Program Overview & Hazard Awareness
Asbestos is a broad name given to a family of naturally occurring silicate minerals which include chrysotile, amosite, crocidolite, tremolite, anthophyllite, and actinolite that have been processed into very thin fibers and mixed with a material to bind the fibers together. Asbestos is resistant to chemical and heat exposure, does not evaporate into the air or dissolve in water. Due to these properties, it was incorporated into a variety of construction products such as wall and ceiling plasters, floor tile, pipe insulation and asphalt roofing.
The presence of asbestos in a building does not mean that the health of building occupants is endangered.
As long as asbestos-containing materials (ACM) remain in good condition and are not disturbed or damaged, exposure is unlikely. On the other hand, damaged, deteriorated, or disturbed ACM can lead to fiber release (exposure), become airborne, inhaled and deposited within the lungs. Only trained, certified workers should handle or remove asbestos-containing materials. Unauthorized or uncontrolled disturbance of asbestos materials is not only potentially unhealthy, it is a violation of University policy and can lead to civil or criminal liability under Occupational Safety and Health Administration (OSHA), the Environmental Protection Agency (EPA), and the Kentucky Division for Air Quality (KDAQ).
An ACM is defined under State and Federal Regulations as a material containing more than 1% asbestos.* ACM is classified as friable or non-friable. Friable ACM is ACM that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. Nonfriable ACM is ACM that, when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure. Nonfriable ACM is further classified as either Category I or Category II. The categories are distinguished from each other by their potential to release fibers when damaged.
Category I nonfriable: Asbestos containing packings, gaskets, resilient floor covering, and asphalt roofing products.
Category II nonfriable: Any material, excluding Category I and is generally is more likely to become friable when damaged.
*Out of an abundance of caution, UK considers any detectable percentage of asbestos as asbestos-containing material.
Partial List of Potential Asbestos-Containing Building Materials
Fume Hood Liners
High Temperature Gaskets
Electrical Panel Partitions
HVAC Duct Insulation
Electrical Wiring Insulation
The mere presence of asbestos in a building does not mean that the health of building occupants is endangered. When asbestos-containing material (ACM) is properly managed, release of asbestos fibers into the air is prevented or minimized, and the risk of asbestos-related disease can be reduced to a negligible level. Asbestos materials can become hazardous when, due to damage, disturbance, or deterioration over time, they release fibers into the air. Long-term exposure to fibers has been linked to five specific diseases:
- Asbestosis (a fibrous scarring of the lungs),
- Lung Cancer,
- Mesothelioma (a cancer of the lining of the chest or abdominal cavity),
- Pleural Effusion (excess fluid between the lungs and chest wall), and
- Pleural Plaque (tissue around the lungs and diaphragm thickens and hardens).
These diseases have generally been observed after long-term exposures from activities that directly disturb ACM and typically the diseases do not develop until 14 to 40 years after exposure. Most cases of severe health problems resulting from asbestos exposure have been experienced by workers who held jobs in industries such as shipbuilding, mining, milling and fabricating, where they were repeatedly exposed to high levels of asbestos. Regardless, appropriate measures must be taken to minimize exposure. The body has natural defense mechanisms to eliminate asbestos fibers and other particles before they become lodged in the lung tissue where the contaminants remain. Many particles are entrapped by the nose and mouth. The breathing passages are lined with a sticky mucous layer that traps small particles. Lining the bronchial tubes are hair-like projections (cilia) that continuously move the mucous layer towards the mouth for expectoration. Cigarette smoke impairs the human body’s defense mechanism by paralyzing the cilia. Documentation shows that smokers who are also exposed to asbestos have an increased risk of lung cancer of 90 times that of a non-exposed non-smoker.
Employee Safety Handbook
UK’s Employee Safety Handbook is intended for all employees, full time and part time, regular and temporary, and all other UK employment categories (STEPS, student workers, etc.). It was developed to provide answers to general questions concerning environmental health and safety in the workplace. As stated in the handbook, campus buildings have the potential to contain asbestos in building materials. However, most asbestos is not accessible to building occupants. In addition, as needed, Environmental Quality Management Department (EQM) conducts building surveys to identify and safely manage previously installed asbestos-containing products. Furthermore, all renovations of campus buildings must be reviewed in advance to ensure that asbestos is not disturbed without proper safeguards. Work that requires removal or repair of asbestos is restricted to trained and qualified persons only.
