Specific Management Plan Procedures

Separate procedures have been established for maintenance and construction operations related to asbestos management. A single procedure has been established for maintenance tasks, and this procedure is used both by Facilities Operations (FO) and Housing and Dining Services (HDS). For construction projects, Capital Planning and Development (CPD), FO and HDS each have separate protocols.

Procedures used in Construction Projects

Because of the type and size of construction of project each department has to manage, several differences can be observed when comparing the following procedures. However, all have several traits in common. They are: (1) Asbestos abatement is performed prior to the construction portion of a project. (2) Care is taken to properly notify and train all persons who may be exposed as a result of an abatement project, including those in proximity to the abatement project who work for other employers, who are tenants, or who are non-employees. (3) In projects in which an asbestos abatement company is employed directly by a general contractor who is responsible for the construction project to which abatement is related, third party oversight is practiced. And (4), information related to asbestos sampling and to asbestos abatement is specifically and strictly gathered to maintain and support the WSU asbestos database. Construction procedures are oriented toward proper management practices.

Procedures Used in Capital Planning and Development Projects

General Description of Capital Planning and Development (CPD) Projects

CPD projects usually pass through several distinct stages, including pre-design (programming), design, and construction. Typically, each project is developed by a designated project officer who is generally responsible for the workings of the project, including the management of any hazardous materials with which it may be associated. Should asbestos abatement be necessary, it is carried out prior to construction of the project.

The design process may include schematic drawings, design development, and finally, construction documents. Although hazardous materials management requirements should be considered in the programming stage, it is especially important to address them in the design process, either in the schematic phase or the design development phase.

Each project requires either a written notice of the reasonable certainty of non-disturbance of asbestos, or a good faith inspection is performed. If there is reasonable certainty of non-disturbance of asbestos, a form bearing the same title is filled out and signed by the project officer. The "Reasonable Certainty of Non-Disturbance of Asbestos" form is located in Appendix 1. A copy of this document is provided to any general contractor bidding on the project.

If a good faith inspection is to be performed, the project officer may select anyone listed in Appendix 5 to perform it. An alternate individual or firm may be selected to perform the good faith inspection after approval by EH&S. The project officer should contact EH&S with the name, address and telephone number of any individual or firm not appearing on the list in Appendix 5 at least one month prior to the date the good faith inspection is to be performed. Following approval, the name of the alternate individual or firm will be placed on the list in Appendix 5. EH&S periodically reviews the names of individuals and firms on the Appendix 5 list to ensure they meet regulatory requirements as inspectors, and to verify that the laboratory used for sample analysis meets EPA and WAC requirements.

After the good faith inspection is performed, the report generated as the result of the inspection is used to plan the management of asbestos-related issues. In addition, the report is provided to any contractor bidding on the project. The document is also provided to any WSU employees who may be exposed during the abatement process or who may be working in areas immediately adjacent to the project.

If the scope of the project changes after the good faith inspection is performed, an additional good faith inspection must be performed in any area not covered by the initial good faith inspection. If the scope of the project changes after the project has been started, the project must be stopped and a good faith inspection and abatement performed prior to recommence of the project.

Asbestos abatement precedes project work as a general policy at WSU. An exception is the rare situation that demolition of the portion of a structure must be done in order to be able to access the asbestos, and the asbestos abatement contractor cannot perform the demolition. In this instance, close cooperation between the general contractor and asbestos abatement contractor is monitored by a third party overseer to safely coordinate the activity.

If asbestos is discovered during the construction phase of the project, the area where it is discovered is isolated and a certified asbestos abatement crew or contractor is brought in to establish a regulated area and properly deal with the asbestos before construction is resumed. Note that friable asbestos materials, or non-friable materials made to release asbestos fibers, must be reported to the Department of Ecology (DOE) and/or to the Washington Department of Labor and Industries ten days prior to abatement if reportable amounts are present. (NOTE: Ten calendar days to report to DOE; ten working days to report to Labor and Industries.)

During asbestos abatement, a third party oversees the activities of the abatement contractor. The project officer may select approved third party overseers from the list contained in Appendix 6. An alternate individual or firm may be selected to perform the third party oversight after approval by EH&S. The project officer should contact EH&S with the name, address and telephone number of any individual or firm not appearing on the list in Appendix 6 at least one month prior to the date asbestos abatement is to be performed. Following approval, the name of the alternate individual or firm will be placed on the list in Appendix 6. EH&S periodically reviews the names of individuals and firms on the Appendix 6 list to ensure they meet regulatory requirements as inspectors and as asbestos supervisors, and to verify that the laboratory used for sample analysis meets EPA and WAC requirements. The third party overseer is responsible to provide services as specified in Appendix 6.

