Creating an Asbestos Operations and Maintenance Program For Your Business

AsbestosThousands of  residential and commercial structures in the U.S. contain many different types of asbestos. Asbestos presents compliance problems home owners and commercial operations and maintenance personnel. This article is focusing on businesses. Staying on top of asbestos training can be time consuming confusing and costly. You have to keep up with Occupational Safety and Health Administration (OSHA) regulations that are in place to protect workers, while the Environmental Protection Agency (EPA) also has numerous regulations designed to address asbestos-containing materials (ACM) management. The EPA recommends implementing an Operations and Maintenance Program to manage asbestos-containing materials (ACM) . These recommendations are not intended for asbestos abatement workers, but ONLY for workers that have may accidentally or incidentally be exposed to asbestos during their regular work.

You Need an Operations and Maintenance Program if Your Workers Have…

  1. Work that is not likely to involve direct contact with asbestos-containing materials (ACM), such as routine cleaning of surfaces where ACM is not present.
  2. Work that may cause accidental disturbance of ACM, such as routine maintenance work in an area that may have ACM like areas above suspended ceilings.
  3. Work that involves relatively small, short-term disturbances of ACM, such as when repairing  a pipe in a boiler room or changing light fixtures.

If the above three factors apply, then an Operations and Maintenance Program can be created with the following components…

  • Appointment of an Asbestos Program Manager (APM) with appropriate authority, knowledge and education to oversee all ACM-related activities including training. EPA recommends The Asbestos Program Manger be EPA accredited under the Asbestos Hazard Emergency Response (AHERA) or state certified as a Building Inspector/Management Planner.
  • Develop an Asbestos Policy for the company.
  • Have the building inspected by an accredited inspector including sampling and analysis of suspect material, an ACM inventory, and assessment of ACM condition and potential for disturbance.
  • Create the Operations and Maintenance Plan based on inspection findings (if large-scale ACM work is required, this work must be performed by trained and accredited asbestos abatement professionals).

For Employees and Contractors

Operations and Maintenance Programs should include a companies employees and all other subcontracted custodial and maintenance workers and contractors, so the EPA recommends the program contain a “work permit system” that requires contractors to obtain a permit from the Asbestos Program Managers (APMs) prior to working in the building.

Renovation Process Needed

The program should call for periodic notification to building tenants and EPA encourages Asbestos Program Managers to have a legal agreement with tenants to notify them before starting any renovations that could result in disturbing ACMs and their exposure.The program should contain a process that includes a review of original inspection records, a sampling analysis, re-inspection, and an additional sampling and analysis if necessary.  Additional steps will be required if  ACMs need to be removed. According to the Asbestos National Emissions Standards for Hazardous Air Pollutants (NESHAP) ACM removal is required for projects that would break up at least 160 square feet of surfacing or miscellaneous material, at least 260 linear feet of material on pipes, or at least 35 cubic feet on facility components not measured prior to stripping.

Need someone to help you create and maintain your  Asbestos Operations and Maintenance Program? We can handle it for you, so you can focus on your core business.

Contact Us (859-689-9222 – KY, 513-367-4100 – OH) to get more information about how we can help your business.

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