All faculty, staff, and student employees are expected to comply with the following rules and guidelines for on-campus asbestos:
Presume all building materials from pre-1981 buildings contain asbestos until determined otherwise by EQM.
Do not remove, cut, drill, sand, grind or otherwise disturb any material that may contain asbestos.
Do not go above ceilings, behind walls or into building spaces such as attics and crawlspaces unless these areas have been inspected and cleared.
Do not pull cable or wiring through above-ceiling spaces with asbestos.
Do not install screws, pins, nails or hangers into asbestos ceiling or wall plasters.
Do not damage walls, ceilings or floors when moving furniture or equipment.
Do not brush, sweep or vacuum textured asbestos ceiling plaster or plaster debris.
Report any observed damage or deterioration of suspect building materials to your supervisor, building operator, EQM, or UK Occupational Health & Safety.
Housekeeping and maintenance employees are required to attend in-house Asbestos Awareness Training.
University Capital Project Design Standards
Design Standard, 028200S01, Asbestos Assessment was developed to provide general asbestos environmental health and safety guidance to any person (including employees, students, contractors, and consultants) on campus which may come in contact with existing ACM in buildings. Building materials that may contain asbestos must be treated as if they do until laboratory testing proves that they do not contain asbestos. Contact a supervisor, resident advisor, house corporation, or EQM to answer questions about whether a material contains asbestos.
Similar in nature, Design Standards 028200S02, Asbestos Remediation Information and 003126S03, Asbestos Information for Consultants & Contractors, were developed to institute the asbestos abatement process for consultants and contractors before and during any construction/renovation project and include the information in all contract requirements. Prior to the start of a project, consultants and contractors should confirm via UK’s Project Manager that all areas covered by a project have been surveyed for the presence of ACM and that all ACM that could be impacted by the project have been removed. In the event a contractor encounters material reasonably believed to be asbestos on the site, the Contractor shall immediately stop work in the affected area and report the condition to UK's Project Manager. The work in the affected area shall not thereafter be resumed until the contractor has been notified in writing by UK's Project Manager that the material is not hazardous, or that it has been abated or has otherwise been rendered harmless. The work in the affected area shall be resumed only in the absence of hazardous material, or when the material has been rendered harmless.
Design Standard 003123S01, Hazardous Communication was developed as a contract requirement for construction/renovation projects to notify contractors and subcontractors that they must have their own OSHA Hazardous Communication Program (29 CFR 1910.1200) for all hazardous materials, including asbestos. The contractor and subcontractor programs must contain:
- A list of the hazardous chemicals to which the employees may be exposed.
- Statement of the measures that employees may take to lessen the possibility of exposure to the hazardous materials.
- The location of and access to the MSDSs related to the hazardous chemicals located in the work area.
- Procedures that the employees are to follow if they are exposed to hazardous chemicals above the Permissible Exposure Limit (PEL).
Design Standard 003126S02, Hazardous Materials Checklist, provides a checklist for all projects to be evaluated for the potential presence of hazardous materials or other environmental concerns. For ACM this includes:
- The UK Project Manager should have EQM survey ALL projects for the presence of ACM.
- The UK Project Manager must provide survey results to Contractor.
- Abatement should be completed prior to project.
- ACM in the project area (but not part of the project) must not be damaged or disturbed at any time.
- Regulatory notification required for demolition projects even if no asbestos is present
Federal Occupational Safety and Health Administration (OSHA)
OSHA regulates and establishes protective measures for occupational exposure to employees who are involved in the removal of asbestos-containing materials (ACM) or whose jobs require them to potentially disturb or otherwise are exposed to ACM. Regulation 40 CFR 1910.1001, Subpart Z, Toxic and Hazardous Substances-Asbestos was developed to regulate asbestos exposure in industries but does not include construction, alterations, and/or repairs. While regulation 40 CFR 1926.1101, Subpart Z, Toxic and Hazardous Substances-Asbestos specifically regulates asbestos exposure during construction, alterations, and/or repairs. The standards establish exposure limits, and establishes work practices including training, labeling, bagging of waste, and respiratory protection.
