Asbestos Management Policy - Northern Michigan University

I. Introduction

Over the past several decades the hazards of asbestos exposure have become well known. With this influx of information, the problem of managing the hazard of asbestos has also arisen. Due to the large scale use of asbestos containing materials (ACM) in many products, the scope of the problem is immense. Asbestos has been widely used in building materials since the 1940's. Examples of these materials include troweled-on acoustical ceiling coatings, sprayed-on-fire-proofing for building superstructures, roofing, pipe and boiler insulations, tile and sheet flooring materials. ACM for the most part has not been used in buildings since the early 1980's.

Since several buildings at Northern Michigan University were built when they still allowed ACM in building materials, asbestos management is an important program. Northern Michigan University's Asbestos Management Program is managed by the University's Safety Director. The Office of Facilities Management and the Purchasing Department play a major role in the program. In addition to the Management Plan, the University will maintain current procedures for management of ACM and presumed ACM (PACM). These procedures will be reviewed annually or more frequently if they amend applicable laws, by the University Safety Director and the Director of Facilities.

II. University Policy

Northern Michigan University is committed to protecting the health and safety of its students, faculty, and staff from unsafe exposure to asbestos. The University complies with applicable laws and regulations concerning asbestos-containing materials. In support of this policy, the University will follow the following principals in the management of asbestos:

A. The University will promptly investigate asbestos problems and will act to protect the safety and health of the University community. The University will fully document and appropriately record abatement procedures and activities.

B. Where required, abatement of asbestos may include removal, encapsulation, enclosure, or other forms of isolation and security to properly protect health and safety. All such projects will be completed in accordance with current State and Federal laws.

C. Protection of employees with the potential for exposure to ACM during their duties is a University priority. The University will properly train employees and contractors who are working in areas that may result in exposure to ACM in asbestos awareness. When working in areas where asbestos exposure is a hazard, the University will provide employees appropriate personal protective equipment (PPE) at no expense to the employee.

D. Only qualified employees or contractors will do asbestos abatement projects and disposal of ACM. All work involving ACM will be according to current laws and regulations.

E. The University will provide students, faculty, and staff timely and accurate information about asbestos abatement activities that may affect them.

F. The University's current policy is one of in-place management. That is, we only disturb or removed ACM when absolutely necessary. This means only during building renovation, demolition of when ACM is found damaged.

III. Federal and State Regulatory Requirements and Guidelines

A. Regulatory Agencies: Currently, two State and one Federal agency regulate Northern Michigan University. The three agencies are the U.S. Environmental Protection Agency (EPA), the Michigan Department of Environmental Quality (DEQ) and the Michigan Department of Consumer & Industry Services, Bureau of Safety & Regulation, Occupational Health Division. The following laws will govern projects involving ACM at Northern Michigan University:

1. Section 40 of the Code of Federal Regulations, Part 61 (40 CFR, Part 61); The EPA National Emissions Standards for Hazardous Air Pollutants (NESHAPS), Asbestos Revision. This section has been adopted and promulgated by the State of Michigan.

2. Section 40 of the Code of Federal Regulations, Part 763 (40 CFR, Part 763); The Asbestos Hazard Emergency Response Act (AHERA), EPA Worker Protection Rule. This section has also been adopted and promulgated by the State of Michigan under Section 24 of Act No. 154 of the Public Acts of 1974, as amended, and Executive Reorganization Orders Nos. 1996-1 and 1996-2.

3. Section 40 of the Code of Federal Regulations, Part 763 (40 CFR, Part 763; The AHERA Reauthorization Act. This section has been adopted and promulgated by the State of Michigan under Public Act 127 of 1995, Amendments of the Asbestos Workers Act, Public Act 440 of 1988.

4. Michigan Public Act 55 of 1993, Amendments of the Asbestos Abatement Contractors Licensing Act (Act 135 of the Public Acts of 1986).

B. Regulatory Requirements: The standards require that Northern Michigan University handle ACM so there are no visible emissions from the work area, use proper disposal containers, prepare waste disposal manifest or shipment records, and notification requirements to the Department of Natural Resources. Smaller projects, such as in-house Operations and Maintenance activities will be reported annually. The law also requires that the University ensure that anyone involved in asbestos related work be certified by an EPA accredited training providers.

C. The occupations currently mandated for certification are:

• Asbestos Removal Worker
• Asbestos Removal Worker/Supervisor
• Building/Facility Asbestos Inspector
• Building/Facility Asbestos Management Planner
• Asbestos Project Designer
• Asbestos Abatement Contractor

These occupations require yearly refresher training, and a certification fee payable to the State of Michigan. Employees required to perform in any previously listed occupation will be trained at no cost to the employee, and certification/accreditation fees will be paid by the employee's department.

There are a variety of other regulations that also apply to the program. These are related to such agencies as the Department of Transportation (Michigan and Federal), the Federal Clean Water Act, and various local regulations. Although descriptions are not included, they are important, and are dealt within management of the program.

