Hazard Communication and Training

Hazard Information

Information about asbestos hazards is provided by EPA-accredited asbestos professionals or by State of Washington-certified asbestos competent persons to WSU employees and to contractors working on the WSU campus.

Contractor information

For major capital projects, contractors are informed by Campus Planning and Development (CPD), through the results of a good faith inspection, of the location of asbestos-containing material (ACM) and presumed asbestos containing material (PACM) related to the construction project. Alternately, contractors may be informed that WSU assumes a suspect material contains asbestos. The material is then managed in accordance with asbestos abatement rules (WAC 296-62-07721(b)(ii)(B). A qualified consultant (see Appendix 5) is retained by WSU to provide a good faith inspection. The information compiled in the good faith inspection report is provided to EH&S, to all bidders on the project, to all WSU employees and tenants who may be affected, and to WSU and non-WSU employees working adjacent to an area where ACM or PACM may be disturbed or abated. EH&S may review consultant inspection reports. EH&S will review good faith submittals to contractors bidding on a major capital project prior to their issue by CPD, if requested by CPD to do so. If CPD in consultation with EH&S is reasonably sure that no asbestos will be disturbed by the project, then CPD will issue a notice of "reasonable certainty of nondisturbance of asbestos" to all contractors bidding on the project. See Appendix 1 for an example of a "Reasonable Certainty of Non-Disturbance of Asbestos" form.

If asbestos abatement is performed the third party overseer for the project shall inform WSU, any WSU tenants in the area, his employees, and the employers of employees working in adjacent areas of precautions to be taken to insure that airborne asbestos is confined to the area in which the ACM/PACM is being removed. If applicable, the multi-employer workplace provisions (WAC 296-62-07706) shall be met.

In areas in which a general contractor is present, or subcontractors to a general contractor are present at the same time an asbestos abatement project is being undertaken, the abatement contractor's competent person controls the regulated area, and provides required information to the general and subcontrators.

WSU Employee Information

Information concerning the hazards associated with asbestos is provided to employees from several sources. Information about asbestos and its hazards is communicated to trades and custodial employees through asbestos awareness training, provided on an annual basis. WSU also has a program for labeling and otherwise identifying asbestos containing materials, so that employees who may come into contact with them will be able to prevent or minimize exposure.

Asbestos-containing material (ACM) is any product or building component that contains more than 1% asbestos. All materials applied to surfaces in university buildings may contain asbestos. Only when certified by an EPA-accredited inspector are surface applied materials considered to be non-asbestos. The same is true of thermal systems insulation, or TSI (i.e., pipe insulation) installed in WSU buildings. If the TSI has not been sampled by an accredited asbestos sampling professional, and shown by analysis of the sample to be less than 1% asbestos, it is presumed to contain asbestos. Regulators refer to TSI and surface-applied materials in buildings constructed in 1980 or earlier as presumed asbestos-containing material, or PACM. WSU's policy identifies PACM more broadly than the regulators. It includes all TSI and surface-applied materials not cleared by an EPA-accredited inspector, regardless of the year of building construction. All employees who may be exposed to asbestos at WSU are provided information on the location of ACM and PACM in their work areas.

Asbestos may be present in resilient flooring materials in buildings. WSU presumes that all such flooring contains asbestos unless it has been sampled by an accredited inspector and shown to be negative for the presence of asbestos. Employees who may be exposed to asbestos from flooring are informed of the location of this "presumed" material (which is technically not called PACM, since PACM only refers to surface applied materials and TSI).

Asbestos may also be present in ceiling tiles in WSU buildings. It is presumed that ceiling tiles contain asbestos until sampled and shown not to contain asbestos. As with flooring materials, employees who may be exposed to ceiling materials presumed to contain asbestos, or containing asbestos, are informed of the location of the material.

The Location of ACMs and PACMs on the WSU Campus

WSU has an ongoing program to sample for asbestos-containing material (ACM) in buildings on campus. Pre-1980 buildings are of the highest priority. Until sampling can be performed, Class I materials in these buildings (generally equivalent to surfacing and TSI materials defined by EPA) are automatically considered to be presumed ACM (PACM) in buildings constructed prior to 1980. Employees may be notified of PACM in pre-1980 buildings by (1) a sign placed on a doorway entering into the area locating the PACM and instructing employees how exposure to asbestos can be avoided. This is commonly done at entryways to mechanical rooms or to the WSU steam tunnels. (2) Alternately, the material may be identified on a database or datasheet on the EH&S website as ACM or PACM. The database/datasheet is then used in training of employees who may work in the area where the ACM/PACM is located. Whether signage is provided, or the ACM and/or PACM is identified on a database or datasheet, employees who may be exposed to asbestos are provided asbestos awareness training, and are informed how to understand the data provided.

