The Catholic University of America

Contractor Safety Guide

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Asbestos

Asbestos-containing material (ACM) is any material that contains more than 1% asbestos, per EPA regulations. OSHA regulations may apply for materials which contain trace levels of asbestos (i.e. less than 1 %). 

The following are examples of products that may be ACMs: flooring products; floor backing, construction mastics; thermal insulation applied to pipes, fittings, boilers, tanks, ducts, or other interior structural components; materials that have been sprayed- or troweled-onto surfaces, such as acoustical plaster on ceilings and fire-proofing on structural members; plaster; drywall and joint compound; textured paints/coatings; cement pipe, wallboard or siding; ceiling tiles; caulks and putties; packing materials; high-temperature gaskets; roofing products.

Consult with CUA representatives to verify asbestos content of suspect building materials prior any work which may result in disturbance.

For asbestos abatement activities, the contractor must abide by all applicable local and federal regulations and CUA abatement specifications.  Responsibilities include, but are not limited to:

  1. provide only trained/certified asbestos workers who will be equipped with necessary personal protective equipment;
  2. supply any other equipment needed to protect the workers and others from overexposure to asbestos;
  3. provide required caution signs and labels;
  4. contain and package the removed asbestos and other waste materials generated so that it does not contaminate the environment and to facilitate proper disposal

Prior to beginning asbestos abatement activities:

  • Notify DC and EPA authorities as required by regulation and obtain needed approvals or permits;
  • Provide two copies of the permits/approvals to the CUA project manager;
  • Submit evidence that each employee on the job has received necessary DC licenses, training and/or certifications, including respiratory protection and EPA abatement worker/supervisor;
  • Submit a detailed, job-specific work plan to be used in the removal and demolition of ACMs for review by CUA's EHS department. Include work procedures, safety precautions and personal protective equipment to be worn. Where applicable, include a sketch of the location, size and details of asbestos control areas; location, layout and details of change rooms; layout and location of waste container pass-out airlock; location of local exhaust equipment; air monitoring to be performed; description of wetting agents or removal encapsulants to be used (MSDSs); and waste disposal plan.

Industrial hygiene services required as part of the work, such as airborne asbestos monitoring, must be conducted by or under the direction of a person certified as an industrial hygienist (CIH) by the American Board of Industrial Hygiene. Laboratory testing must be performed by a laboratory demonstrating proficiency by participation in the AIHA Proficiency Analytical Testing (PAT) Program.  Ambient, area, and/or final clearance air monitoring services shall be provided by a firm under contract with CUA, with whom the abatement contractor shall coordinate. Air monitoring services, with the exception of OSHA required personal exposure measurements, are not to be provided by a firm supplied by the abatement contractor.

Final clearance air sample results for DDOE permitted jobs must be submitted to DDOE within 24 hours in accordance with Chapter 20, Section 8.  The industrial hygiene firm under contract by CUA which collects such samples must coordinate with the abatement firm to ensure this submittal is completed by one of the two involved parties.

Clearly and accurately identify the waste generated that is being removed from campus. During routine business hours, provide all asbestos waste manifests to the CUA project manager for signature.  A representative of the abatement firm may only sign the manifest on the behalf of CUA as the generator for projects conducted outside normal business hours.

REFERENCES

29 CFR 1910.1001;

29 CFR 1926.1101;

49 CFR 171-172;

40 CFR 61, Subparts A and M;

District of Columbia Municipal Regulations (DCMR) Title 20, Chapter 8.