In-House Asbestos Abatement Practices

Asbestos Work Classes

All asbestos work is categorized into one of the four classes listed below. These classes determine training requirements and acceptable work practices.

Class I

Class I work includes removal of thermal system insulation (pipe insulation, tank insulation, etc.) or asbestos surface coatings (fireproofing, popcorn ceilings, etc.).OSHA/L&I training and certification requirements apply to all employees who remove TSI or surfacing asbestos. At least one person on the project must be certified as an Asbestos Supervisor. Asbestos Workers require 32 hours of initial training with 8 hours annual refresher training. Asbestos Supervisors require 40 hours of initial training with 8 hours of annual refresher training. Training is provided through approved vendors. A list of approved vendors may be obtained from EH&S.

Class II

Class II work involves removal of other types of asbestos material such as flooring, roofing, transite, etc.

There are regulatory requirements for training and certification of all employees who remove asbestos flooring, roofing, ceiling tiles, transite, gaskets, or other asbestos containing materials that are not TSI or surfacing materials. 8 hours of training are required in the specific asbestos containing material that the employee will be removing (i.e., roofing, flooring, etc.). Employees will also need an annual 8-hour refresher class. Training is provided through approved vendors. A list of approved vendors may be obtained from EH&S. Note that if more than one kind of Class II material is to be abated in an asbestos project, a certified worker or supervisor must perform the work.

An asbestos supervisor must inspect the job site daily to ensure that control measures are being performed adequately.

Class III

Class III asbestos involves repair and maintenance activities that might disturb asbestos materials. For example, replacement of a steam pipe fitting might mean disturbance of the asbestos-containing insulation covering the fitting. At WSU, employees are not trained to perform this work. All situations involving Class III work will be abated by Class I or Class II-trained personnel prior to the repair/maintenance project.

Class IV

Class IV work includes maintenance/housekeeping/custodial activities in areas where asbestos containing materials are located. As defined by L&I and OSHA, it includes cleanup of dust, waste and debris from Class I, II or III work. However, at WSU no custodial or housekeeping employees are authorized or trained to clean up any materials from Class I, II, or III work.

For maintenance/housekeeping/custodial activities which may result in the disturbance of asbestos, exposure assessments are generated and maintained in Appendix 3. Only tasks involving negative exposure assessments may be performed by custodial or housekeeping employees.

Custodial and housekeeping employees may work around ACMs, but must not disturb these materials thereby releasing asbestos fibers. No exposure of custodial and housekeeping employees is expected, if employees are trained properly. Training for these housekeeping and custodial workers is provided to ensure that ACMs are not disturbed during normal, or non-routine, work activities. Training courses of two hours duration are provided by EH&S for these employees.

Acceptable Abatement Work Practices at WSU

For all asbestos work:

An Asbestos Project Daily Log shall be kept. See Appendix 1.

For all Class I work:

• The HVAC system must be sealed with double layers of 6 mil plastic.
• Impermeable drop cloths must be placed on the floor and over all objects within the regulated area.
• One of the following types of control methods must be used:

1. negative pressure enclosure

• requires at least 4 air changes per hour.
• must maintain -0.02 inches of water negative pressure.
• requires adjacent equipment room, shower and clean room.
• A supplied air respirator.

2. glove bag

• can not glove bag lines over 150° F.
• single use gloves only (no "sliding" glove bags.)
• requires at least two people.

3. mini enclosure

• must be able to fully contain the work.
• space for no more than two people.
• under negative pressure using a HEPA vacuum.
• requires attached change room.

For all Class 1 work that involves more than 25 linear or 10 square feet of TSI or surfacing asbestos or requires a negative pressure enclosure:

• Critical barriers must be erected over openings to the regulated area.
• Must have a decontamination area that is contiguous with the regulated area.
• Decontamination area consists of clean room, shower and equipment room.
• Workers must enter and exit through the decontamination area.

For all Class 1 work that involves less than 25 linear or 10 square feet of TSI or surfacing asbestos:

• Must have equipment room that is adjacent to the regulated area.
• Workers must HEPA vacuum protective clothing before removing.
• Equipment must be cleaned before it is removed from the equipment room.

