Physical Plant Services: Asbestos Inventory Introductory Comments

  • This document must be included with any review or printing of the UWM Asbestos Inventory.
  • The revised OSHA Occupational Exposure to Asbestos standard (29 CFR 1926.1001, issued October 14, 1994) requires that the "employer" communicate the hazards of asbestos to the "employee". Employees at UWM having occupational exposure to asbestos may include trade, maintenance, technical, and housekeeping personnel.
  • UWM provides 2-hour Asbestos Awareness Training to employees having occupational exposure to asbestos. Call Physical Plant Services (x4576) to register for this class.
  • Federal and State laws require the "building owner" (i.e., State of Wisconsin-Department of Administration and UWM) to maintain records of all information concerning the presence, location and quantity of Asbestos Containing Material (ACM) in our facilities.
  • Bulk samples to determine if a substance is ACM have been taken at UWM since ~1984. There are currently three thousand records on file for samples obtained at UWM.

Please Note:

  • Not all building materials at UWM have been tested. If in doubt whether a material is asbestos-free, make sure to have it tested before disturbing it. Per OSHA guidance, unknown materials are considered "presumed asbestos containing materials (PACM)" until proven otherwise.
  • The "older" data in the UWM Inventory may not be as descriptive as the more recent data. In some cases, there is very little information indicated as to what specific material was actually sampled or in what exact location. There may be more detailed information in the field notes or in the actual lab report.
  • The inventory is frequently updated. Check with Physical Plant Services for data interpretation, or for the most current and detailed information.
  • The Physical Plant Services Asbestos Management Program Index Page is now the primary source for the most current asbestos management information at UWM.
  • By definition, any material with greater (>) than 1% asbestos is considered ACM. The inventory will designate these materials as "POSITIVE". Materials with less than 1% are designated as "NON-ACM" in the inventory; however, these materials may still be regulated in regard to work practice and exposure control techniques. Only materials with no traces of asbestos are considered asbestos-free, and are designated as "NEGATIVE" in the inventory.

OSHA Interpretation: Materials Containing Less Than 1% Asbestos, 04/17/1997

...It is accurate to say (a material) that contains less than one percent asbestos is not ACM by OSHA’s definition. The one percent cut off is consistent with EPA’s definition under the asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP). However, the OSHA standard has a definition for both "asbestos" and "asbestos-containing materials." The definition of asbestos does not have a one percent cut off, therefore, asbestos that is present in percentages less than one percent continues to be covered by the OSHA standard. Work operations conducted in areas where the asbestos or asbestos product is below one percent is an "unclassified" operation. The employer still must follow the requirements in paragraphs (g)(1) [except (g)(1)(i)], (g)(2) and (g)(3) that describe engineering and work practice controls operation.

  • At UWM, we use polarized light microscopy (PLM) for our bulk sample analysis. Unfortunately, PLM for determining asbestos content is sometimes inconclusive when the asbestos content is below five percent, especially for certain materials, for example, flooring, plaster and paint. PCM point counting quantitation protocol is often recommended if the percentage is less than ten percent simply by PLM analysis (Source: EPA Asbestos NESHAP Applicability Determination for Paint, 1990). Even at lower asbestos percentages, a hazard exposure assessment is still necessary to determine appropriate work practice controls and exposure control methods.
  • Occupational exposure to asbestos fibers can cause several lung diseases, including cancer. This is why work involving ACM is carefully controlled and supervised.
  • OSHA has developed the following types of work categories:
    • Class I: Removal of thermal system insulation (TSI) or surfacing ACM.
    • Class II: Removal of material that is not TSI or surfacing ACM. For example, floor tile, wallboard, roofing material, mastics, etc.
    • Class III: Repair and maintenance operations, where TSI or surfacing material may be disturbed.
    • Class IV: Housekeeping activities where ACM may be encountered (custodial or maintenance activities).
    • Unclassified Operations:Work operations conducted in areas where the asbestos or asbestos product is below one percent.
  • Most work at UWM involves Class III or Class IV work. Specialized training is required for these activities:
    • Class IV: Two-hour awareness training is required for Class IV work. Examples of this work include floor maintenance, and cleanup activities. Physical Plant Services provides initial training about twice a year. Thereafter, refresher training is provided about once a year.
    • Class III: Sixteen-hour (16) training is recommended for Operations and Maintenance (O&M) work. Examples of this work include maintenance and repair operations where asbestos is disturbed, such as small glovebag or floor tile jobs. Physical Plant Services or outside contractors can provide the initial training. Annual refresher training is required thereafter. Workers performing Class III abatement must be able to wear a respirator and must be included in UWM's respiratory protection program (e.g., training, fit testing, annual medical, periodic air/exposure monitoring, etc.).
    • Class I, and Class II: This work at UWM is currently performed by outside contractors. Forty-hour (40) training is required for this type of abatement. Examples include large scale insulation or surfacing removal, and large scale floor tile and roofing jobs. Most Class III work is also performed by outside contractors.
    • 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.

