The following document contains the University of Florida’s Asbestos Operations and Maintenance (O&M) plan. The primary objective of this plan is to protect building occupants and workers by minimizing the potential for exposure to asbestos fibers.

The reader is to use this document as a supplement to his or her current asbestos training. Also refer to the complete OSHA asbestos standards, Florida DBPR requirements, U.S. EPA regulations, the University Asbestos Policy (Appendix E), and other relevant asbestos guidance documents.

Asbestos is the name of a class of minerals that occur in fibrous form. Due to its heat and chemical resistance and its strength and flexibility, asbestos has been used in thousands of different building and non-building related materials. While most uses of asbestos have been banned, some asbestos containing products remain on the market today. The most commonly encountered types of asbestos containing materials at UF include floor tile and mastic, pipe insulation, fireproofing, window glazing, asbestos cement products and roofing. All building materials in structures built prior to 1981 must be presumed to contain asbestos unless laboratory analysis or historical data indicate otherwise. EPA regulations require that all buildings, regardless of age, be surveyed for asbestos prior to demolition or renovation.

Health effects related to asbestos exposure are due to the inhalation or ingestion of asbestos fibers. Asbestos is a known carcinogen that can cause cancer in the lungs, larynx, trachea and other locations of the body. The debilitating respiratory disease, asbestosis, may also result from asbestos exposure.

Asbestos in good condition that remains undisturbed does not represent an exposure hazard. It is important to check with the appropriate contact before disturbing building materials suspected of containing asbestos.

See Appendix A for a list of definitions relevant to this O&M Plan.

The University maintains a program of periodic surveillance of all known or suspected asbestos containing materials. All accessible functional spaces with known or suspected asbestos containing materials are visually inspected a minimum of once a year. Scheduling leniency is permitted in sensitive areas (e.g. some research labs, housing units). The current condition of the asbestos containing material is evaluated relative to its condition at previous surveys. Deterioration or a change in the condition of any asbestos containing material is documented. If this deterioration results in an increased exposure risk to building occupants the deteriorated area is scheduled for hazard abatement.

Inspections are performed by individuals who are currently certified as EPA Asbestos Building Inspectors or who have been trained to recognize asbestos hazards.

Building Occupants

Buildings presumed to contain asbestos containing materials are posted with a notice sign (Appendix B) alerting occupants to the presence of asbestos and providing guidance on where to find further information. These notices are posted inside of the buildings near the entrances.

Contractors

Contractors arriving on campus to work are notified about the presence of asbestos containing materials through their contract documents. Specifically, the form titled “Statement for Bids” is included in the bid documents for all construction projects. It gives notice of the possibility of encountering asbestos containing materials in University buildings.

For selected contractors, there is a form titled “Notice to Contractors of Asbestos Containing Materials in University Buildings”. This form is included with letters sent by Purchasing to successful vendors.

Information pertaining to asbestos is also included in the University Construction Manual.

There are various levels of training required depending on the type of involvement with asbestos materials. Each division (i.e., Health Center, IFAS, Physical Plant Department, Reitz Union) is responsible for ensuring employees are trained for their level of asbestos involvement. Environmental Health and Safety can guide and assist in training. Documentation of training activities must be provided to the EH&S office.

Medical examinations and consultations are required for all employees who are engaged in asbestos work for a combined total of 30 or more days per year or; are exposed at or above the permissible exposure limit or excursion limit; and for employees who wear negative pressure respirators. Days when fewer than sixty minutes of asbestos work are completed are not included in the 29-day count.

These examinations are repeated at least annually thereafter. If the examining physician determines that any of the examinations should be provided more frequently than specified, affected employees will be examined at the frequencies specified by the physician.

Medical examinations include a medical and work history, with special emphasis directed to the pulmonary, cardiovascular, and gastrointestinal systems. Along with a pulmonary function test, any examinations or tests deemed necessary by the examining physician will be included.

An updated asbestos survey, identifying both friable and nonfriable asbestos containing materials, must be conducted of any building or section of a building that is scheduled for renovation or demolition. The completion of a survey is a requirement of Federal EPA NESHAP regulations. A survey is required regardless of the age of the building and may be specific to the project scope of work. A draft copy of the survey must be reviewed by the University Asbestos Coordinator for completeness prior to accepting the final product. A copy of the updated survey must be kept on site until the renovation or demolition activities are completed.

The survey must be conducted under the supervision of a Florida licensed asbestos consultant. Individuals performing asbestos surveys must be certified as EPA asbestos inspectors through a Florida approved training provider.

Occupants of areas adjacent to planned asbestos removal projects must be notified prior to the start of removal activities. This notification may be in writing or by personal communication and must include information pertaining to what material is being removed and what measures are being taken to prevent exposure to asbestos fibers.

Only properly training and certified in-house staff are authorized to remove asbestos containing materials in campus facilities. Up to date abatement project supervisor and worker certification documents including those documenting required annual refresher training must be on file with the EH&S Asbestos Program Manager before any abatement activities are approved.

