Asbestos Management Policy 2023

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Purpose

Asbestos is a naturally occurring material in the environment that was used often in building construction between the 1940’s and 1970’s.  Asbestos Containing Materials (ACMs) are regulated by the Federal Government through the Environmental Protection Agency (EPA) and the Occupational Health and Safety Administration (OSHA) due to the potential health risks associated with exposure to damaged asbestos.  In many St. Lawrence University buildings, asbestos is present in the form of insulation for pipes, ducts, and boilers.  Asbestos also exists in materials such as floor tiles and fireproofing elements at SLU.  It is important to acknowledge the presence of asbestos in SLU buildings, and to understand the protocol outlined below for recognizing and reporting asbestos hazards.  While asbestos is a serious health and safety concern, available data and risk assessments indicate that properly managed, undamaged ACMs in buildings do not present a significant health risk to building occupants.    

Application and Scope

St. Lawrence University is committed to protecting the health and safety of its students, faculty, and staff from unsafe exposure to asbestos.  This Asbestos Management Policy has been developed to provide guidance for St. Lawrence University personnel on how to recognize, report, and avoid asbestos hazards in the workplace. The goal of this policy is to mitigate the risks associated with asbestos containing materials on campus.  This policy establishes protocols to be followed by students, employees, Environmental Health and Safety (EHS), Facilities Operations, managing staff, and outside contractors.  All ACM removal shall be performed under controlled conditions by outside contractors who have been properly trained and certified to complete such abatement tasks.

Responsibilities

Environmental Health and Safety Shall:

  1. Provide asbestos awareness refresher training to Facilities Operations personnel annually.
  2. Maintain employee training records.
  3. Assist in determining the need for asbestos bulk or air sampling.
  4. Ensure abatement contractors are certified to perform the designated work.
  5. Provide abatement contractors with a copy of St. Lawrence’s Asbestos policy and ensure contractor compliance with the policy guidelines.

St. Lawrence Managers Shall:

  1. Inform their employees about asbestos hazards in the workplace.
  2. Identify employees in their department who require asbestos training.
  3. Notify EHS or Facilities Operations when work activities may disturb suspected ACM.
  4. Notify EHS or Facilities Operations in case of an emergency where there is potential for fiber release from ACM.

Facilities Operations Shall:

  1. Act as the primary point of contact for concerns regarding ACM.
  2. Coordinate testing of ACM.
  3. Coordinate abatement of ACM when necessary.
  4. Coordinate with EHS to ensure abatement contractors are certified to perform the designated work.
  5. Communicate with building occupants, residence life (dorms), and EHS when hazardous ACM is present. This includes affixing proper signage.
  6. Cover costs associated with abatement and reinstallation materials.
  7. Identify employees who require asbestos training to EHS.

Outside Contractors Shall:

  1. Adhere to the requirements of this program.
  2. Perform work in accordance with all local, state, and federal regulations.
  3. Notify EHS and/or Facilities Operations of suspected ACM that may be disturbed during a scope of work.
  4. Notify EHS and/or Facilities Operations of suspected ACM found during work activities.
  5. Provide relevant training and certification documentation for handling/abating ACM to EHS and/or Facilities Operations.

General Reporting Procedures

St. Lawrence University students who encounter suspected damaged ACM on campus must follow the following procedures:

  1. Vacate the area as soon as possible. Do not touch or agitate the suspected ACM.
  2. Notify your Community Assistant or Residence Coordinator immediately.
  3. Do not re-enter the area until it has been deemed safe for occupancy.
  4. Residence Coordinators will contact Facilities Operations to determine if the space must be tested for ACM.
  5. *Students can view the Asbestos Exposure Response Flow Chart on the SLU EHS webpage for more information.

St. Lawrence University employees who encounter suspected damaged ACM on campus must follow the following procedures:

  1. Vacate the area as soon as possible. Do not touch or agitate the suspected ACM.
  2. Notify your immediate supervisor of your suspicions, along with the location where you presume the hazard to be present.
  3. Managers shall coordinate with Facilities Operations to determine if the space must be tested for ACM. At this time, any non-essential access may be blocked off to the hazardous space.
  4. Facilities Operations will coordinate with a certified asbestos testing entity to take samples from the area suspected to have ACM.
  5. Pending test results, access to the space with ACM will be restricted and an asbestos abatement will be scheduled by Facilities Operations. 

Labeling and Signage

If there is a positive sample of ACM on campus that is deemed to be hazardous, and thus requires an abatement procedure, Facilities Operations shall contract with an abatement firm to make the necessary repairs.  Asbestos danger signs and labels shall be affixed around the confines of the affected area in a way that all building occupants are made aware of the existing hazard.  Labels must be affixed to all raw materials, debris, waste, and all other products that contain asbestos fibers, or to their containers.  Labels and signage must be affixed in a way that is clear, visible, and legible. Facilities Operations shall ensure that outside contractors performing abatement work are following these signage and labeling guidelines.

