Asbestos Policy

Unit: Environmental Health and Safety
Contact: William Diltz
Title: Environmental Safety Manager
Effective Date: 9/13/2022
Revision Date: 09/13/2022

Purpose

The purpose of this policy is to ensure compliance with applicable state and federal regulations regarding asbestos-containing materials and to minimize the potential exposure to the University of Alabama (University) students, faculty, staff, visitors and contractors.

Policy

Background

Asbestos-containing materials (ACM) refer to products containing greater than 1% asbestos. While the use of ACM in new building systems has been curtailed for most major applications, ACM can still be present in older building systems. In most cases the ACM does not pose a health hazard if left undisturbed. Activities that have the potential to disturb ACM must be carefully managed to prevent fibers from becoming airborne and creating an inhalation hazard. Additionally, there are several state and federal requirements which regulate activities involving ACM.

The University operates a full-service in-house Asbestos Abatement Program and asbestos laboratory through Environmental Health and Safety (EHS). EHS developed this Asbestos Policy and the Asbestos Program to provide controls, procedures, and requirements to address asbestos abatement activities. The Asbestos Program outlines the principal elements for abatement processes, which include the surveys, training and certification requirements of the asbestos abatement personnel, proper procedures for activities that have the potential to disturb ACM or Presumed Asbestos Containing Material (PACM), and proper disposal of asbestos waste. For additional information related to the Asbestos Abatement Program refer to the EHS website.
All removal or disturbance of ACM shall be performed under controlled conditions by EHS or by an approved licensed and certified abatement contractor.

Training

University personnel involved in asbestos abatement work must receive training as required by applicable regulations and certification frequencies. These records are maintained by EHS. Additionally, training is required for University employees whose job functions involve maintenance projects and cleaning where there is the potential for the disturbance of ACM or PACM. University Facilities Maintenance and Custodial personnel shall receive initial training upon joining the related departments as well as annual awareness training. EHS provides the required training and maintains documentation of the training as does the departments responsible for coordinating the training for the specific employee and their related supervisors.

Additionally, all abatement contractors engaged by the University must provide proof of adequate and current training and certification prior to being allowed to sample, remove, encapsulate, or disturb materials joined with, adjacent to, or containing asbestos. This is documented within the University's contract documents and reviewed by EHS as needed or required.

Surveys, Identification, Sampling

University departments must contact EHS prior to the remodel/renovation of any building space, demolition of any building or structure, or the modification of any mechanical system so that affected building materials can be inspected for ACM. EHS is responsible for the sampling and analysis of suspected asbestos containing building material on campus. Prior to renovation projects and/or maintenance operations that have the potential to disturb building materials, EHS samples and provides analysis of building materials to determine if asbestos is present. Additionally, to prevent exposure of building occupants to asbestos fibers, periodic surveillance of known locations of friable and non-friable ACM will be performed as needed to determine if damage or deterioration has occurred. This also includes response to complaints of suspected ACM.

Sampling of building materials can be requested by contacting the EHS Environmental Safety Manager at 205-348-5905 so that additional details can be gathered regarding the site and locations of any concern(s). EHS or approved accredited inspector(s) must conduct the sampling. EHS maintains a database of all sampling results. Information regarding the status of building materials and sampling results is available from EHS by contacting the Environmental Safety Manager.

ACMs identified as part of any renovation, demolition, or construction project may only be disturbed, removed, or encapsulated by trained and certified personnel prior to or during the project. A written plan specifically detailing the management techniques for the identified asbestos must be developed and included as part of the project description. This plan will define the work area and conditions. Areas with known ACM will be clearly identified in project plans and at the pre-bid walk-through. Any suspected ACM not previously sampled will be sampled by EHS or an approved inspector designated by EHS, and a modification will be made to the scope of work for the project once results of analysis are complete.

Encountering ACM

Any University personnel, contractors, or individuals performing work on campus are responsible for ceasing operations once any suspected ACM is encountered. The project will then be evaluated by EHS personnel to determine the appropriate response. The Environmental Safety Manager is the contact to coordinate sampling of building materials and request reports or exposure assessments.

Campus Maintenance and Renovation Projects

All renovations, additions, and maintenance on campus will be addressed through internal processes by the Facilities and Grounds Department or Construction Administration. These processes will result in the project either being managed by appropriate University personnel such as EHS, or outsourced to a qualified third-party consultant. If departments desire to renovate spaces, and ACM is discovered during this process, the total projected costs must include the costs associated with removing the ACM, and estimates being prepared must reflect this possibility to ensure ACM is removed prior to renovation or as part of the requested renovation. Departments who undertake renovation projects need to be aware that no central funding for asbestos abatement exists; therefore, departments must set aside the necessary funding in the event ACM is discovered as part of a department requested renovation project. Proper training and certification documentation must be submitted for evaluation prior to a third-party professional being retained to complete the requested work. EHS periodically audits the asbestos program's activities, files, and records to ensure compliance with federal, state, and local regulations. Work schedules and activities will be planned to minimize the impact of asbestos abatement on any areas that may be occupied near the scope of the project.

Purchasing

The University will not knowingly purchase products that contain asbestos. The only exception is in the case of funded research projects. Researchers including asbestos into projects must contact EHS prior to submitting any requests for funding, and prior to obtaining any ACM or PACM. Safety Data Sheets are an excellent resource for the identification of asbestos containing materials.

Scope

This policy applies to University faculty, staff and approved contractors.

Office of the Vice President of Finance and Operations

Approved by Cheryl Mowdy, Assistant Vice President for Finance and Operations, 09/13/2022