Job-Site Controls for Work Involving Asbestos-Containing Material (ACM)
Work Control/Permit System
The operations and maintenance (O&M) program should include a system of job-site controls to monitor all work that could disturb asbestos-containing material (ACM). Some building owners have had success using a work permit program. A worker control permit program typically has three parts:
- Job Request Form for Maintenance
- Maintenance Work Authorization Form
- Evaluation of Work Affecting Asbestos-Containing Materials
The first part of the program requires the person requesting the work to submit a job request form for maintenance to the asbestos program manager (APM) before any maintenance work is begun. The form gives the time and location of the requested work, the type of maintenance needed, and available information about any ACM in the vicinity of the requested work. The contractor or other person authorized to perform the work should be identified on the form.
Upon receiving a pre-work job request form, the APM should take the following steps:
- Refer to written records, building plans and specifications, and any building ACM inspection reports to determine whether ACM is present in the area where work will occur. If ACM is present, but it is not anticipated that the material will be disturbed, the APM should note the presence of the ACM on the job request form and provide additional instruction on the importance of not disturbing the ACM.
- If ACM is both present and likely to be disturbed, the APM or a designated supervisor qualified by training or experience, should visit the site and determine what work practices should be instituted to minimize the release of asbestos fibers during the maintenance activity.
- This determination should be recorded on the maintenance work authorization form which is then sent to the in-house maintenance supervisor or to the maintenance contractor to authorize the work.
- The APM should make sure that a copy of both the job request form and the maintenance work authorization form (if granted) are placed in the permanent file.
- Upon completion of the work, a copy of the evaluation of work affecting asbestos-containing materials form should be placed in the permanent asbestos file for the building.
Ensure Use of Good Protective Work Practices. Where the task is not covered by previously approved standard work practices, the APM should make sure that the appropriate work practices and protective measures are used for the job.
Visit the Site. For all jobs where contact with ACM is likely, the APM or a designated supervisor qualified by training or experience should visit the work site when the work begins to see that the job is being performed properly. For lengthy jobs where disturbance of ACM is intended or likely, periodic inspections should be made for the duration of the project.
Evaluate the Work. The APM’s observations should be provided on an evaluation of work affecting asbestos-containing materials form. Any deviation from standard and approved work practices should be recorded immediately on this form and the practices should be immediately corrected.
Building owners should consider using asbestos O&M work control forms similar to those that already may be in use for non-ACM work in their facilities.
The O&M management system should also address work conducted by outside contractors. Many building owners contract for at least some custodial and maintenance services. A building's asbestos work control/permit system, as described above, should also cover contract work.
Contracts with service trades or abatement companies should include the following provisions to ensure that the service or abatement workers can and will follow appropriate work practices:
Proof that the contractor's workers have been properly notified about ACM in the owner's building and that they are properly trained and accredited (if necessary) to work with ACM.
Copies of documentation of use of respiratory protection, medical surveillance, and worker training as required by OSHA, EPA, and/or state regulatory agencies.
Notification to building tenants and visitors that abatement activity is under way (performed by owner).
Submission of written work practices by the vendor or contractor to the APM for approval or modification. The vendor or contractor should then agree to abide by the work practices as finally accepted by the APM.
Assurance that the contractor will use proper work area isolation techniques, proper equipment, and required waste disposal practices.
Historical air monitoring data for representative examples of the contractor's previous projects, with emphasis on projects similar to those likely to be encountered in the building.
Provision for inspections of the area by the owner’s representative to ensure that the area is acceptable for re-entry of occupants/tenants.
Evaluation of resumes for each abatement contractor/supervisor or maintenance crew chief, known as the "competent person" in the OSHA standard and EPA Worker Protection Rule.
Criteria for determining successful completion of the work (i.e., visual inspections and air monitoring).
Notification to EPA (and other appropriate agencies) if the abatement project is large enough to trigger asbestos NESHAP requirements.
Any other information deemed necessary by the owner’s legal counsel.
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