Additional Information:

  • The Department of Physical Plant Services will sample and test suspect ACM at UWM facilities. Call Robert Grieshaber, UWM Industrial Hygiene Specialist (x-4576) for this service. If submitting samples for analysis, please include the building; room number; and brief description, including color, size, the type of utility if applicable. Only personnel authorized by PPS may submit samples.
  • Turn around time for bulk sample results is usually 7-10 days. Results can be obtained in as little as 24 hours IF prior notice is given to the lab. There is an extra charge to UWM for expedited service. The cost of not doing a test and having a project result in asbestos contamination, then requiring remediation can run into the tens of thousands of dollars.
  • When working with ACM, it is critical to prevent the material from becoming a dust and then getting into the air. Keeping a material wet is the best way to ensure that this does not happen.
  • FRIABLE material is defined as being easily turned into a dust with only finger pressure. Most thermal system insulation is in this category. Non-friable material does not meet this definition. Non-friable material MAY be turned into friable material however, by sanding, drilling, cutting, breaking, etc. Floor tile and transite board is in this category.
  • You must have training in order to work with ACM (2 hour awareness, or 16-hour for Operations and Maintenance type activities). You must have additional training and be certified to be involved in other than OSHA Class III or IV projects involving asbestos.
  • For purposes at UWM, an OSHA Class III project (formerly referred to as a simple, "small scale-short duration", or operations and maintenance project), is generally defined as being no more than 3 small pipe fittings, or 9 square feet of ACM (i.e., floor tile). Other examples include: only 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 into transite; or minor repairs to damaged ACM. More complicated projects or any projects with exposure potential are not considered Class III.
  • Only a HEPA vacuum and wet methods may be used for asbestos clean up activities.
  • As a precautionary measure, respiratory protection is generally always worn when working with asbestos. You must be involved in UWM's respiratory protection program to wear a respirator.
  • Projects involving more than 160 square feet, or 260 linear feet of ACM, require at least a 10 day notification to the DNR, DHSS, and the City of Milwaukee before the start of the project.
  • ACM waste must be properly disposed of. Call for further information on necessary waste disposal requirements.
  • The rules regarding asbestos can appear complicated and burdensome. With your assistance, this work can be done safely and with minimal disruption.
  • Interpretation of the inventory information can be obtained by contacting UWM Physical Plant Services: Robert Grieshaber, 229-4576, voice pager #198

Common Abbreviations Used In The Inventory:

  • ACM: Asbestos Containing Material (>1% asbestos content)
  • PACM: Presumed Asbestos Containing Material, or material that has not been tested as being negative for asbestos content. If you don't know for sure, you must assume it's asbestos.
  • "<": Less than...
  • ">": Greater than...
  • N or E or S or W: North, East, South, or West
  • AHERA: EPA's Asbestos Hazard Emergency Response Act
  • A: Attic
  • AC: Air Conditioning System (HVAC)
  • B: Basement
  • HEPA: High efficiency filter capable of capturing asbestos
  • HVAC: Heating, Ventilation, Air Conditioning System
  • LAV: Lavatory
  • LRG: Large
  • NEA: Negative Exposure Assessment
  • OSO: Outside of
  • PEL: Personal Exposure Limit (air monitoring)
  • SM: Small, or Surfacing Material
  • T: Trace Amount
  • TSI: Thermal System Insulation

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Updated November 19, 2007