 For all Class II work

• During all Class II removal projects, the work area shall be cordoned off and posted with warning signs to prevent unauthorized entrants.
• Respirators are required during the removal until WSU has air monitoring results showing that asbestos exposures are below the PEL, or has documented an appropriate NEA (Negative Exposure Assessment).
• In lieu of air monitoring results, on an annual basis, negative exposure assessment data identified in WAC 296-62-07709(3)(b)(ii) may be used.

a. Roofing

• Roofing work requires either certified asbestos workers or Class II - roofing trained workers.
• Work practice restrictions apply only when removing more than 25 ft² of roof.
• Roof level ventilation equipment shall either be shut down or covered with a critical barrier.
• Roofing shall be removed intact where possible.
• Roofing shall be wet if it cannot be removed intact.
• Power cutting machines will be misted along the cut line.
• When using a power cutter, dust and debris along the cut line will be HEPA vacuumed.
• Waste shall be double bagged or lowered to the ground via dust tight chutes.
• Waste shall not remain on the roof after the work shift.
• Waste on the roof during the work shift shall be wet, bagged or covered with 6-mil plastic.
• No respirators are required once WSU has obtained a negative exposure assessment, which must be renewed on an annual basis.
• Waste shall be stored at a central storage building near the asbestos crew’s office area.

b. Flooring

• Removal of flooring requires certified asbestos workers or Class II - flooring trained workers.
• All vinyl or asphalt flooring is assumed to be asbestos unless proven otherwise by lab analysis.
• Tiles will be removed intact.
• Flooring will be wet when removed.
• Resilient sheeting will be wet at the cut line and misted during removal.
• Mastics and backings will also be wet during removal.
• No dry sweeping.
• No sanding of asbestos floors or backing.
• Vacuums must be HEPA filtered and may not have a brush attachment.
• No respirators required once WSU has obtained a negative exposure assessment, renewed on an annual basis.
• Waste shall be stored at a central storage building near the asbestos crew’s office area.

c. Transite

• Removing transite requires certified asbestos workers or Class II - transite trained workers.
• Panels, shingles, etc. shall be removed intact.
• Panels or shingles will be wet when removed.
• Waste will be promptly bagged or lowered to the ground via dust tight chute.
• Waste shall be stored at a central storage building near the asbestos crew’s office area.

d. Gaskets

• Requires certified asbestos workers or Class II - gasket trained workers.
• If gasket is deteriorated, it shall be removed by a certified asbestos worker using glove bag technique.
• Gasket shall be removed wet.
• Any residual gasket will be wetted before scraping.
• No sanding or grinding of gasket.
• Waste shall be stored at a central storage building near the asbestos crew’s office area.

e. Ceiling Tiles

• Removal of ceiling tiles requires certified asbestos workers or Class II - ceiling tile trained workers.
• No untrained workers shall move asbestos ceiling tiles or suspended ceiling tiles located under asbestos fireproofing.
• Employees should verify with EH&S that ceiling tiles are non-asbestos containing before moving, cutting, breaking or disposing of ceiling tiles.
• If asbestos or possible asbestos ceiling tiles become damaged and fall, untrained workers should not clean up the ceiling tiles.
• Contact FO Maintenance Division to arrange for clean up.
• Waste shall be stored at a central storage building near the asbestos crew’s office area.

f. Brakes

• Work on asbestos brake pads requires asbestos awareness trained workers.
• A catch basin shall be placed under the brake assembly to catch the wash water.
• The brake drum and brake support shall be gently wetted with amended water before the brake drum is removed.
• After removing the drum, the wheel hub, back of the brake, brake support plate, brake shoes and brake components shall be thoroughly wetted using amended water.
• Wash water shall be placed in a disposal drum.
• When full, contact FO Maintenance Division to arrange for disposal.

Respirators

Respirators are to be worn under the following situations:

• During any Class I removal projects.
• During any Class II project where the asbestos material is not removed substantially intact.
• During any asbestos removal projects where WSU has not yet demonstrated that exposures are below the PEL.
• During any work activity in which asbestos fibers are released at a concentration above the PEL or excursion limit.

Class I removal inside of a negative pressure enclosure requires the use of supplied air respirators. All other work requires at least half face negative pressure respirators equipped with HEPA filters. Employees may request a powered air purifying respirator instead of a half face negative pressure respirator. A competent person is required to be present for each project in which a respirator is required under the asbestos rules. The competent person will ensure that the proper respirator is worn by the asbestos worker per the requirements of WAC 296-62-07715.

Respirators need to be fit test before initial use and at least annually thereafter. Supplied air and powered air purifying respirators, and full facepiece respirators must be quantitatively tested; half face respirators may be qualitatively tested. Contact the respirator program administrator at EH&S (335-3041) to arrange the fit test.

Protective Equipment

Protective Clothing

Protective clothing is required for all Class I and Class II asbestos work. The competent person on the project will periodically inspect protective clothing to ensure its integrity.

