Introduction
The goal of the Asbestos Control Program is to: 1) manage the asbestos containing materials (ACM) in UNC buildings to ensure that exposures to personnel and the environment are minimized and are below the OSHA permissible exposure limit (PEL); 2) that all removal and disposal of ACM complies with all OSHA, EPA, and State regulations, and State Construction Office requirements; and, 3) maintain records of surveys, monitoring activities, class III asbestos work activities, and personnel exposure. The requirements of these standards are summarized below:

OSHA
OSHA regulates occupational exposure to employees who are involved in removal of ACM or whose jobs require them potentially disturb or otherwise are exposed to ACM (29 CFR 1926.1101, Construction Standard; and 29CFR 1910.1001, General Industry Standard). The standard establishes exposure limits, and requires exposure monitoring, medical surveillance, recordkeeping, provisions for regulated areas, and communication of hazards. The permissible exposure limits (PEL) established by OSHA are: 1) 0.1 fibers per cubic centimeter (f/cc) for an 8 hour time-weighted average limit (TWA); 2) 1.0 f/cc excursion limit (EL) as averaged over a sampling period of 30 minutes. OSHA has classified asbestos work in the following categories:

• Class I - activities involving the removal of thermal system insulation (TSI) and surfacing material asbestos containing material (ACM) and presumed asbestos containing material (PACM).
• Class II - activities involving the removal of ACM, which is not TSI, or surfacing material. This includes the removal of asbestos containing wallboard, floor tile and sheeting, roofing and shingles, and construction mastics.
• Class III - repair and maintenance operations, where "ACM", including thermal system insulation and surfacing material, can be disturbed.
• Class IV -the OSHA standards also cover workers who may come in contact with ACM in buildings. This includes maintenance and custodial staff.

EPA
EPA regulates environmental issues such as visible emissions, waste disposal, building demolition, etc. (40 CFR Part 61, subpart M, National Emission Standards for Hazardous Air Pollutants (NESHAPS)). The Asbestos Hazard Emergency Response Act (AHERA, Title II, Toxic Substance Control Act) concerns asbestos containing materials in schools.

NC Department of Environment, Health, and Natural Resources (DEHNR).
Asbestos Hazard Management Program (State Rules) (NC Administrative Code, Chapter 19C, section .0600 and 0607) administered by the Health Hazard Control Branch, DEHNR, regulates public exposure and accredits personnel engaged in asbestos control activities such as asbestos removal workers, supervisors, inspectors, management planners, removal project designers, and air monitors. The air concentration limit for asbestos fibers in public areas is 0.01 f/cc.

State Construction Office
The NC State Construction Office has written guideline criteria for asbestos abatement for State projects.
Training
Class IV Workers' Training. OSHA Construction Standard 1926.1101 requires two hour annual awareness training for all employees who perform Class IV asbestos work. UNC Environment, Health and Safety Office conducts awareness training (EHS course # 4510) every third Friday of each month. Facilities Services Training Coordinator schedules new Facilities Services personnel and annual refresher training for each of their employees. Other training sessions are also coordinated for telecommunication, housekeeping, and moving crew personnel. Training records are kept in Environment, Health and Safety Management Information System.
Awareness training includes the following topics:

• Asbestos forms and uses
• Heath effects from asbestos exposure
• Locations on campus
• Hazardous communication - training and signs / label requirements
• How to recognize friable asbestos
• Recognizing damage and deterioration of ACM
• Precautions to prevent or minimize personnel exposure
• Housekeeping requirements
• Floor care

• History, Types and Use of Asbestos
• Health Hazards of Asbestos
• Medical Surveillance
• OSHA, EPA and State Regulations
• Other Safety and Health Hazards
• Respiratory Protection
• Respiratory Protection / Fit Testing
• Glove Bag Demonstration
• Use of Glove Bags / Cleaning Respirators
• Control Measures and Work Practices
• Use of Mini-Enclosures and Cleaning Contaminated Areas
• Removing Pipe Insulation as One Unit - General Review

Building Surveys for ACM
All buildings constructed prior to 1980 have been surveyed for asbestos. Two building are scheduled each month to update the information on locations and type of ACM present in the buildings. All asbestos containing materials (surfacing materials, thermal systems insulation, and miscellaneous materials) are re-inspected to evaluate their condition and hazard assessment. A report of the location, condition and type of asbestos containing materials is prepared for each building surveyed. The survey is conducted in the evening or on a weekend for areas normally occupied by building occupants. The survey procedure is described below:

