Physical Plant Services: Asbestos Management Program



GENERAL OVERVIEW:

The Department of Physical Plant Services offers the following services for the UWM Asbestos Management Program:

  • Asbestos awareness training.
  • Sample collection and analysis of building materials for asbestos content.
  • Project oversight of renovation projects involving asbestos, as well as day-to-day operations-and-maintenance of asbestos containing material (ACM).
  • Liaison with regulatory agencies, other state agencies and the campus community involving asbestos management issues.

ASBESTOS AWARENESS:

  • Physical Plant Services offers 2-hour ASBESTOS AWARENESS TRAINING several times a year. Anyone interested in asbestos related issues may attend. Employees who may be exposed to asbestos on the job are required to attend at the time of initial employment. This seminar is free of charge. Call x-4576 for the next scheduled class.
  • Asbestos was widely used throughout the United States since the early part of the century. Asbestos is truely a wonder material because of it's high tensile strength, flexibility, and resistance to thermal, chemical, and electrical conditions.
  • In general, any building constructed before 1980 may have asbestos containing material (ACM). Physical Plant Services ensures abatement projects follow local, state, and federal asbestos management regulations and that other activities do not disturb asbestos still in place.
  • Asbestos enters the body through inhalation or ingestion. Exposure to asbestos fibers can cause several diseases including lung cancer. The EPA, OSHA, NIOSH, and IARC classify asbestos as a carcinogen.
  • The symptoms of asbestos induced diseases generally do not appear for 10, 20, or more years after initial exposure. The documented health effects of occupational exposure to asbestos fibers is why this material is strictly regulated.
  • OSHA began regulating workplace exposure to asbestos in 1970. In the mid-1980s, the EPA's Asbestos Hazard Emergency Response Act (AHERA) heightened the public's awareness of asbestos. Over the years, more information on the adverse health effects of asbestos exposure has become available. This prompted OSHA to revise the Occupational Exposure to Asbestos standard (29 CFR 1926.1101, August 1994). In November 2000, the EPA adopted by reference the OSHA standards, thereby entending the same protection to state and local government-sector workers as that provided to private-sector workers. The OSHA standard, the EPA Toxic Substances Control Act (40 CFR 763, Section 6), and to some extent the EPA AHERA standard, dictate asbestos management policies and practices at UWM.



ASBESTOS MANAGEMENT:

Please Note: Some abatement projects on campus are managed by the Wisconsin Department of Administration-Division of Facilities Development. Please contact the DOA-DFD construction representative if you have any questions or concerns regarding DOA-DFD projects. For all other abatement projects at UWM, please contact Physical Plant Services.
  • UWM follows a practice endorsed by the U.S. EPA known as: management (of asbestos) in place. The goal is to maintain existing asbestos-containing material (ACM) in a stable condition rather than removal of asbestos for the sake of removing asbestos. The mere presence of asbestos does not constitute a hazard. If the ACM is maintained and undisturbed there is no exposure or risk to a building's occupants. Exposure can occur when the ACM is abraded or otherwise disturbed during maintenance operations, remodeling, abuse, or some other activity.
  • OSHA categorizes abatement projects into four (4) classes:
    • Class I: The most potentially hazardous class of abatement. The removal of thermal system insulation (TSI) and sprayed-on or troweled on surfacing material are examples of Class I activities. Most Class I projects are not completed in a single day.

    • Class II: The removal of other types of ACM other than TSI or surfacing material. Examples of Class II work include floor tile removal and roofing projects.
    • Class III: Repair and maintenance operations. Class III projects were formerly referred to as Operations and Maintenance (O&M) activities, or small-scale/short duration. Generally, Class III projects are completed in less than one day.

      UWM's Class III Criteria Rule-of-Thumb

    • Class IV: Clean-up of ACM waste and debris, or routine cleaning activities involving ACM. Dusting contaminated surfaces, mopping, or other floor care, and cleaning up asbestos-containing materials from thermal system insulation (TSI) are included in Class IV activities.
    • Unclassified Operations:Work operations conducted in areas where the asbestos or asbestos product is below one percent. See Class I, II, III, and IV work categories.
    • All abatement categories have specialized training requirements.
  • Asbestos abatement is a routine occurrence in a facility the magnitude and complexity of UWM. For additional information on recent asbestos management activity, please link to the Asbestos Activity News page.
  • Most often asbestos is removed during maintenance activities, or during remodeling projects. The majority of projects at UWM are regarded as Class III.
  • During larger projects or projects of greater complexity, negative pressure enclosures are constructed to prevent the release of any asbestos fibers into the occupied areas of the building.

