provided by the abatement contractor/subcontractor before any notice to proceed is granted. These documents should be reviewed by a Certified Asbestos Consultant for regulatory/NASA policy compliance:

10. Ensure that maintenance personnel do not enter a regulated area without proper Personal Protective Equipment (PPE) and appropriate training.
11. Ensure that asbestos removal projects are performed within a regulated area and have pre and post abatement inspections performed by asbestos trained and qualified personnel. For all asbestos removal projects located within an interior of a building, a final clearance will be performed to ensure area is safe to reoccupy.
12. Ensure when Class 1 work is performed by Negative Pressure Enclosure (NPE) metod that all negative air-pressure manometer recordings are provided.
13. Ensure that all personnel air monitoring and/or perimeter air monitoring conducted is provided to original laboratory reports and negative air-pressure manometer records are provided to the Safety, Health and Medical Services Division.
14. Ensure that any contractors/subcontractors conducting asbestos-related work on NASA property receive a copy of the Ames Asbestos Management Plan and sign a letter of receipt. Ensure that this document is incorporated as part of the required bid documents for each bidder.
15. Ensure that copies of all asbestos-related work documents are available, upon request, to the Safety, Health and Medical Services Division.
16. Ensure all waste is handled and disposed in accordance with the Ames Environmental Procedural Requirements.
17. Ensure all work within a regulated area complies with Ames Health and Safety Procedural Requirements chapters that may apply.
18. Notify the Safety, Health and Medical Services Division if previously unidentified suspect asbestos containing material is discovered, or the scope of the project changes.

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30.4.4 Facilities Engineering Branch

The Facilities Engineering Branch shall maintain an up-to-date specification to be included in bids for projects that involve asbestos-related work.

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30.4.5 Acquisitions Office

1. Require all contracts associated with asbestos-related work to include a copy of the appropriate specification for asbestos-related work and this entire document.
2. Require, as part of the bid documents, a signed letter from the contractor/subcontractor stating they have read and understand the Ames Asbestos Management Plan.
3. Ensure that notification is provided to prospective employers (successful bidders) of the presence, location, and quantity of ACM or PACM at worksites in NASA buildings and facilities. Prospective employers include those employers whose employees reasonably can be expected to work in or adjacent to areas that contain such material.

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30.4.6 Certified Asbestos Consultants

1. Monitor compliance to the Ames Asbestos Management Plan.
2. Conduct bulk/air sampling as requested by the Safety Office and present findings in a user-friendly format.
3. Assist in planning asbestos abatement projects by reviewing and commenting on bids, specifications, and procedures.
4. Review contractor/subcontractors submittals for compliance with the Ames Asbestos Management Plan.
5. Act as ARC primary health and safety contact for inspection and compliance concerning asbestos-related work activities.
6. Conduct pre-and post-asbestos-abatement inspections.
7. Conduct daily inspections on asbestos-abatement projects, including cleanup operations, and document these inspections (see Appendix B section 30.14.2). Notify the project manager and contracting officer of any contractor/subcontractor deficiencies. Should any deficiency pose an imminent safety and health hazard, the consultant may stop the project and immediately follow up with the project manager and contracting officer.
8. Determine final clearance criteria. If the Transmission Electron Microscopy (TEM) method is utilized, a minimum volume of 1199 liters must be collected. The results must be 70 structures per square millimeter (str/mm2) or below to meet clearance criteria. Prior approval from the Ames Safety Office must be granted if the Phase Contrast Microscopy (PCM) method is utilized, and the results must be below 0.01 fibers per cubic centimeter (f/cc) to meet clearance criteria.
9. Written documentation must be provided certifying that area(s) meet the clearance criteria set forth in the Ames Asbestos Management Plan. This documentation must be provided for any final visual inspection and final clearance sampling conducted (see Appendix E section 30.14.5).
10. Conduct area air monitoring on asbestos-abatement projects, as requested by the project manager or NASA Safety Office. Prior to conducting area monitoring, background monitoring should be conducted.
11. All laboratories utilized to perform asbestos analysis and relied upon to supply NASA with results must be American Industrial Hygiene Association (AIHA)-accredited and a successful participant in the Proficiency Analytical Testing Program (PAT). Where asbestos bulk sampling or TEM analysis is required, the laboratory must be accredited by the National laboratory of Science and Technology (NIST) under the National Voluntary Laboratory Accreditation Program (NVLAP) for asbestos analysis.

