Asbestos Management Program

The University of Northern Iowa Asbestos Management Plan is established for the protection of all UNI employees. The plan addresses any operation, including maintenance activities, involving potential or actual disturbance of materials that contain asbestos.

The University of Northern Iowa Asbestos Management Plan complies with state/federal regulations (IOSHA, OSHA, and EPA) and is an effort to streamline these compliance documents into one logical and efficient plan.  All university contractors/subcontractors who conduct asbestos-related work located on university property must adhere to all requirements set forth in the University of Northern Iowa Asbestos Management Plan.

UNI has established the Asbestos Management Plan to address a variety of issues regarding asbestos-related work.  The goals of the Asbestos Management Plan are to:

• Minimize exposure of employees, faculty, students, and visitors to airborne asbestos.
• Comply with all pertinent, regulatory, and University requirements related to asbestos-containing materials (ACM).  UNI recognizes and will comply with all applicable Federal, State, and local governing regulatory agency regulations/guidelines pertaining to asbestos-containing materials.
• Establish procedures for the identification, evaluation, control, maintenance, disturbance, abatement, and waste storage/disposal of asbestos-containing materials (ACM) at the University of Northern Iowa.
• Remove, enclose, encapsulate, or repair hazardous asbestos-containing material as required by government or University regulations and as needed to protect human health.
• Provide asbestos awareness training.
• Appoint an Asbestos Coordinator to evaluate potential asbestos-related hazards, coordinate the sampling of suspect materials and oversee asbestos-abatement projects.
• Eliminate the installation of new asbestos-containing material whenever possible.
• Ensure that UNI asbestos-related contracted/subcontracted work is properly planned, reviewed and conducted.

The principal objective of an operations and maintenance asbestos program is to minimize potential exposure of airborne asbestos fibers to all building occupants and maintenance personnel. Individuals involved in an operations and maintenance program are employees who are in casual and non-intentional contact with asbestos because of the nature of their work or mere presence in a building.

To accomplish this objective, an operations and maintenance program shall include work practices to:

• Remove Presumed Asbestos Containing Material (PACM) where needed.
• Prevent further release of asbestos fibers.
• Monitor the condition of ACM and PACM.
• This program includes the following components:
  • Training of affected employees in asbestos awareness for ACM and PACM.
  • Regular documentation of ACM and PACM’s.
  • A permit system to control activities that might disturb ACM and PACM.
  • Procedures for accidental release of asbestos.
  • Procedures for keeping records that pertain to asbestos activities.

The University of Northern Iowa Asbestos Management Plan is applicable to all university employees and to all work conducted under the direction of the University of Northern Iowa.

UNI adheres to and enforces this policy and all applicable Federal, State and local governing regulatory agency laws/guidelines pertaining to asbestos-containing materials and asbestos-related work, including:

• Iowa Department of Labor, Occupational Safety & Health Administration (IOSHA)
  • 29 CFR Part 1910.1001 (Asbestos Regulations)
  • 29 CFR Part 1910.134 (Respirator Regulations)
  • 29 CFR Part 1926.1101 (Construction Asbestos Regulations)
• Environmental Protection Agency (EPA) Guidance Documents
  • Asbestos-Containing Materials in School Buildings, parts 1 and 2
  • Guidance for Controlling Asbestos-Containing Materials in Buildings
  • Managing Asbestos in Place – A Building Owner’s Guide for Operations and Maintenance Programs for Asbestos-Containing Materials.

