Setting up an Asbestos Operations and Maintenance (O&M) Program

Overview

A comprehensive asbestos management program for a building should include these basic steps:

• Appoint an Asbestos Program Manager and develop an asbestos management policy for your organization.
• Inspect the Building. Have a trained and accredited inspector conduct a physical and visual inspection of the building and take bulk samples of suspect materials to determine if asbestos-containing material (ACM) is present, establish an ACM inventory, and assess the ACM's condition and potential for disturbance.
• Develop an O&M Plan. If ACM is located, develop an O&M program, based on the inspection and assessment data.
• If Necessary, Select and Implement Larger Asbestos Repair or Abatement Projects. The condition of the ACM may necessitate that certain abatement actions be conducted by trained and accredited asbestos professionals.

Appoint an Asbestos Program Manager

The building owner should appoint an asbestos program manager (APM). In general, the APM should have the authority to oversee all asbestos-related activities in the building, including inspections, O&M activities, and other abatement actions. The APM will either train building workers in O&M techniques or ensure that such worker training takes place. In addition, he or she should oversee the custodial and maintenance staffs, contractors, and outside service vendors with regard to all asbestos-related activities.

The position of APM is frequently held by the building engineer, superintendent, facilities manager, or safety and health director. In a small organization, the building owner may have this role. Regardless of who holds this position, the individual should be knowledgeable, through training and experience, and to be actively involved in all asbestos-control activities. EPA accreditation under the Asbestos Hazard Emergency Response Act (AHERA) or state certification as a Building Inspector/Management Planner would be appropriate training for an individual seeking this position.

Inspect the Building

To determine whether an asbestos O&M program should be implemented, the owner should have an initial building inspection performed by a trained and accredited inspector to locate and assess the condition of all ACM in the building. A trained and accredited inspector who is able to perform the sampling of suspect ACM for laboratory analysis, should conduct the inspection. If an inspection is not performed, then certain suspect materials should be assumed to contain asbestos, and treated accordingly.

If ACM is found, the material's characteristics, condition, quantity, and location within the building, as well as building use, will affect how the building owner should deal with the ACM. For instance, if ACM is in good condition, O&M procedures may be appropriate and sufficient. However, if ACM is significantly damaged, O&M procedures alone are not sufficient. In these instances it is recommended that some form of abatement — repair, encapsulation, enclosure, encasement, or removal — be performed by a trained and accredited asbestos professional.

Instituting a work permit system may prevent accidental disturbances of ACM.

Develop an O&M Plan

When managing an O&M program, the APM should oversee all asbestos-related activities. In instances where a building owner hires a contractor to perform custodial and maintenance work, the APM should ensure that the contractor is trained to conduct work that may involve ACM.

Work Permit System

The APM should also monitor the work by other contractors, such as electricians and plumbers, who might inadvertently disturb ACM. Instituting a work permit system may prevent accidental disturbances of ACM. Under this system, a contractor must receive a work permit from the APM before commencing work. At that time, the APM will inform the contractor whether the project could disturb ACM and provide any special instructions to make sure the work is done properly.

Periodic Notice to Building Occupants

Communication between the APM and tenants occupying the building is essential to prevent activities that might compromise the O&M program. Owners should consider requiring tenants (by legal agreement or understanding) to notify the owner or the APM before conducting even small planned renovations that would disturb building materials.

Revise the O&M Plan

The APM should periodically review the written O&M plan to determine whether it should be updated. For example, after removal or renovations affecting ACM the O&M program should be revised accordingly. The O&M program should remain in effect as long as there is ACM present in the building.

If Necessary, Select and Implement Larger Asbestos Repair or Abatement Projects

In some instances, due to the condition of ACM or upcoming building renovations, a building owner may decide to take abatement actions to deal with ACM in the building. These response actions could include encapsulation (covering the ACM with a sealant to prevent fiber release), enclosure (placing an air-tight barrier around the ACM), encasement (covering the ACM with a hard-setting sealing material), repair, or removal (minor) of the ACM. Trained and accredited asbestos professionals should be used for any of these actions.

Renovations (including remodeling or redecorating) of buildings or replacement of utility systems increases the potential for disturbing ACM. Before conducting any renovation or remodeling work, the building owner should have the APM review asbestos inspection and assessment records to determine where ACM may be located, visually reinspect the area, and evaluate the likelihood that ACM will be disturbed. Any suspect or assumed ACM that could be disturbed during the renovation work should either be sampled and analyzed to determine whether it contains asbestos, or the work should be carried out as if the materials did contain asbestos. The APM should also ensure that no new ACM is introduced into the building as part of the renovation work.

Removal

Removal of the ACM before renovation begins may be necessary in some instances. Removal is required by the asbestos NESHAP regulations for projects that would break up more than a specified minimum combined amount of ACM; specifically, at least 160 square feet of surfacing or miscellaneous material, at least 260 linear feet of material on pipes, or at least 35 cubic feet on facility components not measured prior to stripping.

Building owners and managers are encouraged to contact their state or local health or environmental department for further clarification of these requirements.

Proper completion of the ACM removal is best evaluated with air clearance procedures using transmission electron microscopy (TEM). (These procedures are described in 40 CFR Part 763, Appendix A to Subpart E.) Clearance protocols for statistically comparing asbestos fiber levels inside the work area with outside levels are set forth for schools in the Asbestos-Containing Materials in Schools Rule. Under these clearance protocols (which are not required for abatement actions in commercial buildings, but can be used for reference purposes), if the measured levels inside are not statistically higher than the average airborne asbestos concentration measured outside the abatement area, the cleanup is considered successful, and the space is judged ready for reoccupancy.

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