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Policies & Procedures

Policies & Procedures

Asbestos Management Program

I.  Introduction

    A.  Summary of Asbestos Management Program

The School District of Philadelphia Asbestos Management Program was established to meet the requirements of the Occupational Safety and Health Administration (OSHA) General Industry Standard (29 CFR 1910.1001) and Construction Industry Standard (29 CFR 1926.1101), the United States Environmental Protection Agency Asbestos Hazard Emergency Response Act (US EPA AHERA), the National Emissions Standard for Hazardous Air Pollutants subpart M, Part 61 (NESHAP), the Commonwealth of Pennsylvania Department of Labor and Industry Asbestos Occupations, Accreditation and Certification Act, the City of Philadelphia Department of Public Health Asbestos Control Regulations, and the School District of Philadelphia Asbestos Policy Statement. 

 
This School District of Philadelphia is dedicated to providing a safe and healthful work environment for its employees, students, faculty, contractors and visitors. In recognition of the potential health impacts associated with asbestos, the School District of Philadelphia is committed to a comprehensive asbestos control program.  This program is implemented and maintained through the School District of Philadelphia's Office of Environmental Management and Services (OEMS).  OEMS is responsible for establishing asbestos abatement procedures, asbestos inspection, air- monitoring, renovation, and demolition activities within all School District of Philadelphia owned or leased facilities.

The Asbestos Management Program procedures were developed to ensure the following:

1.  People are not exposed to significant levels of asbestos fibers.

2.  Asbestos waste is handled and disposed of properly.

3.  Members of the School District of Philadelphia community have access to OEMS' information, assistance, guidance, and interpretation regarding asbestos-related matters.

4.  Members of the School District of Philadelphia community have access to each school's Asbestos Management Plan as required and outlined in the US EPA AHERA regulations, including annual written notification to all parents. 

5.  Compliance with all applicable Federal, State and Local Asbestos Regulations Asbestos Management Program

1.0 General

The Office of Environmental Management and Services(OEMS) develops, implements, and manages safety and health programs for the School District of Philadelphia's faculty, staff and students, and assists with ensuring that all contractors comply with Federal, State and Local Environmental Regulations. The OEMS provides the oversight of School District of Philadelphia employees (Environmental Response Team), environmental consultants, and asbestos abatement contractors for all projects within the School District of Philadelphia concerning Asbestos Containing Materials. The control of safety and health hazards at the School District of Philadelphia is primarily through the implementation of engineering, work practice and administrative controls. Personal Protective Equipment (PPE) is used to supplement these controls or whenever the controls are not feasible or are in the process of being implemented. PPE is also recommended whenever exposures to chemical, physical or biological agents can be prevented or reduced by its use.

This written program establishes the procedures and requirements necessary to meet established standards and federal regulations for occupational exposure to asbestos fibers, to meet the requirements of the City of Philadelphia Asbestos Control Regulations which encompasses the disturbance and/or abatement of asbestos containing building materials, and to provide the necessary health and safety protection to School District of Philadelphia staff, faculty, students, contractors and visitors. Requirements outlined in this manual are mandatory in nature where the word "SHALL" is used and are advisory in nature where the word "SHOULD" is used. Summary of Program Execution

1.1 Asbestos Management Program Execution

The Asbestos Management Program is administered by the Office of Environmental Management and Services (OEMS). OEMS provides exposure monitoring services, building inspection/surveys (bulk sampling) for the identification of asbestos containing materials, asbestos project design services, asbestos abatement project and air monitoring services, emergency response to fiber release episodes, education/information, medical monitoring, and training for School District of Philadelphia personnel.

B.  Responsibilities

2.0 Department Chairperson or Director

The OEMS Manager is responsible for:

  • Assuring the health and safety of employees, students and visitors in the School District of Philadelphia facilities under his/her control.
  • Being kept informed of all areas under his or her jurisdiction where potential asbestos exposures exist and initiating protection programs that adhere to the Asbestos Management Program requirements of this manual.
  • Assuring that Asbestos Management Program requirements for principal investigators, project managers, supervisors, or division heads, and School District of Philadelphia personnel under their supervision are adhered to.
  • Ensuring that all employees within the Asbestos Management Program comply with (OSHA 1910.1001 (j) (7) (iv)) and the US EPA AHERA regulations by attending the required annual training.
  • Ensuring the posting of warning labels/signage and Asbestos Inspection Reports where required.

2.1 Supervisor or Project Manager (Capital, Maintenance and Facilities)

Each person who is in charge of a project, maintenance/repair, renovation/demolition, or other activity from Capital, Maintenance, and/or Facilities where asbestos containing materials may be present is responsible for:

  • Identifying, with the assistance of OEMS, asbestos-containing building materials prior to any disturbance of these materials. Various Federal (OSHA and EPA) and City of Philadelphia Asbestos Control Regulations require Asbestos Inspections prior to renovation/demolition activities. This shall be accomplished by following the Asbestos Management Program Procedures.
  • Ensuring that the requirements of the Asbestos Management Program Procedures are followed by all personnel, trades, and contractors who are involved with the project.
  • Reviewing of the required Asbestos Inspections (AIR Form See Exhibit 2.1) prior to activities that may disturb any Asbestos Containing Materials
  • Performing all project related duties as outlined in the Project Manager Responsibilities
  • Keeping the department chairperson or director informed of any actions proposed or taken regarding the Asbestos Management Program.

