Safe Work Practices
An operations and maintenance (O&M) program should focus on a special set of work practices for custodial, maintenance, and construction staff. This page describes the types of safe work practices and when they should be applied. Many of these activities are also covered under the Occupational Safety and Health Administration (OSHA) regulations for asbestos at 29 CFR 1910.1001 and 1926.1101.
- When to Apply Special O&M Work Practices – Implementation of key work practices should be based on the likelihood of disturbing asbestos-containing materials (ACM) and releasing fibers.
- Basic O&M Procedures — Basic procedures are used to perform routine custodial and maintenance tasks that may involve ACM.
- Worker Personal Protective Equipment (PPE) — Proper PPE helps ensure custodial and maintenance staff are adequately protected from asbestos exposure.
- Special O&M Cleaning Techniques — Special techniques to clean up asbestos fibers on a routine basis.
- Procedures for Asbestos Fiber Release Episodes — If moderate to relatively large amounts of ACM are disturbed, the building owner should use these procedures to address the hazard.
When to Apply Special O&M Work Practices
The nature and extent of any special work practices for custodial, maintenance, and construction staff should reflect the likelihood that the asbestos-containing materials (ACM) will be disturbed and that fibers will be released. Maintenance activities can be divided into three categories with regard to their potential for disturbing ACM.
- Those which are unlikely to involve any direct disturbance of ACM; for example, cleaning shelves or counter tops with a damp cloth.
- Those which may cause accidental disturbance of ACM; for example, working on a fixture near a ceiling with surfacing ACM.
- Those which involve intentional small-scale manipulation or disturbance of ACM; for example, removing a small segment of thermal system insulation (TSI) ACM to repair a pipe leak.
Note that activities beyond maintenance activities (or small-scale short duration activities) should be performed only by specially trained and accredited asbestos professionals.
| Summary of When to Apply Key O&M Work Practices | |||
|---|---|---|---|
|
Likelihood of ACM Disturbance
|
|||
| Contact Unlikely | Accidental Disturbance Possible | Disturbance Intended of Likely | |
| Management Responsibilities | |||
| Need Pre-Work Approval from APM | Review by Program Manager | Yes | Yes |
| Special Scheduling or Access Control |
No | Yes | Yes |
| Supervision Needed | No | Initial, at least | Yes |
| HVAC System Modification |
None | As Needed* | Shut Down* |
| Area Containment | None | Drop Cloths, Mini-enclosures | Yes** |
| Personal Protection | |||
| Respiratory Protection | Available for Use | Yes | Yes |
| Protective Clothing | None | Review by APM | Yes |
| Work Practices | |||
| Use of Wet Methods | No | As Needed | Yes |
| Use of HEPA Vacuum | Available for Use | Available for Use | As Needed |
* In the area where work takes place
** Type of containment may vary (e.g., small-scale, short-duration tasks may not require full containment)
Basic O&M Procedures
Below are basic O&M procedures to minimize and/or contain asbestos fibers when there is the potential to disturb ACM includes:
- Wet methods (such as applying water to ACM with a low pressure sprayer).
- Use of mini-enclosures.
- Use of portable power tools equipped with special local ventilation attachments.
- Area isolation.
- Avoidance of certain activities, such as sawing, sanding, and drilling ACM.
If in doubt about the possibility of disturbing ACM during maintenance activities, adequate precautions should be taken to minimize fiber release; these will protect workers as well as the building environment.
Worker Personal Protective Equipment (PPE)
Protective Clothing
Most often, protective clothing is disposable and consists of coveralls, a head cover, and foot covers made of a synthetic fabric which does not allow asbestos fibers to pass through. This type of clothing can prevent workers' regular clothing from becoming contaminated with asbestos fibers. Contaminated clothing should not be taken home to avoid creating a possible risk to the worker's family members.
When in doubt about exposure
It is important that workers be properly trained in the use, removal, and disposal of protective clothing after use. Not all O&M activities require the use of protective clothing so it is important for the asbestos project manager (APM) to assess this need on a case-by-case basis. OSHA regulations require workers to wear protective clothing whenever they are exposed, or likely to be exposed, to fiber levels above OSHA's permissible levels.
Respiratory Protection
Some O&M tasks may require the use of respirators (reference above chart). The selection of approved respirators, suitable for the hazards to which the worker is exposed, is only one aspect of a complete respiratory protection program. Other elements include written operating procedures for respirator use; outlining personnel responsibilities for respirator cleaning, storage, and repair; medical examination of workers for respirator use; training in proper respirator use and limitations; respirator fit testing; and work-site supervision. All of these are described in detail in the OSHA respirator standard found at 29 CFR 1910.134. The O&M respirator program can be administered by the facility safety and health manager or the asbestos program manager (APM), if properly trained and accredited. As with protective clothing, OSHA regulations require the use of respirators whenever workers are exposed, or likely to be exposed, to fiber levels above OSHA's permissible levels.
Do not use single use, disposable paper dust masks when dealing with asbestos.
