TO: All Members of the University Community 1997:45
DATE: September 1997
To provide for policy and procedure for inspection for Asbestos Containing Material (hereinafter ACM) and implementation of an appropriate response action with respect to ACM in the University’s building.
It is the policy of Ferris State University that the University shall comply with all State and Federal Laws as applicable to asbestos.
The presence of ACM in a building raises a multitude of questions as to the condition of the ACM and the safety of the occupants and visitors of the building. The mere presence of ACM in a building does not necessarily endanger the safety of the occupants and visitors as long as the ACM is in good condition and is not disturbed. Therefore, the following procedure is hereby established to effectuate asbestos control to minimize the risk of injury to students, faculty, staff and visitors to the University.
Inventory of Buildings
An inventory of all ACM in the buildings of the University shall be developed as is reasonably feasible. Said inventory shall include results of all visual inspections, sampling and testing of suspected material, labeling of ACM and complete documentation for all findings. The results of said inventory shall be available in the office of the Physical Plant Department.
Operations and Maintenance Program
An operations and maintenance program (OMP) shall be established and implemented by the Assistant Vice President, Physical Plant, after consultation with the Environmental Health and Safety Officer (hereinafter EHSO). The OMP shall establish procedures for the maintenance and eradication of ACM, establish training and procedures for the affected staff in the proper and safe method of cleaning and maintenance of ACM, and the inspection as needed of all ACM for evidence of damage and disturbance.
All abatement projects shall be performed by licensed asbestos abatement contractors, except such projects as may be safely completed by properly trained and certified employees of the University.
The Occupational Health and Safety Act (OSHA) requires awareness training on the health and safety aspects of asbestos for all employees likely to be involved with removing, altering or otherwise disturbing asbestos, such as maintenance, janitorial, building and/or equipment repair persons and communications personnel whose duties may place them in contact with ACM. EHSO shall provide said training to all present and new employees who may, as a part of their assigned duties, need to work with or in close proximity to ACM.
Outside contractors and/or their employees who are likely to be involve with removing, altering or otherwise disturbing ACM shall present sufficient proof that the contractor and/or their employees have sufficient training pursuant to OSHA regulations.
Additional training shall be provided by EHSO for employees who are engaged in abatement of friable asbestos material. All training shall comply with OSHA regulations and shall include the proper use of respirators and other protective gear as well as safe procedures for asbestos removal. All records of training shall be maintained by EHSO as required by OSHA.
A respiratory protective program shall be established and maintained by EHSO in accordance with OSHA regulations. The program shall include training, respiratory maintenance, medical examinations and testing, and respiratory fit testing. EHSO shall maintain and monitor all records of the respiratory protective program in accordance with OSHA regulations. All records as are required by OSHA as it pertains to training shall be available through the Physical Plant Department.
Ferris State University shall comply with 29 CFR 1926.1101 (August 10, 1994) for the identification of possible asbestos hazards notifications to building occupants before ACM removal, and contractor notification (except in emergency situations)
EHSO shall establish and maintain an asbestos testing program including bulk samples and high volume air samples. All bulk samples shall be submitted to an independent industrial hygiene laboratory for analysis. All high volume air samples shall be submitted to an independent laboratory for analysis. Records of all analysis and all bulk samples shall be maintained in accordance with OSHA regulations. All such records shall be available through the Physical Plant Department.
Personal air sampling shall be conducted by EHSO of all Ferris State University employees engaged in asbestos abatement. High volume air sampling shall be conducted before and after all asbestos abatement projects and as otherwise deemed necessary to make an assessment of ACM conditions.
The Assistant Vice President, Physical Plant, or his/her designee, shall be responsible for the implementation and administration of the asbestos control program of the University.
The University shall not purchase, accept, or otherwise acquire or receive any new or used personal property which contains asbestos except in situations where the acquisition of such property is necessary and is unavailable without the asbestos. The acquisition of property containing asbestos shall only be permitted on a temporary basis and only upon prior authorization of the Vice President for Administration and Finance, after notice of a consultation with the Risk Manager, the Environmental Engineer, and the EHSO officer.
ACM shall not be used in renovation or new construction of any buildings on campus.
The University shall not knowingly sell, barter or trade any equipment or material containing asbestos. All waste material or other equipment or material containing asbestos shall be properly disposed of in accordance with regulations, including but not limited to, being thoroughly wetted or encapsulated, placed in sealed impermeable containers, labeled with an asbestos caution notice, and transported to an type II sanitary landfill for disposal.
Prior to the sale, barter or trade of any equipment or material EHSO shall be notified of the pending transfer sufficiently in advance so the EHSO or his/her designee has an opportunity to inspect, test as necessary and remove prior to the transfer all equipment or material containing ACM.
Repair, clean-up, and disposal of all asbestos material shall be in accordance with OSHA regulations, in conjunction with the rules and ;regulations of all other applicable governmental agencies, including but not limited to, the Environmental Protection Agency, the Department of Environmental Quality, and the State Public Health Department.
This policy shall be reviewed and revised annually, or as otherwise required by regulations, by the Environmental Engineer, through the Office of the Assistant Vice President for Plant Management, and in consultation with the EHSO Officer and the Office of the General Counsel. Any revision of this policy shall be effective upon approval of the revised policy by the Vice President for Administration and Finance.
Richard P. Duffett,
Vice President for Administration and Finance
Contact: Physical Plant