2.2 Employee –Capital

All School District of Philadelphia maintenance or custodial employee are responsible for:

  • Ensuring that no suspect or asbestos-containing building materials are disturbed in the course of the projects they are performing. This shall be accomplished by notifying their supervisor and OEMS by issuance of a work order permit and verifying that the materials which may be disturbed are non-asbestos containing. If this information is not available or verification has not been made, these materials should not be disturbed.
  • Employees and contractors shall immediately notify OEMS and their supervisor in the event of a potential fiber release episode or upon discovery of visible damage to asbestos containing materials. The types of projects represented as part of the Capital Improvement Program are as follows:
    • Complete Renovation of an existing building that addresses all facility component concerns and educational program needs.
    • Major Renovation of an existing building addressing significant facility component and educational improvements.
    • Addition to an existing building (either as an attachment or stand-alone structure) to accommodate needed program space.
    • Conversion of an existing facility to accommodate a change in educational program.
    • Facility Component Improvement of specific facility needs (i.e. electrical or HVAC system upgrades, ADA improvements, life safety improvements, exterior renovations, etc.).

2.3 Employee - Maintenance

All School District of Philadelphia Maintenance employees are responsible for: 

  • Ensuring that no suspect or asbestos containing building materials are disturbed in the course of their duties or work they are performing. This shall be accomplished by notifying their supervisor and OEMS by issuance of a work order or permit and verifying that the materials which may be disturbed are non-asbestos containing. If this information is not available or verification has not been made, these materials should not be disturbed.
  • Employees shall immediately notify OEMS and their supervisor in the event of a potential fiber release episode or upon discovery of visible damage to asbestos-containing materials.
  • All employees involved in housekeeping activities shall attend annual Asbestos Awareness training program.

2.4 Employee - Facilities & Custodial

All School District of Philadelphia Facilities and custodial employees are responsible for:

  • Ensuring that no suspect or asbestos-containing building materials are disturbed in the course of their duties or work they are performing. This shall be accomplished by notifying their supervisor and OEMS by issuance of a work order or permit and verifying that the materials which may be disturbed are non-asbestos containing. If this information is not available or verification has not been made, these materials should not be disturbed.
  • Employees shall immediately notify OEMS and their supervisor in the event of a potential fiber release episode or upon discovery of visible damage to asbestos containing materials.

2.5 Office of Environmental Management and Services

OEMS is responsible for performing the following functions:

  • Developing and administering the Asbestos Management Program.
  • Providing asbestos-related services to all School District of Philadelphia departments.
  • Conducting required annual training of the Asbestos Management Program and working jointly with departments to schedule training.
  • Identifying and posting areas where labeling/signage is required.
  • Medical Monitoring of OEMS Asbestos Program staff.
  • Certification and training for OEMS Asbestos Program staff.
  • Record keeping as required by US EPA AHERA regulations and Employee Exposure Monitoring.  When information indicates that any employee's exposure to asbestos fibers may equal or exceed an 8-hour time-weighted average of 0.1 f/cc, OEMS shall develop and implement an asbestos exposure monitoring program. The sampling strategy shall be designed to identify employees by work task (job classification) that is exposed to asbestos fibers that exceed an 8-hour time-weighted average of 0.1 f/cc.
  • Employee Notification
    • OEMS shall notify in writing, each employee exposed to asbestos fibers at or above an 8-hour time weighted average of 0.1 f/cc.
    • Observation of Monitoring OEMS shall provide affected employees or their representatives with an opportunity to observe any exposure measurements conducted.
    • Training Program OEMS shall institute a training program which meets the requirements of 1910.1001 (j) and AHERA for all employees who perform housekeeping operations in a facility/school which contains asbestos containing materials or presumed asbestos containing materials, and the affected departments shall ensure employee participation in this program. The training shall be conducted annually for each employee included in the asbestos management program. The asbestos awareness training program shall include: o health effects of asbestos o locations of ACM and PACM in the building/facility o recognition of ACM and PACM damage and deterioration o requirements of the OSHA 1910.1001 standard relating to housekeeping o proper response to fiber release episodes
    • Access to Information OEMS shall make available to affected employees or their representative’s copies of the Occupational Safety and Health Administration (OSHA) General Industry Standard Part 1910.1001 and the department shall post a copy in the workplace.
    • Record keeping OEMS shall maintain an accurate record of all employee exposure measurements. OEMS shall maintain records of employee medical monitoring program. OEMS shall maintain all employee training records. All records shall be provided upon request to employees, former employees, representatives designated by the individual employee, and the Assistant Secretary.
    • AHERA Program OEMS shall distribute to each school principal’s office the annul notification letter to each parent, teacher and assistants per the AHERA regulation. See attached Exhibit 3.6 “Annual Notification Letter Package”
    • Asbestos Worker/ Supervisor-“A-TEAM” OEMS shall ensure that all “A-TEAM” workers/supervisors adhere to the following requirements:
      • All employees shall attend an initial Worker/Supervisor Asbestos Course and maintain the annual re-certification per EPA AHERA requirements and Commonwealth of Pennsylvania Asbestos Occupations, Accreditation and Certifications Act.
      • All employees shall undergo an annual Asbestos Medical Evaluation
      • All employees shall undergo an annual Respirator Medical Clearance
      • All employees shall undergo an annual Respirator Fit Testing

 

REFERENCES and RESOURCES

Applicable regulations for asbestos projects impacted by renovation, demolition, and maintenance activities:

Philadelphia Air Management Services - Asbestos Control Unit 

Pennsylvania Asbestos Occupations, Accreditation and Certification Act 

United States Environmental Protection Agency Asbestos  

Occupational Health and Safety Administration (OSHA)