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Environmental Health and Safety
Teachers College, Columbia University
Teachers College Columbia University
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Environmental Hazards Policy & Responsibilities

I. Role of EH&S:

The role of the Office of Environmental Health and Safety is to assist the various departments (Capital Projects, Facilities Management, and Residential Services) in complying with the applicable regulations and this policy. In order to insure compliance with this policy the Office of EH&S shall conduct routine inspections/audits of abatement and other construction projects but it is ultimately the responsibility of the TC project manager to monitor the activities of the contractor selected.  EH&S, in consultation with the General Counsel, shall be responsible for regulatory agency correspondence as it relates to environmental projects.

The EH&S office shall generate an "approved asbestos Contractor's list" and an “approved environmental consultant list” which shall indicate those vendors (Contractors and Consultants) approved to work on environmental projects at Teachers College.  Only those firms included on the approved list may participate in environmental projects at Teachers College.

 

II. Notification of the Office of EH&S:

All projects and other events which may potentially involve environmental components must be reported directly to the office of EH&S immediately by phone or utilizing the appropriate form. Examples of such situations are:

  • Maintenance projects
  • General construction & renovation
  • Emergency pipe breaks and floods
  • Electrical work above suspended ceilings, boiler plants
  • Any work in the steam tunnels, or other mechanical equipment areas
  • Building demolition

 

When the following materials/building components may potentially be impacted, the EH&S office shall be notified:

  • Thermal system insulation (pre-1975) including pipe insulation, boiler jackets, etc.
  • Trowelled-on wall & ceiling plaster (pre-1940)
  • Acoustical ceilings (pre-1975)
  • Floor tiles & rolled linoleum (pre-1980)
  • Suspended ceiling tiles (pre-1980)
  • Spray-on fireproofing (pre-1975)
  • Roofing (field and flashing)

 

When there is any potential for an asbestos containing material to be impacted the office of EH&S shall be notified immediately (212) 678-6640. The Teachers College manager responsible for the abatement is required to notify the office of EH&S of all pending work no less than 72 hours prior to commencement of work. Emergency work should be reported as soon as manager is aware of need.

 

III. Submittal of "EHS Project Notification form":

The office of EH&S shall be notified of asbestos and lead related events using the Project Notification and Inspection Request Form. The project notification form will be used by the Office of EH&S and the requesting department to capture all the details related to the project this will include, the project requestor, the project type, a written scope of the project, the actions that EH&S will take as a result of the project, and inspection of the project progress and the details of the project logistics. 

 

 

IV. Response from the Office of Environmental Health and Safety:

            1.         Conduct inspection

            2.         Get results

            3.         Provide contractor information to manager.

 

Based on the project  notification and inspection form the office of EH&S will take appropriate actions which may include a review of the scope a visit to the work site (prior to work beginning to verify the scope) providing abatement contractor and monitoring contractor information to the TC Manager and in some cases coordinate prior analytical testing. 

 

V. Review of Asbestos Terminology

In order to provide as much clarity as possible, listed below are a few key definitions:

1.  Abatement - An approved method for handling asbestos containing materials (i.e. removal,  encapsulation, enclosure). 

2.   Air Monitoring - Collection of "asbestos in air samples" by a 3rd party according to method NIOSH 7400 protocol to evaluate the hazard potential of asbestos exposure. 

3.    Asbestos Building Survey - The identification, evaluation, and quantitation of ACM in a building. 

4.   Asbestos Encapsulation/Wrap & Repair - The covering of an asbestos containing material which a bridging or penetrating encapsulating agent or covering the asbestos containing material with a wettable canvas material impregnated with a latex encapsulating agent. 

5.   Asbestos Enclosure - The physical enclosure of the asbestos containing material on the area where the material is present with a hard permanent barrier. The insulated vertical heating risers located behind exterior/perimeter walls and above hard plaster Ceilings may be considered to be enclosed if the walls are not demolished or otherwise penetrated.

6.   Asbestos Containing Material - (by NYCDEP) any material that has been determined by laboratory testing to contain 1% or greater asbestos. 

7.   Asbestos Removal Project - The physical removal of asbestos containing materials by a licensed Contractor employing trained and licensed personnel and following the applicable regulations. 

8.  Friable/Non-Friable - (by NYCDEP) any asbestos or ACM that can be crumbled, pulverized, or reduced to powder when dry, by hand or other mechanical pressure. 

9.   Operations and Maintenance Program - A program which addresses the in-place management of asbestos containing materials to insure compliance with all regulatory programs and protect human health (involves periodic re-inspection and air sampling). 