The abatement contractor is certified by the State of Washington, and meets all the regulatory requirements of the WAC asbestos rules. The abatement contractor is required to conform to the specifications contained in Appendix 7. Note that if the abatement is performed in-house, the in-house asbestos abatement procedures are use, listed below.

The third party overseer informs the project officer in writing of any rule violations by the abatement contractor during the abatement process. The third party overseer also performs pre-abatement and clearance sampling of the abatement project. Finally, the third overseer provides a final report indicating that no asbestos-containing material remains in the abatement area, or documents the nature of any unabated material. Note: A Washington State-certified asbestos supervisor employed by WSU, who is also an EPA-accredited asbestos building inspector, may function as the third party overseer. Also note: The third party overseer may not be in any way associated with the same company as the asbestos abatement contractor, even if the overseer is listed in Appendix 6.

When abatement is completed, the third party overseer performs clearance sampling and certifies the area is clean to the project officer. The project officer then permits the clearance document to be given to the asbestos abatement contractor, and the containment securing the abatement area can be removed.

After the completion of the project, the abatement contractor provides documentation of the abatement work completed to the third party overseer. The third party overseer prepares and provides a report to WSU citing specific areas where asbestos has been abated and certifying asbestos is not present on abated surfaces.

Procedures Used in Facilities Operations Construction Projects

General Description of Facilities Operations Construction Projects

Facilities Operations (FO) performs three separate kinds of construction projects: public works projects, internally logged WSU shop projects, and work orders. FO public works projects are similar in nature to CPD major capital construction projects since they typically involve design, but they are usually on a much smaller scale. In FO public works projects, independent contractors bid on the work to be performed, and asbestos abatement may be part of the bid. Logged shop projects are performed by WSU employees, and use the WSU asbestos abatement crew for any good faith inspection and asbestos abatement needs. Work orders are usually very small projects; they may also use the WSU asbestos abatement crew for good faith inspection and abatement work.

Procedure

Each project requires either a written notice of the reasonable certainty of non-disturbance of asbestos, or a good faith inspection is performed.

At the time a construction project is conceived or the project is conceptually developed a decision is made as to whether or not design will be involved. If design is involved, a FO architect, engineer or project leader will ascertain whether or not there is reasonable certainty of non-disturbance of asbestos, or whether a good faith inspection will be performed, and will complete any needed forms or statements. If the project is a log with no design, or is a no log work order, the construction supervisor will complete any necessary forms.

If there is reasonable certainty of non-disturbance of asbestos on a logged project, the "No" box on the "Safety Hazard Checklist" for the Log is checked. Alternately, the "No" box on the "hazard list" on the No Log Work Order form is checked. If the project is a public works project, a "Reasonable Certainty of Non-Disturbance of Asbestos" form is filled out and signed by the project officer. This form is provided to each bidder on the project. An example of a "Reasonable Certainty of Non-Disturbance of Asbestos" form is located in Appendix 1.

If the "Yes" box is checked on either the log or no log forms, the architect, engineer, project leader or construction supervisor copies the form and sends it to the Operations Center Supervisor, Maintenance Services Division. The Operations Center Supervisor, or an employee working directly for the Operations Center Supervisor will coordinate with the architect, engineer, project leader or construction supervisor, and will arrange for a good faith inspection of the project. Alternately, the WSU asbestos database will be checked, and if sample result(s) are found for materials which may be disturbed during the project, the page(s) containing the result(s) are copied. The results of the good faith inspection, or the copied asbestos database page, are attached to the log or no log "Safety Hazard Checklist" form and returned to the architect, engineer, project leader or construction supervisor.

If a good faith inspection is to be performed, an accredited member of the WSU asbestos abatement crew may perform it. As an alternative, anyone listed in Appendix 5 may be selected to perform the good faith inspection. Any additional individual or firm may be selected to perform the good faith inspection after approval by EH&S. The architect, engineer or construction supervisor should contact EH&S with the name, address and telephone number of any individual or firm not appearing on the list in Appendix 5 at least one month prior to the date the good faith inspection is to be performed. Following approval, the name of the alternate individual or firm will be placed on the list in Appendix 5. EH&S periodically reviews the names of individuals and firms on the Appendix 5 list to ensure they meet regulatory requirements as inspectors, and to verify that the laboratory used for sample analysis meets Department of Ecology and WAC requirements.

After the good faith inspection is performed, the report generated as the result of the inspection is used to plan the management of asbestos-related issues. If the project is a public works project, the good faith inspection document is provided to any bidding contractor. This good faith inspection document is also provided to any WSU employees who may be working in areas immediately adjacent to the project or who may be exposed during the abatement process.

If the scope of the project changes after the good faith inspection is performed, an additional good faith inspection must be performed in any area not covered by the initial good faith inspection. If the scope of the project changes after the project has been started, the project must be stopped and a good faith inspection and abatement performed prior to recommence of the project.