The options that should be used include:
- A half or full facepiece, negative pressure, air-purifying respirator with replaceable high-efficiency filters.
- A half or full facepiece powered air purifying respirator (PAPR) with replaceable high-efficiency filters. This has a battery powered pump which assists breathing and provides positive pressure in the facepiece.
For additional information on respirator programs, respirator types, and respirator use, the building owner or APM can consult the following references:
-
OSHA asbestos regulations (29 CFR 1910.1001, 1915.1001, and 1926.1101)
Special O&M Cleaning Practices
Wet Cleaning
Proper O&M cleaning will involve the use of wet cleaning or wet-wiping practices to pick up asbestos fibers. Dry sweeping or dusting can result in asbestos fibers being re-suspended into the building's air and therefore should not be used. Once wet cloths, rags, or mops have been used to pick up asbestos fibers, they should be properly discarded as asbestos waste while still wet. They should not be allowed to dry out, because the collected fibers might be released at some later time when disturbed.
HEPA Vacuums
The use of special vacuum cleaners, commonly referred to as HEPA (high efficiency particulate air) vacuums, may be preferable to wet cleaning in certain situations. These vacuums are equipped with filters designed to remove very small particles or fibers—such as asbestos—by filtering those particles from the air passing through the vacuum. Because the exhaust air from an ordinary vacuum cleaner is not filtered sufficiently, it is possible for tiny asbestos fibers to pass through the filter and back into the building air.
Special procedures are generally needed to minimize the spread of fibers in the building after asbestos fiber release occurs.
It is important for O&M workers to use caution when emptying HEPA vacuums and changing the filters because exposures could result from such activities. Before emptying the HEPA vacuums, workers should move the HEPA vacuum to a physically isolated area of the facility and put on proper personal protective equipment before emptying the dust and debris into properly labeled, sealed, and leak-tight containers for disposal as asbestos-containing waste. When custodial workers are not trained to work with ACM, trained maintenance workers can be used to empty the HEPA vacuums and change their filters.
Steam Cleaning Carpets
If ACM has been released onto a carpeted area of a building, it may not always be possible to adequately clean the carpeted area. "Steam" cleaning and HEPA vacuuming methods are sometimes employed for this purpose. The APM should consider the need for workers engaged in cleaning asbestos-fiber-contaminated carpets to wear proper respiratory protection. It may also be prudent to arrange for this type of cleaning to be done after normal working hours or when the facility is less occupied. Additionally, it may be more cost effective to properly dispose of contaminated carpets and other fabrics as asbestos-containing waste if a permanent asbestos control option is being undertaken in the building.
Where the ACM is damaged and located in an "air plenum" — where fibers can be transported by the heating, ventilation, or air conditioning (HVAC) system throughout the building — cleaning practices described above may be extended to the entire building, including the HVAC system itself.
In general, for major fiber releases, the area should be isolated by closing doors and/or erecting temporary barriers to restrict airflow as well as access to the site.
Procedures for Asbestos Fiber Release Episodes
Special procedures are generally followed to minimize the spread of fibers throughout the building after asbestos fiber releases occur, such as the partial collapse of an ACM ceiling or wall. According to EPA regulations for schools a “major fiber release” is one involving more than three square or linear feet of ACM. The procedures to be followed will vary according to the site of the major release episode, the amount of ACM affected, the extent of fiber release from the ACM, the relationship of the release area to the air handling systems, and whether the release site is accessible to building occupants. Depending on the severity of the episode, asbestos abatement consultants and contractors may be helpful in developing a strategy for conducting the cleanup operations.
It is important to recognize that different levels of training may be needed for workers involved with fiber release episodes. For instance, the degree of training considered appropriate for dealing with the clean up of a major fiber release, e.g., asbestos abatement worker training is quite different from the degree of training considered adequate for O&M workers.
Isolate the Area and Alert Building Occupants
In general, for major fiber releases, the area should be isolated by closing doors and/or erecting temporary barriers to restrict airflow as well as access to the site. Signs should be posted as necessary, immediately outside the fiber release site to prevent persons not involved in the cleanup operation from inadvertently entering the area. If asbestos fibers could enter the HVAC system, the system should be modified to prevent fiber entry, or should be shut down and sealed off.
Thoroughly Clean and Inspect the Area
The final step should be to employ thorough cleanup procedures to properly control the ACM. Conduct a careful visual inspection and final clearance air monitoring to verify satisfactory cleanup.
Similar procedures can be used for much smaller fiber release events where the amount of ACM is three square or linear feet or less. The HEPA vacuuming, wet wiping, and worker protection procedures outlined in this guidance document, as well as wetting ACM wastes and properly placing them in an appropriate leak-tight container (such as a properly labeled, 6-mil-thick plastic bag), are examples of some of the procedures that could be used for both major and minor fiber releases.
EPA suggests that building owners and APMs consult with state and local regulatory officials before establishing formal training procedures for each type of situation.
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