Exposure Limit

The Permissible Exposure Limit (PEL) set by OSHA for asbestos is 0.1 fiber per cubic centimeter of air as an 8-hour time-weighted average (TWA) with an excursion limit (EL) of 1.0 asbestos fibers per cubic centimeter over a 30-minute period.  Asbestos exposure can be measured by air monitoring to determine if levels are at or above the PEL. If asbestos exposure has the potential to be at or above the PEL or EL, St. Lawrence University must implement engineering or administrative controls to keep levels at or below the PEL and EL.

Abatement

General Information: If ACM is deemed in poor condition, may be disturbed by planned work activities, or otherwise presents a risk of exposure to building occupants, it must be abated. When feasible, the preferred method of abatement is full removal of ACM.  If removal is not possible, ACM may need to be encapsulated or repaired. The decision to encapsulate or repair ACM instead of removing the material must be made in consultation with SLU Facilities Operations, EHS, and outside contractors when necessary.  ACM that is not removed during an abatement must be appropriately labeled thereafter including the type, quantity, and location.

Prior to Abatement: The designated contractor performing the abatement shall provide a detailed scope of work that must be reviewed by SLU Facilities and EHS prior to commencing work.  Facilities Operations shall secure an abatement firm who will provide advanced notice of anticipated abatement work to affected building occupants. This notice should include the abatement location, relevant dates, and scope of work to be performed.  This abatement notice must be posted for all building occupants a minimum of 10 days in advance of the project start date.  The abatement contractor is responsible for notifying all relevant local, state, and federal jurisdictions regarding the details and extent of the abatement.

During Abatement: The abatement contractor is responsible for constructing a sealed, airtight, and properly ventilated work area that prevents any asbestos particles from escaping the confines of the abatement zone.  The abatement contractor is responsible for supplying their employees with the appropriate training and PPE.  The abatement contractor is responsible for air monitoring during the abatement and should be performed at least daily. Personal air monitoring must be performed in accordance with 29 CFR 1926.1101.

Post-Abatement:  ACM shall be collected and disposed of in sealed, labeled, impermeable bags or containers. The abatement contractor is responsible for the transportation and disposal of all ACM from the abatement site, and for following all applicable local, state, and federal regulations.  Air monitoring must be performed upon completion of the abatement work and after removal of the asbestos containment zone to ensure that atmospheric conditions are safe.     

Training  

Because there are no SLU employees trained or certified to handle or abate asbestos containing materials, annual refresher training is limited to type 1 awareness-level topics approved by the EPA and OSHA.  Annual refresher training shall be provided to custodial, cleaning, skilled trades, and mechanic staff, as well as the managing supervisors for each group.  Refresher training and record keeping of training will be provided and maintained by the EHS office. Annual refresher training may include but is not limited to the following topics:

  • Background information on asbestos
  • Health effects of asbestos
  • Regulatory changes/updates to asbestos management
  • Locations and types of asbestos in university buildings
  • Recognition of ACM damage and deterioration
  • Response and procedure review when PACM is encountered

 Record Keeping

It is the responsibility of the Facilities Operations building or project manager to request and collect all building ACM or PACM test samples, whenever test samples are taken from an SLU facility. Abatement project scopes of work, analytical reports of findings, waste manifests, and abatement records involving ACM upon completion of an abatement project should be collected as well.  These records should then be sent to the EHS office for record review and retention.  EHS is responsible for maintaining all asbestos records including employee training.  Note: If the abatement contractor agrees to file ACM test samples, project scopes of work, and abatement records in a shared electronic drive that is also accessible to the SLU Facilities and EHS team, records may be stored in said shared drive.  Records must be kept on file for a minimum of 30 years.  

Program Contacts

Environmental Health and Safety

Pat Gagnon……  Assistant VP of Safety & Security & Emergency Management. Director, EH&S (315) 229-5555 pgagnon@stlawu.edu

Suna Stone…… Chemical Hygiene and Environmental Compliance Officer (315) 229-5105 smcmasters@stlawu.edu

Dean Manley…… EH&S Coordinator (315) 229-5339 dmanley@stlawu.edu

Facilities Operations

Bob Hance…… Associate VP for Facilities Management/ Chief Facilities Officer (315) 229-5601 bhance@stlawu.edu

Jim Kozsan…… Director, Facilities Operations (315) 229-5625 jkozsan@stlawu.edu

Asbestos Exposure Response 

Potential Asbestos Exposure in Residence Halls

A potential asbestos hazard is identified...

1.  Immediately report concerns to building CA/RC.  Include the location of presumed asbestos as clearly as possible.  Vacate the area if possible until there is communication from ResLife that it is OK to return.

2.  RC/CA to immediately contact Facilities Operations. A FacOps shift supervisor will respond to the concern.

3.  FacOps will coordinate with ResLife and Security to determine if student relocation is required. 

4.  If necessary, FacOps will coordinate material sampling and will communicate next steps with ResLife and EHS.

5.  If abatement is required, see Asbestos Management Plan on EHS website.