• Abatement: Any operation that is designed to permanently remove asbestos-containing materials.
• Asbestos: Includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos and any minerals that have been chemically treated and/or altered.
• Asbestos-Containing Material (ACM):  Any material that contains more than 1 % asbestos. Suspect asbestos-containing material includes floor tile, linoleum, pipe and boiler insulation, heat duct wrap and joint tape, cementitous asbestos such as transite or slate siding and roofing, asphalt-based roofing and shingles, ceiling tiles, joint compound, sprayed-on acoustical, decorative texturing and other materials.
• Asbestos-Related Work:  Any work that involves asbestos-containing material and may result in the release of any quantity of asbestos fibers into the air.
• Certified Asbestos Consultant:  Any person who contracts to provide professional health and safety services that relate to asbestos-containing construction material.  The activities of an asbestos consultant include building inspection, abatement project design, contract administration sample collection, preparation of asbestos management plans, clearance monitoring and supervision of site surveillance technicians.
• Disturbance:  Contact with any material that contains ACM or PACM that causes release of fibers.  This term includes activities that disrupt the matrix of ACM or PACM or generate visible debris.  Disturbance includes cutting away small amounts of ACM and PACM.
• Fiber:  A particulate form of asbestos, 5 micrometers or longer, with a length-to-diameter ration of at least 3-to-1.
• Intact:  ACM that has not crumbled, been pulverized, or otherwise deteriorated so that it is no longer likely to be bound with its matrix.
• Presumed Asbestos-Containing Material (PACM):  Materials that may contain asbestos but have not yet been tested.
• Removal: All operations where ACM and/or PACM is taken out or stripped from structures or substrates, including demolition operations.
• Renovation: Any operation that involves altering a facility or one or more facility components in any way.

• Oversee development and implementation of the UNI Asbestos Management Plan.
• Review and evaluate the impact of regulatory changes on the University
• Oversee and maintain records of asbestos awareness training given to University employees.
• Participate in determining the need for baseline air monitoring in occupied buildings.
• Maintain a central location for all asbestos management documentation.

All building asbestos management documents are located in the University of Northern Iowa Risk Management/Environmental Health and Safety Office.  Some of the documents at the location include.

• Air sampling data from abatement and university projects located in the UNI Risk Management/Environmental Health and Safety Office.
• Laboratory results from area/final clearance sampling and personnel monitoring located in the UNI Risk Management/Environmental Health and Safety Office.
• Results from bulk sampling analysis located in the UNI Risk Management/Environmental Health and Safety Office.
• Medical Surveillance Records (all medical surveillance records of University employees will be located in the Human Resource Office).
• Proof of medical surveillance and successful completion of an asbestos physical located in the UNI Risk Management/Environmental Health and Safety Office.

The Asbestos Coordinator will see that the PACM will be tested or removed and disposed in compliance with applicable governing regulatory agency regulations/guidelines pertaining to ACM.  The Asbestos Coordinator will use licensed asbestos contractors (Advanced Environmental and Abatement., Iowa Illinois Taylor Insulation, etc.) with the proper license and permits to remove, store and dispose of ACM.  The approved removal contractor will hire the proper testing lab as required for clearance.

All University personnel who manage construction or maintenance projects will report PACM to the Asbestos Coordinator. The manager/supervisor will inform the Asbestos Coordinator of the nature of the project, request testing for asbestos and provide testing results and records of any asbestos abatement to the asbestos coordinator.

A certified asbestos consultant will be called upon by the Asbestos Coordinator when required. The certified consultant will supervise the asbestos contractor when required by forming a scope of work, supervising containment set up, testing and daily sight visits. All results and reports will be sent to the Asbestos Coordinator.

Any contractor or UNI employee that discovers any PACM on a project controlled by the University will through their supervisor, inform the Asbestos Coordinator who will make all arrangements to address same.

Any contractor and their employees used for asbestos related work shall be licensed and trained in the proper and safe removal of asbestos and will show their license to the Asbestos Coordinator before starting the project.

Asbestos contractor will inform Asbestos Coordinator before beginning a project so that the proper parties can be notified of the project and at the conclusion of project to make a final inspection of area.

All labs used for UNI asbestos work will be licensed for asbestos related testing.

Asbestos abatement contractors must submit a two page Asbestos Notification of Demolition and Renovation Form to the Iowa Department of Natural Resources at least 10 days prior to the start of each project. University in-house projects are exempt from this requirement unless the project involves an abatement of more than 160 square feet, 260 linear feet or 35 cubic feet of asbestos-containing material.  Copies of these forms must be submitted to and retained by the Risk Management/Environmental Health and Safety Office.