In-house asbestos removal will be limited to small amounts of material for maintenance purposes only. Examples would include HEPA vacuuming loose fireproofing from an open wall cavity or removal of sections of TSI for the purpose of performing repairs on a valve or section of pipe. Safe work practices, as mandated by OSHA, must be followed for all asbestos removal activities.

University personnel removing asbestos containing floor tile and mastic must comply with the training and notification requirements stated in the OSHA Asbestos Construction Standard (29CFR1926.1101) and in FS 469. All removal must be conducted in strict accordance with the procedural requirements of the Resilient Floor Covering Institute (RFCI). An updated negative exposure assessment (NEA) shall be conducted at least annually by each group conducting floor covering removal using the RFCI methods. Air sampling for the NEA must be conducted by a Licensed Asbestos Consultant and a copy of the final NEA report must be submitted to EH&S for approval.

EH&S must be notified of any proposed in-house asbestos removal at least one week prior to the start of work activities. A written work plan outlining the methods of removal and safe work practices must be submitted to EH&S and approved prior to the start of abatement.

EH&S will review each project on a case by case basis and may require the implementation of additional safe guards, an adjustment to proposed work practices or air monitoring.

EH&S also reserves the right to require that the proposed abatement activities be performed by an approved contractor rather than as an in-house project.

To initiate a project the Project Manager selects an approved asbestos abatement contractor and a licensed asbestos consultant, if required. An Asbestos Project Notification form would then be completed and submitted to EH&S. Estimates are acceptable for costs and dates, and may be corrected at the completion of the project.

The completed APNF is forwarded to the University Asbestos Coordinator by the Project Manager. The selected contractor shall provide the necessary notifications to the Department of Environmental Protection and/or the Department of Business and Professional Regulation (floor covering removals only).

Within 30 days of completing site asbestos activities the Project Manager will need to obtain project reports from the asbestos contractor, and if applicable the licensed asbestos consultant, and provide them to the Asbestos Coordinator at Environmental Health and Safety. An amended APNF should be sent if corrections have been made to the original information.

All asbestos work on campus shall be conducted in compliance with the applicable OSHA standard: 29 CFR 1926.1101 or 1910.1001 depending or the type of work. OSHA enforces these standards for contractors and consultants, and the US EPA enforces them under the Worker Protection Rule 40 CFR 763 for University employees. Additional State of Florida requirements are found in FAC Chapter 469.

Work is to be performed in accordance with the 29 CFR 1926.1101 (OSHA Asbestos Construction Standard), in addition to accepted industry work procedures, and other applicable Federal, State, and County regulations.

On site superintendent must be a “competent person” as defined in 29 CFR 1926.1101 (b). Superintendent must be on the job site full time during the entire contract period of work execution. Superintendent must have a minimum (3) three years experience in type(s) of work and products specified for the project.

All work, for all routine projects is to be conducted with asbestos exposures at or below the OSHA permitted exposure level (PEL). Written approval by the University Asbestos Coordinator is required for projects that are intended to exceed the PEL.

Work is to be performed in accordance with the ASTM E 1368-00, Standard Practice for Visual Inspection of Asbestos Projects, in addition to accepted industry work procedures, and applicable Federal, State, and County regulations.

On site representatives must be a “competent person” as defined in 29 CFR 1926.1101 (b). At a minimum, the on site representative must have NIOSH 582 or equivalent asbestos air sampling and analysis certification and have an up to date asbestos abatement project management and supervision certification from a Florida approved training provider.

If the on site representative is not able to perform his or her duties due to any contractor created safety or health hazard at the site, the representative must direct the contractor to correct the hazard. If the contractor cannot, or will not correct the hazard, the on site representative shall notify the University Project Manager, and shut the project down until the hazard can be corrected.

Air monitoring by the licensed asbestos consultant shall include adequate personnel samples to confirm contractor’s compliance with the NEA.

The on site representative shall have the necessary training, equipment and experience to verify that the contractor is maintaining adequate diminished pressure and air changes per hour in the NPE.

Asbestos: includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these minerals that has been chemically treated or altered.

Asbestos-Containing Material (ACM): any material containing more than one percent asbestos.

Class I Asbestos Work: the removal of thermal system insulation and/or surfacing material (ACM or PACM).

Class II Asbestos Work: removal of any ACM which is not Class I, such as wallboard, floor tile, ceiling tile, linoleum, transite board, roofing materials and mastics.

Class III Asbestos Work: repair and maintenance operations where ACM is likely to be disturbed.

Class IV Asbestos Work: maintenance and custodial activities during which employees contact but do not disturb ACM, and activities to clean up dust and debris which may be generated by Class I, II, or III work.

Clearance Air Monitoring: Air monitoring conducted by an Asbestos Project Monitor at the conclusion of an asbestos project. Clearance air monitoring includes the successful completion of a final visual inspection for work area debris and the collection and analysis of air samples in accordance with AHERA protocols.

Competent person means, in addition to the definition in 29 CFR 1926.32 (f), one who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure, who has the authority to take prompt corrective measures to eliminate them, as specified in 29 CFR 1926.32(f): in addition, for Class I and Class II work who is specially trained in a training course which meets the criteria of EPA’s Model Accreditation Plan (40 CFR 763) for supervisor, or its equivalent and, for Class III and Class IV work, who is trained in a manner consistent with EPA requirements for training of local education agency maintenance and custodial staff as set forth at 40 CFR 763.92 (a)(2).