Class II building materials presumed to contain asbestos are also included in the sampling plan (generally limited to building interior resilient flooring). These materials are not labeled but the location of vinyl flooring presumed to contain asbestos is placed on the same asbestos location database used for Class I materials. WSU employees have access to this information either on-line or in printed form. Employees are trained to access the on-line database or are provided a printed report showing the location of ACM in their work areas.

Miscellaneous building materials such as ceiling tiles may present a risk of accidental exposure to asbestos at WSU, since they may be moved to access spaces above the ceiling. Ceiling tiles have been sampled in a number of campus buildings and information about their location and asbestos content has been added to on-line database discussed in the previous two paragraphs. Workers who may move these tiles to install cable or work in ceiling mechanical spaces receive awareness training and are told how to utilize the database information.

Training

Asbestos health and safety training is provided on several levels.

Maintenance, Repair or Custodial/Housekeeping Work

Training is provided to persons who may be exposed to asbestos fibers on an incidental basis during maintenance, repair or janitorial work. This includes trades workers, custodians, housekeepers and other employees involved in custodial, maintenance and repair work in campus buildings and apartments. A two-hour training program includes the following categories:

Two-Hour Asbestos Awareness Training Program Components

available information concerning the location of PACM, ACM, asbestos-containing flooring and ceiling materials where the absence of asbestos has not been certified,
instruction on how to recognize damaged, deteriorated, and delimitated asbestos containing building materials,
the health effects associated with asbestos exposure,
the relationship between smoking and exposure to asbestos producing lung cancer,
methods of recognizing asbestos and quantity, location, manner of use, release, and storage of asbestos and the specific nature of operations which could result in exposure to asbestos,
engineering controls and work practices associated with the employee's job assignment,
the specific procedures implemented to protect employees from exposure to asbestos,
the purpose, proper use and limitations or protective clothing,
the purpose and a description of the medical surveillance program required by L&I rules,
the content of the L&I standard and its appendices,
identification of organizations which conduct programs concerning smoking cessation,
the requirements for posting signs and affixing labels, and the meaning of such signs and labels, and
the purpose, proper use, limitations and other training requirements for respiratory protection.

Construction work on Non-Asbestos Materials

Training is provided to persons who may be exposed to asbestos fibers on an incidental basis during construction, demolition, renovation or remodeling in minor capital projects on campus. These employees, usually trades workers, will perform tasks only in areas where a good faith survey has been previously performed, and no asbestos-containing materials have been found, or found materials have been abated. The employee may be exposed to asbestos fibers, however, when suspect material is unexpectedly uncovered during construction work. Construction workers are trained at the same level as maintenance, repair and custodial workers. A two-hour awareness training program is provided using the same components indicated in the two-hour program above.

Maintenance Work on Asbestos-Containing Materials

Maintenance workers may potentially be exposed to asbestos due to incidental disturbance of ACM or PACM as part of a task. A two-hour awareness training program is provided using the same components indicated in the two-hour program above. Note that if intentional disturbance is planned, an accredited asbestos worker (and supervisor) must perform the task.

AHERA Building Inspectors

Training is provided to AHERA- accredited inspectors. AHERA- accredited inspectors must pass the EPA-approved 24-hour training course, become accredited, and maintain annual training and accreditation. AHERA-accredited building inspectors who may perform inspections at WSU are included in Appendix 5.

Asbestos Workers and Supervisors

Training is provided to asbestos abatement workers and supervisors. Workers and supervisors must be certified under the provisions of WAC 296-65 and must maintain certification continuously in order to be eligible to perform asbestos abatement work on campus.

Third Party Overseers

WSU may hire persons to perform oversight of asbestos abatement jobs on campus. These persons must hold current certifications as AHERA building inspectors and as either AHERA project designers or asbestos supervisors. Person who may perform third party oversight services are listed in Appendix 6.

Engineers, Architects, Project Leaders, Construction Supervisors, and Maintenance & Custodial Supervisors

Training is provided to employees with supervisory or project management responsibilities in the construction, maintenance or cleaning of facilities. This training, typically 1-2 hours, is oriented toward regulatory requirements and involves a specific training on the WSU Asbestos Management Program. Employees with supervisory or management responsibilities are strongly encouraged to participate in awareness training.

Sample/Records Management Staff

Training is provided to the Facilities Operations maintenance office staff, which provides services as a clearinghouse for asbestos surveys and manages the shipping of asbestos samples.