All ACM will be transported, stored and disposed of by the removing contractor.

No University employee shall engage in any of the following activities involving PACM.

• Sweeping up of any PACM
• Removing any PACM
• Taking samples of PACM
• Grinding of any PACM
• Power wire brushing of any PACM.
• Disturbing any PACM.

Conditions, accessibility, use factors, etc. are likely to change over time. Therefore, ACM’s require periodic reassessment to determine if changes have occurred that warrant reassessment to a different hazard class.

When suspected asbestos containing material (PACM) is found and must be disturbed to effect needed repairs:

Employee will request that his manager/supervisor have the material tested. Employee will provide the following information to his supervisor:

• Location
• Amount that needs to be addressed
• Type of ACM it is (pipe, floor, tile, plaster, sprayed).
• Relative urgency of access
  • For non-emergency cases, you may contact the Asbestos Coordinator Gordon.Krueger@uni.edu or phone (3-3445). In case of emergency, the supervisor in charge of the project should contact the appropriate asbestos abatement contractor directly (Usually Advanced Environmental Testing and Abatement). In either instance, any paperwork involving testing results and/or abatement that took place during the project must be forwarded to the asbestos coordinator.

The following information should be provided to either the asbestos coordinator or abatement contractor:

• Contact person (person requesting)
• Maintenance group
• Building
• Room
• Exact location of test or removal and how many feet
• Is the material covering a steam or water pipe?
• Is it an emergency
• Required completion date

At this time it will be decided if there is a need to have a test sample taken or if it is to be handled as ACM. This will be based on location or quantity. The Asbestos Coordinator will call the asbestos contractor. If the project is rather extensive, quotes will be requested by facilities management and they will work with the approved contractor to schedule the necessary work.

• If the project is large enough to require containment, the Asbestos Coordinator and/or appropriate Facilities Management personnel will show prospective asbestos removal contractors the area. The original contact person may be asked to assist.
• Facilities Management personnel in charge of the project will send out the request for quotes and the requisition for the PO#.

Once the project date has arrived the unit manager/supervisor will

• Coordinate the shutting off of all affected utilities for the contractor to do his job safely (proper Lock Out/Tag Out).
• Notification of effected parties (Asbestos Coordinator will assist with this).

After contractor has received final clearance to release the area, all systems will be returned to normal.

The following procedures must be followed if asbestos is accidentally released:

• Immediately isolate the area by closing doors and/or erecting temporary barriers to restrict air movement as well as access to the site.
• Notify Asbestos Coordinator.
• If asbestos fibers are suspected to have entered the heating, ventilation and air conditioning (HVAC) system (or may do so), the HVAC system must be shut down and sealed off.
• Through an asbestos contractor, employ thorough cleanup procedures to properly control the ACM, by using wet methods, HEPA vacuums, respiratory protection, etc.
• Asbestos Coordinator will inspect the area before clearance is given. Arrange for the collection of at least one air sample for a final clearance level of no more than 70 structures per square millimeter (strm/mm2) using the Transmission Electron Microscope (TEM) method or not more than .01 fibers per cubic centimeter (f/cc) if using the Phase Contract Microscopy (PCM) method.

The following procedures must be followed if PACM is accidentally contacted:

• MINOR CONTACT (i.e. brushing up against PACM with small amount of fiber sticking to clothes.)
  • DO NOT brush of or blow off PACM.
  • Remove PACM with wet rag or wet paper towel.
  • Wrap wet rag or wet paper towel contain PACM in another layer of wet rag or wet paper towel.
  • Dispose of rags and/or paper towels in a sealed plastic bag.
• MAJOR CONTACT
  • Take measures to terminate contact with PACM.
  • Notify Asbestos Coordinator.
  • Initiate testing procedure for PACM material contacted.
  • Change clothes and shower.
  • Clothing may be bagged and remain sealed until testing procedure determines if ACM is present.

Reviewed by Risk/EHS October 22, 2024