Friable Asbestos Containing Material: any material containing more than one percent asbestos, which when dry, may be crumbled, pulverized or reduced to powder by hand pressure.

High Efficiency Particulate Air (HEPA) Filter: a filter capable of trapping and retaining at least 99.97 percent of all mono-dispersed particles of 0.3 micrometers in diameter.

Negative Exposure Assessment (NEA): a demonstration by the employer, which complies with the criteria in OSHA 29 (CFR) 1926.1101 paragraph (f) (2) (iii), that the employee exposure during the monitored operation is expected to be consistently below the PELs.

Non-Friable Asbestos Containing Material: materials in which asbestos is bound in a matrix which cannot, when dry, be crumbled, pulverized or reduced to powder by hand pressure (such as floor tile and asphaltic building materials).

Permissible Exposure Limits (PELs):

1. Time Weighted Average (TWA): the employer shall ensure that no employee is exposed to an airborne concentration of asbestos in excess of 0.1 fiber per cubic centimeter as an eight (8) hour time weighted average.
2. Excursion Limit (EL): the employer shall ensure that no employee is exposed to an airborne concentration of asbestos in excess of 1.0 fiber per cubic centimeter of air as averaged over a sampling period of thirty (30) minutes.

Presumed Asbestos Containing Material (PACM): thermal system insulation and surfacing material in buildings constructed no later than 1980, are assumed to contain asbestos until it has been analyzed to verify or negate its asbestos content.

Regulated Area: means an area established by the employer to distinguish areas where airborne concentrations of asbestos exceed or there is a reasonable possibility that they may exceed the permissible exposure limits.

Vinyl Asbestos Floor Tile (VAT): vinyl floor tile and in some cases its mastic which contain more than one percent asbestos and must be handled as ACM.

Asbestos Containing Material Notification

Asbestos Project Notification Form (APNF)

The University of Florida require asbestos contractors doing work for the University to carry asbestos general liability insurance in addition to all other insurance coverage (including but not limited to automobile and workers compensation) required by the bid and contract documents. The asbestos related insurance policy must be procured through an underwriter with an A.M. Best rating of A- or better lawfully authorized to do business in Florida. The insurance policy shall provide that the University of Florida is named as an additional insured. The University shall not be responsible for any sums of money associated with the policy, including any deductible. Coverage shall be on “occurrence” basis, rather than “claims made” and must protect Contractor from all claims arising out of the Contractor’s asbestos abatement work for the University. The minimum limits of liability for the asbestos contractor general liability are:

Each Occurrence	Limit $1,000,000
Personal Injury and Advertising	Injury Limit $1,000,000
Fire Damage	Limit (any one fire) $50,000
Medical Expense	Limit (any one person) $5,000
Products and Completed Operations Aggregate	Limit $1,000,000
Aggregate (Other than Products/Completed Operations)	Limit $1,000,000

The Contractor shall file with the University a certificate of insurance and a copy of the policy acceptable to the University prior to the commencement of the work. The policy shall remain in force without interruption from the date of the commencement of the work until the work is completed and the Contractor is off site. The certificate and policy shall indicate that coverage afforded under the policy will not be canceled or allowed to expire until at least 30 days prior written notice has been given to the University.

Asbestos Policy

Asbestos Floor Tile Policy

The following Work Practices are to be used when impacting wallboard in any University of Florida (UF) facility. Prior to any maintenance activity that may impact wallboard (cutting, drilling, painting, nailing, patching, removal, etc.), the project manager or facility manager must be notified. It is the responsibility of the project/facility manager to have the subject wallboard tested for the presence or absence of asbestos in the material. Records will be maintained by the facility manager and the Environmental Health and Safety (EH&S) Department of the sampling locations and analytical results. If the wallboard system (note: ‘wallboard system’ is defined as the combination of the wallboard, joint compound (mud) and seam tape) is negative for asbestos, then the following procedures do not apply. If the composite wallboard system is positive for asbestos (> or equal to 1% asbestos), then the material must be handled by an UF asbestos term contractor. If the composite wallboard system is <1% asbestos (example: wallboard is negative for asbestos, joint compound is positive for asbestos), then the following procedures must be followed. An OSHA compliant Negative Exposure Assessment (NEA) must be established with regards to each task and procedure by an UF asbestos term contractor before the following procedures can be implemented on a standard Maintenance level.

These work practices are to be followed whenever drilling or installing nails or screws or cutting through known or presumed asbestos containing joint compound where the wallboard system (wallboard, taping and mud together) contains less than 1% asbestos. This includes activities such as:

1. hanging pictures
2. installing coat hooks
3. installing shelving track
4. removal of wall fixtures or furnishings
5. attaching modular furniture to walls
6. installing wiremold, switches or outlets,
7. patching
8. painting

These procedures have been reviewed and approved by the UF EH&S Department.

If other work tasks such as sanding and scraping walls, or specifically cutting along drywall seams, are necessary; they must be done by an UF asbestos term contractor.