The permissible exposure limits (PEL) established by OSHA are:
- 0.1 fibers per cubic centimeter (f/cc) for an 8 hour time-weighted average limit (TWA) and
- 1.0 f/cc excursion limit (EL) as averaged over a sampling period of 30 minutes.
Federal Environmental Protection Agency (EPA)
EPA through the Clean Air Act (CAA) protects public health and welfare (e.g., harm the environment and cause property damage) through protecting and improving air quality. The CAA establishes emission standards which includes asbestos. In addition, the Toxic Substance Control Act (TSCA) gave EPA the authority to require reporting, recordkeeping, and testing requirements of asbestos. Using these laws, EPA developed and implemented regulation 40 CFR 61, Subpart M, National Emission Standard for Asbestos. The regulation requires the owner or operator, prior to commencement, to thoroughly inspect (assess) the area where the demolition or renovation (abatement) operation will occur for the presence of asbestos. If ACM is detected, the regulation contains notification and procedures for emission controls based on the abatement size and asbestos classification. Additionally, the regulation governs waste disposal, air cleaning, and reporting requirements.
In 1988, the EPA evaluated various asbestos control and abatement (removal) actions to help building owners manage ACM in their facilities, to alleviate unwarranted fears about the mere presence of asbestos in buildings, and to discourage spontaneous decisions to remove all ACM regardless of its condition. In 1990, EPA issued a guide titled Managing Asbestos In Place, which emphasizes the importance of in-place management as an alternative to asbestos abatement through a properly conducted Operations and Maintenance (O&M) Program.
The Asbestos Hazard Emergency Response Act (AHERA)’s Model Accreditation Plan (MAP) requires that asbestos professionals (including any worker, contractor or supervisor, inspector, management planner, or project designer) working with asbestos-containing building materials in a school, public or commercial building be accredited under a training program at least as stringent as the EPA Model Accreditation Plan (MAP).
Kentucky Division for Air Quality (KDAQ)
Per regulation 401 KAR 58:005, Accreditation of asbestos professionals, a person shall not engage in, nor allow a person to engage in, an asbestos abatement project unless an accreditation certificate to engage in these projects has been issued to the person by the cabinet, is currently in effect, and is maintained on the person at all times while the asbestos abatement project is being conducted.
Regulation 401 KAR 58:025, 40 CFR Part 61 national emission standard for asbestos, adopts the Federal EPA regulation and delegates authority to the State of Kentucky to enforce the Federal requirements.
Regulation 401 KAR 58:040, Requirements for asbestos abatement entities, defines an asbestos abatement entity as any partnership, firm, association, corporation, sole proprietorship, or other business concern, any governmental agency, or any other organization, composed of one (1) or more employees or members, or any individual involved in any of asbestos-related activities. The regulation defines prohibited actions, work practice requirements, certifications, employee training, and reporting/recordkeeping requirements.
University of Kentucky
UK has established contract requirements and Administrative Regulations (ARs) to implement Governing Regulations and provide for general administration and oversight. ARs are official rules or directives that, among other things:
- Mandate requirements for members of the UK community.
- Ensure the consistent and equitable application of policies and procedures.
- Enhance the UK’s mission, reduce institutional risk, and/or promote operational efficiency.
- Help achieve compliance with applicable federal or state law, local ordinance, or accrediting bodies.
AR 6:3 Environmental Health and Safety specifically mandates compliance and assigns specific responsibilities associated with the implementation of UK’s health, safety, and environmental protection programs. Through AR 6:3 UK has established broad, yet comprehensive authority over its population of faculty, staff, and students regarding compliance with local, state, and federal environmental regulations including asbestos requirements.
Listed below are some key definitions used in OSHA and EPA regulations.
Abatement- Procedures to control fiber release from ACM, including removal, encapsulation and enclosure of ACM.
Amended Water - means a water solution containing an effective low sudsing wetting agent.
Appropriate Protective Clothing - means protective outer clothing, which is worn by an individual who is engaged in an asbestos project regardless of the concentration of asbestos fibers in the air within the asbestos project. Protective clothing consists of coveralls or similar whole body covering, head covers, foot covers and the appropriate respirator protection.