1. Notify department heads of inspection.
2. Review existing data in EHS files for the building, including previous surveys, bulk sampling analysis, and previous asbestos removals.
3. Survey equipment needed: TSI sampling kit (cutter sleeves with handle and cases, caulking fill for core holes), respirator, ladder, knife, hammer, chisel, screw driver, pliers, flashlight, spray adhesive, plastic sheeting, portable HEPA vacuum, bags for samples, custody sheet for samples.
4. Confirm ACM locations from previous survey.
5. Identify areas with potential ACM that have not been previously sampled.
6. Evaluate the condition of the ACM for physical damage, water damage, deterioration, and the potential for disturbance due to accessibility of building occupants. Also, evaluate the activities that could disturb the asbestos materials.
7. Collect bulk samples for analysis.
8. Take samples to lab for analysis.
9. Prepare survey report.
10. Send a copy of the building survey to Facilities Services and to the facility department heads.
11. Maintain survey report in EHS files.

Renovation Reviews
Construction and renovation projects are reviewed to assess if asbestos-containing material will be disturbed during the work phase of the project. This is coordinated by reviewing project descriptions and/or drawings submitted to EHS from Facilities Services Architectural and Engineering offices. Requests for review of renovation plans can come from Architectural and Engineering Services, Work Management, Construction Administration, or Facilities Planning.
The following procedures are carried out in the review of construction and renovation projects:

• Review computer log for previous samples collected for the facility
• Inspect job location for homogeneous areas
• Collect bulk samples as necessary
• Document on custody sheet the location and type of material
• After lab analysis send reports and recommendations to the requester

Semi-Annual Inspections
Semi-annual inspections are conducted for buildings containing friable sprayed-on asbestos fireproofing. The inspection consists of an evaluation of the condition of the sprayed-on surfacing material and air monitoring to determine if there are building occupant exposures above the limit for public areas (0.01 f/cc). These buildings include 440 W Franklin St., Hamilton Hall, Nations Bank, and General Administration Building. The following procedures are followed:

1. Contact department/building representative to coordinate the sampling locations and time.
2. Calibrate air-sampling equipment.
3. An air sample is collected on a cellulose ester membrane filter. Approximately 2000 liters of air are sampled. The time of sample and calculation of sample volume are recorded on the sample data sheet and on the 25 mm cassette containing the sample filter.
4. The condition of the ACM is evaluated for physical damage, water damage, deterioration, and the potential for disturbance due to accessibility of building occupants. Also, any activities that could disturb the ACM are documented and evaluated for employee exposures.
5. An inspection report, including air monitoring results, is prepared and sent to department / building representatives.

Complaint Response
Occasionally employees raise concerns about their potential for exposure to asbestos. Their work areas are inspected and their potential exposures are evaluated. This evaluation may require collecting a bulk sample to determine if material involved is in fact asbestos. Air monitoring is performed if there is any disturbance of ACM that could result in personnel exposure to airborne asbestos. Examples of complaints include ceiling material falling onto an employee’s desk, questions about containment during an ACM removal project, damaged ACM debris on the floor, employees encounter potential ACM during the performance of their duties and have questions about their potential exposures. A written report of the investigation is sent to the employee.

Exposure Assessment and Monitoring
OSHA regulations require that each employer who has a workplace or work operation covered by the standard shall perform monitoring to determine accurately the airborne concentrations of asbestos to which employees may be exposed. These must be breathing zone air samples representative of 8-hour time-weighted average and 30-minute short-term exposures. University employees do not perform class I or II operations at this time. The following class III and class IV work operations have been identified for exposure monitoring:
Class III work operations:

• Glove bag removal of TSI
• Non-glove bag repair / removal of TSI, such as on a hot water tank.
• Clean up of damaged friable ACM (TSI or surfacing material) that has fallen to the floor or other horizontal surfaces
• Repair / removal of damaged surfacing materials
• Removal of small amounts of surfacing ACM for maintenance activities or construction activities

