Asbestos Management Policy

Purpose

Due to the presence of asbestos in our buildings, the University of Dayton (University) has developed a policy designed to reduce human exposure to airborne asbestos fibers and to comply with the various city, state, and federal regulations pertaining to asbestos-containing materials (ACM).

Scope

This policy applies to all faculty, staff, students, visitors, and contractors who work with or around asbestos-containing materials.  The proper management of asbestos-containing materials will help to prevent airborne exposure in University facilities.  The University has developed an asbestos management plan that is implemented through the Department of Environmental Health & Safety (EHS).

Policy History

Effective Date:  December 12, 2006

Approval:  June 7, 2024

Policy History: 

• Approved in original form:  December 12, 2006
• Approved as amended:  January 25, 2016
• Approved as amended:  June 7, 2024

Maintenance of Policy:  Assistant Vice President for Compliance and Environmental Health & Safety, Division of Audit, Risk, and Compliance

Definitions

“Asbestos” is a generic term referring to six naturally-occurring fibrous silicate minerals found predominantly in metamorphic rock.  Asbestos fibers are very small and may remain airborne for several hours when broken-up and dispersed into the air.

“Asbestos-Containing Material” (ACM) means any material containing more than one percent asbestos.  Common examples of ACM include, but are not limited to, pipe and boiler insulation, spray-applied fireproofing, troweled-on acoustical plaster, floor tile and mastic, transite materials (shingles, siding, lab tables, hood walls), roofing materials, wall and ceiling plaster, ceiling tiles, and gasket materials.

“Asbestos Awareness Training” is provided for employees who may be exposed to ACM during the course of the job, i.e. maintenance or custodial personnel.

“Asbestos Project” includes the construction, demolition, repair, remodeling, maintenance, or renovation of any public or private building or structure, mechanical piping equipment or system involving the demolition, removal, encapsulation, salvage or disposal of material, or outdoor activity releasing or likely to release asbestos fibers into the air.

“Presumed Asbestos-Containing Material” (PACM) means thermal system insulation and surfacing material found in buildings, vessels and vessel sections constructed no later than 1980 that are assumed to contain greater than one percent asbestos but have not been sampled or analyzed to verify or negate the presence of asbestos.

Policy

Asbestos-containing material (ACM) shall only be removed or otherwise impacted by a licensed asbestos abatement contractor utilizing licensed workers.  ACM or other asbestos-contaminated debris/waste shall be properly labelled and transported off-site by a licensed waste hauler to a registered landfill where proper manifesting procedures shall be utilized.

I.  All asbestos-related activities will be managed and/or coordinated through EHS for all University-owned property.  Practices include but are not limited to:

• Determine the presence and location of ACM.
• Coordinate, oversee and manage all asbestos projects impacting ACM in University facilities including renovation and demolition.
• Manage all asbestos abatement activities.
• Procure the services of licensed asbestos abatement contractors and consultants.
• Conduct training to inform, provide knowledge, and basic awareness on asbestos issues.
• Manage the campus-wide and residential database including survey and abatement with the associated documentation.

II.  Any University department or contractor that will be performing work with the potential to disturb suspect asbestos-containing materials in University-owned property shall coordinate work through EHS.  EHS shall be provided with the scope of work, including drawings with demolition notes when available, along with the schedule of the project.  All information must be submitted to EHS in a timely manner for coordination and regulatory notification purposes.  

III.  During any project in University-owned property that will involve the disturbance of asbestos-containing materials, the project manager will arrange a meeting with EHS to review the scope of the project and submit in writing detailed information including the scope of work.

Reference Documents

1. Environmental Health and Safety Policy

Applicable Regulations

1. Occupational Safety Health Administration (OSHA) 29 CFR 1926.1101, 29 CFR 1910.1001;
2. Environmental Protection Agency (EPA) 40 CFR Part 61;
3. Ohio Department of Health (ODH) ORC 3710;
4. Regional Air Pollution Control Agency (RAPCA);
5. Department of Transportation (DOT)