Asbestos abatement precedes project work as a general policy at WSU. An exception is the rare situation that demolition of the portion of a structure must be done in order to be able to access the asbestos, and the asbestos abatement contractor cannot perform the demolition. In this instance, close cooperation between the general contractor and asbestos abatement contractor is monitored by a WSU third party overseer, to safely coordinate the activity.

If asbestos is discovered during the construction phase of the project, the area where it is discovered is isolated, and a certified asbestos abatement crew or contractor is brought in to establish a regulated area and properly deal with the asbestos before construction is resumed. Note that friable asbestos materials, or non-friable materials made to release asbestos fibers, must be reported to DOE and/or to the Washington Department of Labor and Industries ten days prior to abatement if reportable amounts are present.

Except in public works contracts, asbestos abatement will be performed by the WSU asbestos abatement crew, unless specifically called out for the project by the architect, engineer, project leader or construction supervisor. If the WSU asbestos crew performs abatement, the supervisor of the crew shall be accredited by DOE as an asbestos building inspector, and shall be certified as an asbestos supervisor by the State of Washington. After abatement is completed, the supervisor of the WSU asbestos crew provides information to EH&S as specified in the "Good Faith Inspection Criteria" in Appendix 5.

In public works contracts, as well as in special situation project logs, asbestos abatement may be performed by a subcontract to a general contractor. For any asbestos abatement project performed by an asbestos abatement contractor, a third party oversees the activities of the asbestos abatement contractor.

The abatement contractor is certified by the State of Washington, and meets all the regulatory requirements of the WAC asbestos rules. The abatement contractor is required to conform to the specifications contained in Appendix 7.

The third party overseer informs EH&S in writing of any rule violations by the abatement contractor during the abatement process. The third party overseer also performs pre-abatement and clearance sampling of the abatement project. Finally, the third party overseer provides a final report indicating that no asbestos-containing material remains in the abatement area, or documents the nature of any unabated material. Note: A Washington State-certified asbestos supervisor employed by WSU, who is also an EPA-accredited asbestos building inspector, may function as the project overseer. Also note: The third party overseer may not be in any way associated with the same company as the asbestos abatement contractor, even if the overseer is listed in Appendix 6.

When abatement is completed, the third party overseer performs clearance sampling and certifies the area is clean to the architect, engineer or construction supervisor. The architect, engineer or construction supervisor then permits the clearance document to be given to the asbestos abatement contractor, and the containment securing the abatement area can be removed.

After the completion of the project, the abatement contractor provides documentation of the abatement work completed to the third party overseer. The third party overseer prepares and provides a report to WSU citing specific areas where asbestos has been abated and certifying asbestos is not present on abated surfaces.

Procedures Used in Housing and Dining Services Construction Projects

General Description of Housing and Dining Services Construction Projects

Housing and Dining Services (HDS) performs construction projects of various sizes. Larger projects are given to Capital Planning and Development (CPD) or to Facilities Operations (FO), where they go through the previously defined procedures for asbestos management. Smaller projects are performed by departmental staff.

Procedure

Each construction project performed by HDS staff requires either a written notice of the reasonable certainty of non-disturbance of asbestos, or a good faith inspection is performed. The supervisor for the specific HDS area in which the construction project is to be done is responsible for the evaluation of the project, and the determination of whether (a) asbestos is involved in the construction project, and (b) if asbestos is present, whether it will be disturbed.

If there is reasonable certainty of non-disturbance of asbestos, the "No" box on the "Safety Hazard Checklist" for the project is checked.

If there is not reasonable certainty, the "Yes" box on the checklist is marked. A good faith inspection must then be performed. The supervisor notifies the Maintenance and Construction Manager, Housing Services who arranges for the good faith inspection.

If a good faith inspection is to be performed, an accredited member of the WSU asbestos abatement crew may perform it. As an alternative, anyone listed in Appendix 5 may be selected to perform the good faith inspection. Any additional individual or firm may be selected to perform the good faith inspection after approval by EH&S. EH&S should be contacted with the name, address and telephone number of any individual or firm not appearing on the list in Appendix 5 at least one month prior to the date the good faith inspection is to be performed. Following approval, the name of the alternate individual or firm will be placed on the list in Appendix 5. EH&S periodically reviews the names of individuals and firms on the Appendix 5 list to ensure they meet regulatory requirements as inspectors, and to verify that the laboratory used for sample analysis meets EPA and WAC requirements.

After the good faith inspection is performed, the report generated as the result of the inspection is used to plan the management of asbestos-related issues. The good faith inspection document is provided to any WSU employees who may be exposed to asbestos released from the materials sampled. It is also given to any employee working in areas immediately adjacent to the project or who may be exposed during the abatement process.