• cleaning floors in a ME room that has ACM
• entering an ME room that has ACM
• entering an ME room to perform work on equipment that does not disturb ACM
• buffing/stripping VAT (vinyl asbestos tile)
• repair of fireproof doors
• repair of light fixtures and junction boxes
• conducting work above suspended ceilings - inspection
• conducting work above suspended ceilings - running cable

Inspection of Class III Asbestos Work Teams
Two Building Services work units perform class III asbestos work, the Insulation Shop (removes asbestos thermal systems insulation, spot removals on asbestos surfacing material and vinyl asbestos floor tiles containing asbestos) and Housing Support (removes vinyl asbestos floor tiles and light fixture with asbestos insulation). Quarterly inspections of these teams are conducted to verify:

• work practices are in compliance with OSHA regulations and University policies (proper use of respiratory protection and personal protective equipment, proper work equipment, signs posted, proper containment)
• training records for each employee
• medical surveillance records
• accreditation records
• respirator fit test

Principles of Containment and Personal Protection
When performing class III asbestos work, the following containment and personal protection practices are to be followed:

• Personnel are to wear a minimum of a half face cartridge respirator equipped with a HEPA (N100) filter. Use a glove bag for removal of TSI.
• Plastic sheeting is to be used as a drop cloth on the floor below any TSI and surfacing material that is to be removed.
• Wet methods of ACM removal are to be used to minimize airborne asbestos.
• The room or area must be isolated from the building ventilation system.
• Enclosures under negative pressure are to be constructed to isolate the ACM removal from other areas of the building.
• Warning signs are to be posted outside the room or enclosure with the following information: "Danger, asbestos cancer and disease hazard; authorized personnel only; respirators and protective clothing are required in this area."
• Surfaces potentially contaminated with ACM are to be cleaned using wet methods or a HEPA vacuum.
• Contaminated waste is to be placed in sealed, leak-tight containers and transported to the temporary storage area at Facilities Services.

Inspection of Class I and II Asbestos Work
Class I and II asbestos work on campus is performed by outside contractors. These removal projects are also inspected by the Environment, Health and Safety Office to ensure the safety of University employees occupying areas adjacent to these removal sites. Class I and II removal projects are inspected prior to beginning of work, periodic visits to job site, and after the completion of the project before the clearance inspection. These inspections are coordinated with Building Services Contract Management, who provides University oversight for these contractors. The following items are inspected:

• integrity of containment area (negative air pressure, decontamination area, proper construction of containment)
• use of respiratory protection and other PPE
• use of wet methods
• log book
• proper signs
• inspect accreditation records of contractor’s crew

Warning Signs
OSHA Construction Standard 1926.1101 (k) (5) requires that signs be posted at the entrance to mechanical equipment rooms with asbestos containing material. The signs must identify the type, location and procedures necessary for possible disturbance of asbestos material. Signs are to be placed inside the room so that persons entering the room can see the signs and are forewarned of the presence of asbestos. The degree to which signs and labels are required depends on the exposure potential, access to the asbestos material, and the hazard of the material. The sign for asbestos thermal systems insulation material reads as follows:

Inspection of Housekeeping Buffing Operations
According to OSHA regulations Housekeeping buffers used for stripping floor wax from vinyl asbestos floor tiles must not operate above 300 RPM. Wet methods and low abrasion floor pads are also to be used. Labels are placed on buffers/strippers with adjustable speeds stating: "Do not use above 300 RPM when stripping asbestos floor tiles". These instructions are included in the annual awareness training provided to Housekeeping staff and in written Housekeeping procedures. Semi-annual inspections for housekeeping personnel are conducted to ensure that these requirements are followed.

Medical Surveillance
The employees who are engaged in Class I, II, III work or are exposed at or above a permissible exposure limit and are required to wear negative pressure respirators are provided with an annual medical surveillance program at the University Employee Occupational Health Clinic. The program includes a medical and work history with special emphasis directed to the pulmonary, cardiovascular, and gastrointestinal systems.

Recordkeeping
Records must be kept for all activities of inspections, abatement and sampling. The Environment, Health and Safety Office maintains the following:

• training records
• medical surveillance
• inspection reports
• buildings surveyed for ACM
• bulk sample log for each building on campus
• bulk sample analysis information sheet for each sample collected
• air monitoring data sheet
• air monitoring analysis data sheet
• pump calibration records
• respirator fit testing and medical clearance for each person using a respirator for asbestos related work