Example of a negative pressure enclosure for a Class I abatement project in a campus mechanical room. The large box-like object in the center is a HEPA filtered negative pressure machine. This device both filters the air inside the enclosure of any asbestos fibers that may be liberated during the removal process and prevents the release of any fibers from escaping the enclosure. Negative Pressure Enclosure
  • Physical Plant Services performs air monitoring before, during, and after such projects to ensure that air quality criteria established by the EPA, OSHA, and DILHR is maintained. Contractors also monitor their own employees involved in abatement activities.
  • All projects are conducted to minimize disruption to campus activities. All asbestos abatement projects are clearly labeled to indicate to the campus community that such work is ongoing:
Sign for Regulated Areas
Required sign for regulated areas.
UWM courtesy sign for non-regulated area
UWM courtesy sign for non-regulated areas.
  • Awareness Training is required for Class IV work. Repair and maintenance training is required for Class III work. Additional training and certification is required for Class I or Class II work. The State of Wisconsin DHFS licenses workers for Class I or II work.
  • Only wet methods or a HEPA filtered vacuum may be used for asbestos clean up activities. Respiratory protection is generally required when working with asbestos. Keeping a material wet ensures that the asbestos does not become airborne. Preventing the material from becoming a dust is the critical exposure control measure.
  • State law requires that projects involving more than 160 square feet or 260 linear feet of ACM, require at least a 10 day notification before the start of the abatement. A Class III project is generally defined as being no more than 3 small pipe fittings, or 9 square feet of ACM (e.g., floor tile). Other examples include: amounts that can be removed in a single, small glovebag; removing a gasket on a valve; drilling or cutting a hole into a wall coated with asbestos; or minor repairs to damaged ACM. More extensive projects are not considered Class III.
  • ACM waste must be properly disposed. On campus, the Department of University Safety and Assurances Environmental Affairs staff handle waste disposal of hazardous materials, including asbestos. ACM waste includes both building materials, and articles such as thermal gloves and theatre lamps. Call x4576 for additional information on legal waste disposal procedures and methods.
  • The rules regarding asbestos can appear complicated and burdensome. With your assistance this work can be done safely and with minimal disruption.



CAMPUS INVENTORY:

  • The Department of Physical Plant Services maintains an inventory of asbestos-containing building materials (ACM) at UWM. Questions regarding this inventory should be directed to Robert Grieshaber, Industrial Hygiene Specialist, at x4576 [(414-)229-4576].
  • Questions regarding asbestos other than at UWM should be directed to your local health department, the Wisconsin Bureau of Public Health (608-266-1253), or to the Wisconsin Department of Natural Resources (DNR) Air Management Section.
  • In general, any building or residential structure constructed before 1980 may have asbestos-containing building material. The Business Administration Building, the School of Architecture and Urban Planning, and the Lapham Hall addition are asbestos-free buildings.
  • Contrary to popular belief, most asbestos products are not banned. However, some EPA regulations do prohibit new installation of certain materials like spray-on fire proofing and decorative material. The so-called July 1989 EPA rule commonly known as the Asbestos Ban and Phaseout Rule (40 CFR 763 Subpart I, Sec. 762.160 763.179) originally banned the manufacture, importation, processing or distribution in commerce of many asbestos containing materials; however, this law was substantially vacated and remanded in 1991. The Clean Air Act bans most sprayed-applied surfacing ACM, and wet applied and pre-formed insulation products. The Toxic Substance Control Act bans corrugated paper, rollboard, commercial and specialty papers, flooring felts and new uses of asbestos. It should be noted that EPA does not track the manufacture, processing or distribution in commerce of asbestos containing products (i.e., buyer beware).
  • Bulk samples of suspect ACM have been taken in campus buildings since 1984; over 3,000 records are on file. The inventory is over 100 pages long and is cataloged by building. The UWM Asbestos Inventory is available for public review and can be obtained in hard copy format.
  • Not all materials in campus buildings have been tested or labeled. Make sure to have a material analyzed before disturbing it, if in doubt as to whether a material is abestos-free. The new OSHA standard requires that a building material is presumed to contain asbestos until proven otherwise. In other words, if you don't have documentation that it's asbestos-free it needs to be tested before disturbance.
  • Bulk sample results are usually received within 7-10 days. Results can be obtained in as little as 24 hours if prior notice is given to the laboratory. Expedited analysis costs extra.
  • Any material with greater (>) than 1% asbestos is considered ACM. Materials with less (<) than 1% may still be regulated in regard to right-to-know requirements, work practice and exposure control techniques. Only materials with no traces of asbestos are considered asbestos-free.
  • Control measures to prevent asbestos exposure take effect when any work is conducted on ACM. Regulated areas are established to demarcate locations where a reasonable possibility airborne levels of asbestos may exceed the OSHA Permissible Exposure Limit (PEL) of 0.1 asbestos fibers per cubic centimeter (f/cc) of air.
  • Friable asbestos is defined as being easily turned into a dust with only finger pressure. Most uncovered, dilapidated thermal system insulation is in this category. Non-friable asbestos does not meet this definition. However, non-friable material may become friable material by sanding, drilling, cutting, breaking, etc. ACM floor tile is an example of non-friable material. Friable material is the more hazardous form of ACM.
Unmilled mineral asbestos
Unmilled Mineral Asbestos
(100% Chrysotile)
Click here for larger image (61 kb).
Friable Asbestos Pipe Insulation
Example of friable asbestos pipe insulation (Sample contains 14% Chrysotile and 12% Amosite Asbestos).
  • Asbestos is not unique to this facility. UWM aggressively manages asbestos to minimize any exposure and to ensure compliance with applicable local, state, and federal guidelines and rules.
  • Examples of materials that may contain asbestos:
    • Acoustical material (e.g., plaster, transite board, etc)

