Introduction

Asbestos Management at WSU

General Policy

In order to protect the health of Washington State University (WSU) employees, students and the general public, all asbestos-containing materials are carefully managed. Employees and all other potentially affected persons are informed of the disturbance, or potential disturbance, of asbestos-containing materials which may result in exposure to asbestos. Asbestos-containing building materials are labeled, or employees are otherwise informed of their location and condition. Employees who may be exposed to asbestos are monitored to determine the extent of exposure. Employees who may be exposed to asbestos are trained according to regulatory requirements. WSU complies with EPA rules and Washington State rules governing asbestos activities.

WSU Departments Involved in the Asbestos Management Program

Academic Departments

Employees, students and visitors in academic departments at WSU will not normally be involved in activities which may disturb asbestos-containing building materials. In rare instances when exposure to these persons occurs or may occur due to disturbance of these materials, representatives of the WSU Environmental Health and Safety department work directly with them to ensure proper training, monitoring and exposure controls are in place.

When WSU shop employees or asbestos abatement contractor employees perform work which may disturb asbestos-containing materials in academic areas, academic department employees are informed of the nature of the work performed in accordance with WAC 296-62-07721(2)(b) and (c) notification requirements.

Service Departments

Four service departments are involved in asbestos activities at WSU. They are the departments of Capital Planning and Development (CPD), Facilities Operations (FO), Housing and Dining Services (HDS) and Environmental Health and Safety (EH&S). Each of these departments plays a different role in asbestos activities. CPD is involved in major construction, renovation and demolition projects, typically involving contracts for services in excess of $500,000. FO manages minor construction projects which cost less than $500,000. FO also performs maintenance and custodial activities in all campus academic and services buildings except those occupied by HDS. HDS performs small construction projects, as well as maintenance and custodial activities, these in residence and food service buildings associated with WSU.

EH&S fulfills a coordinator role in the WSU Asbestos Management Program. EH&S is responsible to ensure the Asbestos Management Program is updated and meets regulatory requirements. EH&S also maintains an asbestos sample database, information from which is used in maintenance and construction operations, as well as in asbestos awareness training of employees, on the WSU campus. EH&S investigates complaints about possible asbestos exposures, and consults with service and academic departments to resolve complaint issues. EH&S also oversees the activities of the WSU asbestos abatement crew which performs asbestos building inspection and asbestos abatement work. EH&S staff may perform area or personal sampling for asbestos exposures to personnel at WSU, however, monitoring for asbestos abatement projects is typically performed by the asbestos supervisor in charge of the particular project. 

Construction Projects

Each construction project at WSU is either certified as reasonably certain not to result in disturbance of asbestos, or is subject to a good faith inspection. Good faith inspections are performed only by EPA-accredited inspectors. Results of analysis of asbestos bulk samples obtained by accredited inspectors are placed on the WSU on-line asbestos database, except in the case the subject building is demolished.

Procedures for asbestos abatement differ depending on the WSU department involved in each particular construction project. CPD projects may involve general contractor subcontracts for asbestos abatement, or abatement may be performed under separate contract. Abatement in CPD projects is overseen by an independent third party or by a WSU employee who is Washington Labor & Industries-certified as an asbestos supervisor/project designer and inspector.

FO projects are either performed in-house, or are performed under a public works contract. In public works contracts a general contractor may subcontract for asbestos abatement, or abatement may be performed separately by the WSU asbestos abatement crew prior to releasing the project for bid by outside contractors. If a public works contract includes asbestos abatement, the project is overseen by an independent third party or by a WSU employee who is certified both as an asbestos supervisor and as an asbestos building inspector.

HDS construction projects are performed in-house, primarily by HDS employees. At times FO may perform a construction project for HDS. The WSU asbestos abatement crew abates asbestos in all HDS minor constructon projects. Major construction projects are administered by CPD.

Maintenance and Custodial/Housekeeping Activities

Both FO and HDS maintain structures on the WSU campus. Activities include both maintenance and custodial or housekeeping work. Employees are informed of the presence and location of asbestos-containing materials (ACM) or presumed asbestos-containing materials (PACM) in their work areas. Awareness training is provided to ensure employees will recognize asbestos materials and will not perform activities which might lead to asbestos exposure above the PEL. Further, maintenance and custodial tasks are evaluated to determine if asbestos may be disturbed. Maintenance and custodial employees are trained not to clean up releases of suspected ACM or PACM, but to contact the WSU asbestos abatement crew for cleanup.

When ACM or PACM may be disturbed during a maintenance or custodial task, employee exposure monitoring may be performed if there is a potential for exposure. Based on the monitoring results and the environmental conditions associated with the task, the exposure assessment will be determined to be negative (exposure levels consistently below the PEL) or positive (exposures measured above the PEL). Records of these assessments will be maintained in the WSU Asbestos Management Program. See Appendix 3

Asbestos Abatement Projects Performed In-House

WSU maintains an asbestos abatement crew that performs asbestos sampling and abatement activities associated with campus maintenance and/or construction projects. The crew and its members are certified by the Washington State Department of Labor and Industries. The crew is actively involved in cleanup of releases of asbestos-containing materials on campus.

WSU asbestos abatement crew employees perform a variety of tasks in abatement work. Personal monitoring is performed during these tasks (except when supplied air systems are used for respiratory protection). Based on the monitoring results, negative or positive exposure assessments are made. These are recorded in the Asbestos Management Program, Appendix 2.