Typically, asbestos abatement will be performed by the WSU asbestos abatement crew, unless specifically called out for a project managed by a FO architect, engineer or construction supervisor. If the WSU asbestos crew performs abatement, the supervisor of the crew shall be accredited by EPA as an asbestos building inspector, and shall be certified as an asbestos supervisor by the State of Washington. After abatement is completed, the supervisor of the WSU asbestos crew provides information to EH&S as specified in the "Good Faith Inspection Criteria" in Appendix 5.

In public works contracts, as well as in special situation project logs, asbestos abatement may be performed by a subcontract to a general contractor. For any asbestos abatement project performed by an asbestos abatement contractor, a third party oversees the activities of the asbestos abatement contractor.

The abatement contractor is certified by the State of Washington, and meets all the regulatory requirements of the WAC asbestos rules. The abatement contractor is required to conform to the specifications contained in Appendix 7.

The third party overseer informs EH&S in writing of any rule violations by the abatement contractor during the abatement process. The third party overseer also performs pre-abatement and clearance sampling of the abatement project. Finally, the third party overseer provides a final report indicating that no asbestos-containing material remains in the abatement area, or documents the nature of any unabated material. Note: A Washington State-certified asbestos supervisor employed by WSU, who is also an EPA-accredited asbestos building inspector, may function as the project overseer. Also note: The third party overseer may not be in any way associated with the same company as the asbestos abatement contractor, even if the overseer is listed in Appendix 6.

When abatement is completed, the third party overseer performs clearance sampling and certifies the area is clean to the architect, engineer or construction supervisor. The architect, engineer or construction supervisor then permits the clearance document to be given to the asbestos abatement contractor, and the containment securing the abatement area can be removed.

After the completion of the project, the abatement contractor provides documentation of the abatement work completed to the third party overseer. The third party overseer prepares and provides a report to WSU citing specific areas where asbestos has been abated and certifying asbestos is not present on abated surfaces.

Procedures Used in Maintenance and Custodial Activities

General Description of Maintenance and Custodial Activities Involving Asbestos Containing Materials

Both Facilities Operations (FO) and Housing and Dining Services (HDS) employ maintenance and custodial staff. Maintenance staff in both departments may work in building mechanical rooms where surface-applied materials or thermal systems insulation (TSI) are present. Maintenance staff may move ceiling tiles which contain asbestos, or may affix equipment or fixtures to floors, walls or ceilings which may contain asbestos-containing material (ACM). Plumbers may work on systems insulated with ACM. Mechanics may work on specific HVAC systems in mechanical rooms which may contain ACM. In the motor pool, mechanics may be exposed to brake or clutch parts which may contain ACM.

Custodians in both HDS and FO perform routine custodial tasks, such as cleaning, waxing and buffing. Cleaning and buffing of floors containing asbestos is common activity. Surfaces such as popcorn ceilings or suspended tile ceilings may be cleaned.

Both custodians and maintenance employees may be confronted to damaged or broken TSI, surfacing materials or ceiling tiles which may be ACM.

Procedure

The supervisor of an employee at WSU is responsible to ensure that employee is not inappropriately exposed to a health and safety risk, including hazardous chemical substances such as asbestos fibers. The supervisor must evaluate each task of the employee to determine if hazardous conditions exist, then ensure the employee has proper training and protective equipment and uses established procedures so that his/her health is not compromised.

Both WSU employees supervisors in maintenance and custodial departments are trained annually in recognition of ACM and presumed asbestos-containing material (PACM), and in procedures to be used if there is a release of fibers from ACM or PACM.

When an employee's task is identified in which an ACM or PACM may be disturbed by a maintenance or custodial employee, the supervisor makes arrangements with EH&S and a member of the WSU asbestos crew or other certified asbestos worker(s) to have the task performed with monitoring for exposure. Sampling of the material is done, and a record of environmental conditions during the task is made. Air monitoring is performed during the task, and the employee is informed of the results of monitoring. This information is used to develop either a positive exposure assessment (PEA) or a negative exposure assessment (NEA), depending on the monitoring results. The exposure assessment is placed in the Asbestos Management Plan, Appendix 3.

Any supervisor may refer to the Asbestos Management Plan with a query about asbestos exposure during a specific task. If the task "closely resembles the processes, type of material including percentage of asbestos, control methods, work practices, and environmental conditions," the employee may perform the task as indicated in any NEA. If there is a PEA for the task, it must be performed by the WSU asbestos crew or other certified asbestos worker.

If the task does not "closely resemble the processes, type of material including percentage of asbestos, control methods, work practices, and environmental conditions," then an exposure assessment is performed. The supervisor contacts EH&S and a certified worker, as indicated above, to perform the assessment.