    • Adhesives, caulks, glazing, mastics
    • Thermal System Insulation (TSI) (e.g., pipe insulation, HVAC duct insulation)
    • Boiler/Furnace insulation and breeching
    • Chalkboards
    • Cooling towers
    • Surfacing material on walls or ceilings
    • Textured surfacing material
    • Transite panels (e.g., garage door panels, fume hood walls, fire walls, acoustical board, etc.)
    • Electrical insulation and wiring
    • Fire-proofing material
    • Fire-protective clothing
    • Fire-rated asbestos core doors
    • Fire-stop material and fire-resistant drywall
    • Floor tile (especially 9-inch tile) and tile mastic
    • Hair dryers (insulating material)
    • Heating pads
    • HVAC duct connectors
    • Joint/spackling compound
    • Lab hoods, benches, ovens, gloves, insulating material
    • Vinyl sheet flooring
    • Roofing materials
    • Siding, Roofing Paper, Shingles and Adhesives
    • Textured paints and coatings
    • Theatrical lamps (insulation)
    • Theatrical (fire) curtains
    • Brake pads / Clutch disks
    • Roofing shingles and adhesives
    • Some ceiling tiles
    • Some plasters
    • Some cements
    • Some spackling compounds
    • Asbestos cement pipe

AIR SAMPLING METHODS:

  • Air sampling is usually conducted before and during abatement, to monitor workers' exposure, and to ensure that the site has been adequately cleaned (post-abatement, or clearance monitoring).
  • Two methods are used to analyze air samples: Phase Contrast Microscopy (PCM) and Transmission Electron Microscopy (TEM):
    • PCM: The advantages of PCM are the inexpensive cost, the wide-spread availability, the minimal sample preparation, and quick results. PCM is also the OSHA analytical method. The disadvantages are that it is not asbestos specific and fibers smaller than a given size are not counted.

    • TEM: Unlike PCM, TEM is specific for asbestos and even the smallest of fibers are counted. The disadvantages are the expensive costs and slow turnaround times.
  • The clearance level for PCM analysis is 0.01 fibers/cubic centimeter of air (f/cc). Levels above this indicate the need for further cleaning or analysis with TEM to confirm the presence of asbestos fibers opposed to non-asbestos fibers present on the sample. Clearance levels for TEM analysis are less than 70 structures per square millimeter of filter area. The current OSHA Permissible Exposure Limit (PEL-TWA) for asbestos is 0.1 f/cc for an 8-hour day.
  • NIOSH has not established an exposure limit for asbestos, since NIOSH has not identified thresholds for carcinogens that will protect 100% of the population. NIOSH recommends that occupational exposure to carcinogens, including asbestos fibers, be limited to the lowest feasible concentration.

Example of a personal sampling pump with a 25 mm MCE filter used to monitor air quality during asbestos abatement projects. Personal Sampling Pump

Additional information regarding asbestos management at UWM can be obtained by contacting:

Robert J. Grieshaber, CIH, Industrial Hygiene Specialist
Department of Physical Plant Services
University of Wisconsin-Milwaukee
PO Box 413
Milwaukee, WI 53201 USA
(414) 229-4576 (x4576)
rjg@uwm.edu



Updated July 27, 2009 rjg