For Class I work, Tyvek coveralls or equivalent shall be worn, together with gloves, head coverings, foot coverings, and eye/face protective equipment complying with the Personal Protective Equipment (PPE) rule (WAC 296-24-07801) unless a negative exposure assessment is produced.

For any asbestos work in a regulated area, clean change areas must be provided which meets the requirements of WAC 296-62-07719, except that employees performing Class III or Class IV work may clean their protective clothing with a HEPA vacuum prior to leaving the area where work was performed.

Employees shall wear Tyvek coveralls during all asbestos removal/repair projects involving Class II asbestos work, provided a negative exposure assessment has not been produced. Coveralls will be replaced whenever the employee leaves the regulated area or when the integrity of the coverall is compromised, whichever comes first.

Decontamination

Shower facilities are required for all negative pressure enclosures and for all work areas in which the employee is exposed above the PEL. Shower facilities must have hot and cold running water discharged through a mixing faucet, soap, and (a) clean towel(s) for each person using the shower. The competent person shall ensure that workers use good hygiene practices and use the decontamination facilities.

For all Class I work involving more than 25 linear feet or 10 square feet of TSI or surfacing ACM/PACM, a three stage decontamination area must be provided, including an equipment room, a shower (if feasible), and a clean change room. All employees must enter the decontamination area through the clean room and pass through to the regulated area through the equipment room. If a shower is not feasible at the abatement site, a separate equipment room, shower and clean room will be established elsewhere. Workers will remove gross debris from their work clothing and while continuing to wear their respirator, don a clean Tyvek suit over the suit they are wearing. The employee will then proceed to the alternate shower/clean room site, and shall enter the alternate equipment room. Coveralls will be removed and disposed of, while the respirator is removed after the employee is fully wetted in the shower. After showering, the employee shall enter the clean room where clean street clothing is available.

For Class I work involving less than 25 linear feet or 10 square feet of TSI or surfacing ACM/PACM, and for Class II and Class III tasks where exposures exceed a PEL or where there is no negative exposure assessment, a decontamination area consisting of a dropcloth on a floor or horizontal working surface shall be established. This area shall be of sufficient size to accommodate the cleaning of equipment and removing of PPE without spreading contamination. Work clothing and equipment are HEPA vacuumed prior to removal. All employees will enter the regulated area through the equipment room or area.

The decontamination area will not be used for the transportation of asbestos debris.

Signage and Labeling

Signage

Signs will be posted outside of all Class I, Class II and Class III asbestos work areas. The legend shall be:

Signs bearing label information shall be posted at the entrance to all mechanical spaces that contain asbestos. In all other areas, installed asbestos products will be labeled, where feasible, as containing asbestos. The legend for labels shall be:

The legend for labels shall be:

 Waste disposal

Asbestos was must be adequately wet when bagged. All waste should be promptly bagged, at a minimum waste must be bagged by the end of the work shift. A two-chambered air lock will be used for all Class I work in which there is a negative pressure enclosure, or whenever more than 25 linear feet or 10 square feet of asbestos is involved. Bagged waste will be decontaminated in the first chamber or placed in a second bag, then placed in the second chamber for load out. Otherwise, waste is double-bagged and the outer bag is HEPA vacuumed prior to the waste being removed from the abatement area

Asbestos waste will be kept at the storage area near the asbestos crew's office until taken to an approved waste disposal area.

Asbestos waste must be double bagged and marked with:

Danger
Contains asbestos fibers
Avoid creating dust
Cancer and lung disease hazard
Avoid breathing airborne asbestos fibers
Washington State University
Pullman, Washington 99164

A waste shipment record (40 CFR 61 Subpart M, see Attachment 1) needs to accompany all asbestos waste disposal. The asbestos project supervisor may complete this form as necessary. A copy of each waste shipment record is sent to EH&S when shipment occurs.

Recordkeeping

 Medical Surveillance

All employees who are either certified asbestos workers, certified asbestos supervisors, or 8-hour trained for Class II work shall receive initial, annual and termination medical surveillance exams. The exam may be scheduled by Benefit Services (335-4589), otherwise it is the responsibility of the employee's department to schedule and pay for exams.

The exam shall be administered before the employee starts Class I or Class II work or is assigned to an area where s/he may be exposed to airborne asbestos fibers above the PEL or where negative pressure respirators are required. Exams shall be conducted by a physician and shall include a medical and work history, assessment of the employee's ability to wear a negative pressure respirator, completion of the appropriate questionnaire in Appendix D of WAC 296-62-077 and a chest x-ray, if needed. Chest X-rays shall be given following the schedule outlined in Table 2 of WAC 296-62-07725 and interpreted by a certified B-reader.