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30.4.7 General Contractors Involved in Asbestos-Related Work

1. Exercise supervisory authority over all work covered by this chapter. As supervisor of the entire project, the general contractor shall comply and require all subcontractors to comply with the Ames Asbestos Management Plan, and all applicable regulatory requirements.
2. Notify the NASA project manager immediately upon discovery of any previously unidentified suspected asbestos-containing material or other material with possible hazards or undetermined contaminants.

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30.4.8 Asbestos Abatement Contractors/Subcontractors

1. Adhere to the Ames Asbestos Management Plan, and all Federal, State, and local regulatory agency laws/guidelines that pertain to asbestos. Any deviations from the Ames Asbestos Management Plan must have the approval of NASA Safety Office and the NASA project manager.
2. All asbestos-related work, unless directed by the NASA Safety Office, shall be conducted under the surveillance of a Certified Asbestos Consultant who is independently procured and financed by ARC or who is a representative of the NASA Safety Office.
3. On multiemployer worksites, a contractor who performs work that requires the establishment of a regulated area shall inform other employers on the site of the nature of the employer's work with asbestos and/or PACM, of the existence of the requirements that pertain to regulated areas, and the measures taken to ensure that employees of the other employer are not exposed to asbestos.
4. Asbestos hazards at the contractor's/subcontractor's worksite shall be abated by the contractors/subcontractors who created or control the source.
5. Notify the NASA project manager immediately upon discovery of any previously unidentified suspected asbestos-containing material or PACM.
6. The following documents must be delivered to the project manager and approved before any asbestos-related work is conducted:

7. There shall be no deviations from the contractor's/subcontractor's approved health and safety plan without prior consent of the Safety Office and the NASA project manager.

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30.4.9 Competent Person/Certified Supervisor

1. Conduct frequent and regular inspections of the job sites, materials, and equipment in accordance with the site health and safety prevention program.
2. If necessary, establish the negative-pressure enclosure, ensure its integrity, and control entry to and exit from the enclosure. Ensure that all employees working within such enclosures wear the appropriate personal protective equipment and are trained in the use of appropriate methods of exposure control and use of hygiene facilities and decontamination procedures.
3. Set up procedures to control entry to and exit from the enclosures and/or area.
4. Ensure that employees use the hygiene facilities and observe the decontamination procedures required.
5. Supervise required employee exposure monitoring.
6. Ensure that engineering controls in use are in operation condition and are functioning properly.
7. Ensure proper signs are posted in the work area.

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30.5 Prohibited Asbestos-Related Work

In addition, the competent person/certified supervisor for Class I and Class II work must have successfully completed an EPA-approved training course for supervisors/contractors, and for Class III and Class IV work must be trained in an Operations and Maintenance course developed by the EPA. All EPA-approved courses require annual recertification.Prohibited Asbestos-Related Work Activities

The following work practices and engineering controls shall not be utilized for asbestos-related work, regardless of quantity, type, or operation:

1. High-speed abrasive disc saws that are not equipped with a point-of-cut ventilator or enclosures with HEPA-filtered exhaust air.
2. Compressed air, unless the compressed air is used in conjunction with an enclosed ventilation system designed to capture the dust cloud created by the compressed air.
3. Dry sweeping, shoveling, or other dry cleanup of suspected asbestos-containing material.
4. Employee rotation as a means to reduce employee exposure to asbestos.

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30.6 Procedures for Asbestos Activities

30.6.1 Basic Procedures for Asbestos Work

30.6.1.1 Basic Procedures for Class I Asbestos Work

Activities that involve the removal of TSI and surfacing ACM and PACM are considered Class I operations. This work is to be performed by asbestos abatement contractors meeting the requirements stated in 30.6.5 of this chapter, in accordance with CAL OSHA and BAAQMD regulations.

30.6.1.2 Basic Procedures for Class II Asbestos Work

Activities that involve the removal of ACM that is not TSI or surfacing material are considered Class II operations. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics. This work is to be performed by asbestos abatement contractors meeting the requirements stated in 30.6.5 of this chapter, in accordance with CAL OSHA and BAAQMD regulations.