Approved Asbestos Waste Disposal Site - means a solid waste disposal area that is operated under a permit issued by the Kentucky Department of Environmental Protection and is authorized to receive asbestos containing solid wastes.
Asbestos - A natural occurring mineral in the form of cyrysotile, amosite, crocidolite, tremolite, anthophyllite, actinolite chemically treated and/or altered.
Asbestosis - The scarring of the tissue of the lung itself from inhalation of airborne asbestos fibers.
Asbestos containing material (ACM) - Any material containing asbestos in an amount greater than one percent(> 1%).
Asbestos Hazard Emergency Response Act (AH ERA) - Federal law that requires the use of specially trained persons to conduct inspections for asbestos, develop asbestos management plans, and design or conduct asbestos work.
Asbestos subcontractor - A contractor licensed by the state of Kentucky and is under contract to perform asbestos abatement and removal on behalf of the University of Kentucky.
Asbestos Danger Label - means a label which contains the following legend, printed in letters of sufficient size and contrast to be readily visible and legible: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD
Demolition - Wrecking, intentional burning, moving or dismantling of any load-supporting structural member, or portion thereof, of a building.
Containment Area - means a negative pressure asbestos project work area and decontamination facility configured so as to isolate asbestos project activities from areas which are to remain uncontaminated.
Critical Barrier - means a closure device constructed of plastic sheeting and installed in an entryway into an area contaminated or to be contaminated with ACM. A control curtain is intended to restrict the movement of air into, and from, a contaminated area.
Decontamination Facility - means that portion of the containment area containing an equipment room, shower facility and a clean change room.
Enclosure - means the construction of an airtight, impermeable permanent barrier around ACM to control the release of asbestos fibers into the air.
EPA-means the U.S. Environmental Protection Agency
Friable asbestos - ACM which can be crumbled, pulverized, or reduced to powder, when dry or by hand pressure.
HEPA Filter means - a high efficiency particulate air filter capable of trapping and retaining from an air stream 99.97% of asbestos fibers greater than 0.3 microns in size.
Mesothelioma - A rare type of cancer that affects the pleural sac that surrounds the lungs, and is caused by exposure to asbestos
Occupational Health and Safety Administration (OSHA) Classification Designations for Asbestos Work:
Class I. Asbestos operations and activities involving the removal of friable asbestos, thermal systems insulation (TSI) and surfacing ACM and PACM.
Class II. Asbestos operations and activities involving the removal of ACM which is not friable asbestos, TSI or surfacing material, such as floor tiles, wallboard, and transite board.
Class Ill. Construction, repair and maintenance activities where ACM is likely to be disturbed. Class IV. Maintenance and custodial activities during which personnel contact ACM and PACM.
Permissible exposure limit (PEL} - Generally, a limit for personal exposure to a substance. The OSHA eighthour PEL for asbestos is 0.1 fibers per cubic centimeter
Presumed asbestos containing material (PACM } - TSI and surfacing material found in buildings constructed before 1981
Renovation - An operation other than demolition in which PACM is removed or stripped from any element of a building, structure, installation or portion thereof
Supervisor means - an individual who is appropriately certified to supervise and direct an asbestos project in accordance with the Asbestos Control Act and the rules and regulations adopted and promulgated pursuant to this act.
Thermal system insulation (TSI} - Material in a building applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes
Wet Cleaning means - the process of using amended water or a removal encapsulant and a wet brush, mop, cloth, sponge or similar wet cleaning device to remove completely any visible ACM residue from surfaces.
Wetting Agent - means a surfactant or chemical that is added to water to decrease its surface tension and allow it to spread more easily over or penetrate into a surface that is covered with ACM.
Work Area - means a specific room or physically isolated portion of a room in which ACM is required to be handled in accordance with the requirements of these regulations. These areas are designated as work areas from the time that the room, or portion of it, is being prepared in order to perform the asbestos project until the time the area has been cleaned free of all visible residue in accordance with applicable Departmental regulations.
Worker - means an individual who is appropriately certified in a nonsupervisory capacity to clean, handle, repair, remove, encapsulate, haul, dispose of or otherwise work with ACM in activities involving more than three square feet or three linear feet of ACM.