IV. Asbestos Identification

Due to the amount and diversity of ACM found within the University, we use several approaches to aid in asbestos identification. These include visual inspection, sampling of suspect materials and the presumption that certain materials commonly found in our facilities contain asbestos. Laboratory analysis of samples is the final confirmation step in identifying ACM.

A. Visual Inspection: Visual inspection is the first aspect in identifying suspect ACM in buildings. The inspection is used to quantify how much ACM in a building, and if the suspect material is found to contain asbestos. Visual inspection information from confirmed ACM is used to identify areas that the University will inspect annually. This allows for the tracking of changes in the condition of ACM over time. If the material is deteriorating, we will remove or repair it, whichever best suits the situation.

B. Bulk Sampling: If Bulk Sampling is required, the University will conduct them according to AHERA requirements by Michigan certified workers only.

C. Presumption: Certain materials are commonly found to contain asbestos and are therefore, always presumed to be ACM (PACM). These include any thermal system insulation (TSI) that is not obviously fiberglass or foam rubber. TSI's are those found on plumbing, boilers, furnaces, steam heat exchanges, etc. The University will make this presumption primarily based on the age of the building. We also presume that floor tile, sheet flooring, backing and adhesives were ACM. This includes both 9"x9" and 12"x12" tiles. If large scale removal is required, the University will sample them to confirm ACM content. The University manages these materials as separate entities, because they are considered non-friable. Transite, a brand name for preformed material used in roofing, oven liners, chemical fume hood lines, piping and the University also presumes that sheeting was ACM. Asphaltic roofing materials, shingles and tar paper are presumed to be ACM.

D. Laboratory Analysis: Laboratory analysis is the final confirming step in identifying a substance as ACM. Before the University uses a laboratory, we will verify that the U.S. Department of Commerce and the American Industrial Hygiene Association has accredited the laboratory.

V. Definitions

A. Friable - any material containing more than 1% asbestos, as determined using AHERA mandated analytical methods, that when dry can be crumbled, pulverized, or reduced to a power with hand pressure. (This material easily becomes airborne.)

B. Non-friable - any material containing more than 1% asbestos that when dry cannot be crumbled, pulverized or reduced to a powder by hand pressure. (This material does not easily become airborne.)

V. Hazard Management

Two Departments conduct the actual day to day management of the University's ACM. The first is the Safety Department, which is responsible for the development, implementation, training and coordination of the program. The second is the Facilities Department that is mainly responsible for Operations and Maintenance, developing renovation and demolition documents, inspections, calculating cost estimates, developing budgets for projects and so on. Coordination between the two departments is very important. Part of the coordination entails deciding how best to conduct the required work. Due to the scope and complexity of the projects, the University will use one of two methods to complete all asbestos work within the system, either in-house or contracted hazard management.

VI. In-House Hazard Management

Specially trained trades workers can conduct projects at the University. The State of Michigan must certify these employees for their respective duties. They are responsible for conducting small-scale short duration Operations and Maintenance activities. These include limited removal of pipe insulation using the glove bag technique, and damaged ACM debris cleanups and insulation repairs. Due to the limited amount of personnel and equipment, they do not do large scale projects or removal of most troweled or spray applied materials. Outside contractors will conduct these activities, under full containment conditions only.

A. Asbestos Awareness Training: Due to the large number of employees that work near ACM, the University will provide annual awareness to certain tradesmen, custodians, and others, in various aspects of asbestos awareness. Training will be arranged and/or provided by the Safety Department, according to the most current listing of Michigan approved asbestos trainers. The Safety Department will develop and maintain records of training to be placed in the employee Personnel File at the Human Resources Department. Attached to this Management Plan is the listing of employee classifications and the hours of training required.

B. The Facilities Department will post signs in buildings where ACM is present and conduct periodic inspections to ensure that the signs remains in place.

C. Responsibilities of the Asbestos Abatement Coordinator (AAC): All work orders, or projects requiring a Purchase Requisition, no matter origin, must be reviewed by the AAC before work being commenced. If the project entails either ACM or PACM, consultation with the University Safety Department is required before work begins.

VII. Contracted Hazard Management

Before the University allows a contractor to conduct asbestos related activities with the University, the contractor must be considered prequalified by the Safety Director and the Purchasing Director.

A. Prequalification consists of verifying the contractors competence in asbestos abatement. The documentation required includes proper licensing, training records, insurance, past project references, three continuous years of experience in asbestos related work. In addition, a regulatory authority must not have cited the contractor. If a contractor meets the Prequalification requirements, they are placed on the list of qualified bidders.

B. Emergency Response to asbestos related incidents will require that a standard purchase order be developed by the Director of Purchasing. This purchase order will have a maximum dollar amount determined by the Purchasing Department. Contractors who have been prequalified to bid, will be allowed to bid on the contract each year.