30.6.1.3 Basic Procedures for Class III Asbestos Work

Repair and maintenance operations where ACM (including thermal system insulation and surfacing material) is likely to be disturbed are considered Class III operations (must fit in one standard glove bag or waste container <60 inches square). All Class III asbestos work shall be conducted using employees who have current 16 hour EPA) O&M training. Less training will be allowed when determined to be sufficient for a specific task by a Competent Person and approval by the Safety, Health Medical Services Division.

30.6.1.4 Basic Procedures for Class IV Asbestos Work

1. Maintenance and custodial activities during which employees contact ACM and/or PACM, and activities to clean up minimal waste and debris containing ACM and/or PACM will be considered Class IV asbestos work. (This work must not exceed the OSHA PEL or EL. If work is expected to release airborne asbestos fibers, which may cause the employee exposure in excess of the OSHA PEL or EL, work must be considered Class III work. The Safety, Health and Medical Services Division shall determine this potential.) All Class IV asbestos work shall be conducted using employees who at a minimum have current two hour Asbestos Awareness training. The work activities must be in compliance with ASHA and BAAQMD regulations.

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30.6.2 Procedures for Accidental Release of Asbestos

The following procedures must be used if asbestos is accidentally released:

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30.6.3 Emergency Demolition/Renovation Operations

Before any asbestos-related work is conducted pursuant to and classified as an emergency demolition/renovation project, the Safety, Health and Medical Services Division must be notified and the work plan and schedule must be approved by the Safety, Health and Medical Services Division.

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30.6.4 Brake/Clutch Inspection and Repair

The OSHA General Industry Standard for asbestos impacts the Automotive Repair Shop (Motorpool). OSHA standards require engineering and work practice controls during brake and clutch repair, inspection, disassembly, repair, and assembly operations on materials that contain asbestos. There are two methods that meet this requirement:

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30.6.5 Procedures for Specific Maintenance Operations

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30.6.6 TA Wire Insulation

TA wire for the purpose of repairing electrical connections is classified as Class III asbestos-related work because this work is part of a maintenance and repair operation, and disturbance will occur as an adjunct to the repair and maintenance of the electrical system. This work must follow the procedures for Class III work.

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30.6.7 Drilling Holes

Notification must be provided to the Safety, Health and Medical Services Division prior to any drilling operation that affects ACM/PACM. Drilling holes into asbestos-containing material shall be limited to non-friable materials such as transite siding, floor tiles, and sheetrock with asbestos containing joint compound. Since this is considered Class III work by OSHA definition, a minimum of Class III worker training is required. The safety office will ensure Impermeable drop cloths must be placed under/around area(s) to be drilled, drilling must be performed through a wet sponge or disposable cup of shaving cream to prevent airborne fiber release. Upon project completion, the area must be cleaned using wet methods and/or HEPA vacuums if necessary. Waste, including disposable suits, wet sponge, and cleaning rag must be placed in asbestos labeled bags, fill out a waste manifest and contact the hazardous waste group at x4-2613.

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30.6.8 Notification

The Safety, Health and Medical Services Division (in coordination with the building managers and supervisors) will periodically notify the following groups of the presence, location, and quantity of ACM or PACM at the work sites in NASA buildings and facilities:

30.6.8.1 Posting Signs for Areas or Building that Contain Asbestos

Areas or buildings found to contain asbestos shall be posted with a warning notice that is readily comprehended, indicating the presence of asbestos, its location, and work practices that ensure that it will not be disturbed. An example of suitable sign format and content is shown in Appendix A (see secton 30.7).

30.6.8.2 Installed Asbestos-Containing Material Notification

Warning labels/signs will be posted (with assistance from Facilities Engineering), where feasible, on installed friable asbestos-containing materials that are accessible to employees, contractors, or the general public. (see Appendix A section 30.7). At a minimum, these signs will be posted at the entrance to mechanical rooms/areas in which employees reasonably can be expected to enter an that contain ACM/PACM.

30.6.8.3 Contractors Notification

All successful bidding contractors (regardless of the contract amount) will be provided with a written Asbestos Notification Summary at the time a contract is awarded. The Asbestos Notification Summary should list the location and condition of ACM. It is the responsibility of the NASA Acquisition Office as well as all contractors to provide the Asbestos Notification Summary in all contracts.

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Appendices

Appendix A: Asbestos Labels/Signs for Installed Asbestos- Containing Materials

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Appendix B: Post Abatement Clearance Certification

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