10.PCM - Phase contrast microscopy is the standard approved method for analysis of "asbestos in air" samples. 

11.PLM - Polarized light microscopy is the standard approved method for analysis of "asbestos in bulk" samples. 

12.TEM - Transmission electron microscopy is the "state of the art" (lowest achievable detection limit) method for analysis of "asbestos in air and bulk samples". 

13.VAT - Non-friable vinyl asbestos containing floor tile. 

14.NYC DEP ACP-7 "Asbestos Project" Notification Form - An ACP-7 must be completed and submitted to the NYC DEP Asbestos Control Department at least seven working days in advance of asbestos abatement projects involving 25 linear/10 square feet or greater of friable ACM per level (in addition, for large projects, the project must be filed with the NYS DOL and EPA NESHAPS division at least 10 calendar days from the start date of the abatement project). 

15. NYC DEP ACP-5 "Not an Asbestos Project" Notification Form - An ACP-5 form has multiple applications; non- friable transite and floor tile as well as "minor" quantities of friable ACM (less than 25 linear/10 square feet) of friable ACM may be removed under an ACP-5; an ACP-5 is also used to provide documentation that, while ACM may be present, it will not be impacted during a renovation project. An ACP-5 form must be signed and stamped by a licensed NYC Asbestos Investigator.

 

VI.

Since many campus buildings were constructed prior to 1975, "asbestos containing" material is likely to be present and may be impacted during HVAC, structural, and other renovation projects. In order to obtain plumbing, electrical, demolition and other Building Department permits (requires ACP-5 submittal) and comply with this policy, an asbestos investigation is required.

 

In order to avoid delaying general construction, it is highly recommended that asbestos related phases of projects (asbestos abatement is usually always prior to the Phase I demolition work and a separate contract to the general contractor) be scheduled as soon as possible once the project is budgeted. If extensive interior demolition work is scheduled, enclosed/concealed ACM running behind walls and above ceilings may be exposed and should be considered in defining the scope of work.

 

The EH&S Office shall review the available project drawings in order to determine whether ACM may potentially be impacted.

 

a.Review of asbestos survey & abatement work conducted previously

Over the past ten years asbestos sampling and analysis work has been conducted for various construction and maintenance projects. The documentation for such previous survey work is available for review at the EH&S office. Upon request the EH&S Office shall search the "Asbestos Building File" for relevant information. Any information retrieved shall be reviewed for integrity and forwarded to the appropriate Facilities Project Manager and/or Capital Projects Project Manager and/or Department Manager. In some instances additional representative bulk sampling and analysis is required to verify the previous survey work.

 

b.Asbestos building surveys/hazard assessments

For major construction and other projects where no previous sampling and analysis data is available an asbestos survey/hazard assessment is required. Such a survey involves collection of representative bulk samples such that various materials may be classified as ACM or non-ACM. Wherever possible the locations of ACM shall be marked on a project drawing.

Protocol for asbestos building surveys

In order to accurately assess the building and follow EPA AHERA protocol for asbestos building surveys the following sample collection frequency shall be utilized for asbestos building surveys:

·         3 samples per homogeneous area/material for surfaces <1000 sq.ft.

·         5 samples per homogeneous area/material for surfaces 1000-5000 sq.ft.

·         7 samples per homogeneous area/material for surfaces >5000 sq.ft.

 

For thermal system insulation (TSI) the general procedure to satisfy the above listed criteria is to collect three samples of each type of homogeneous material per mechanical room/riser area. The procedure for floor tile is self-explanatory (3 samples per 1000 sq.ft. tile + mastic), however confirmatory TEM/NOB (non-organically bound) analysis is required. The material type which requires the greatest number of samples to accurately characterize due to its inherent inhomogeneity and large surface area is wall and ceiling plaster. For example, plaster found on exterior and structural walls is commonly not of the same composition as interior partition wall plaster. In order to provide results which reflect this lack of uniformity a relative large number of samples are required to accurately characterize this material.

 

c. "Negative exposure assessments"/ACP-5's

If, after the asbestos building file search and survey work mentioned above, it is determined that no asbestos may potentially be impacted, a "negative exposure assessment" report (as defined by the most recent OSHA regulations) shall be issued. In addition to the negative exposure assessment, an ACP-5 may be completed and filed with the Building Department as required. It should be emphasized that completion of either a "negative exposure assessment" or ACP-5 is contingent upon no disturbance of ACM for a particular project; it does not require that a building or area be "asbestos free".

d. Management of outside Contractors & sub-Contractors

It is the responsibility of the Facilities Project Manager and/or Capital Projects Managers to insure that all outside Contractors and sub-Contractors comply with this policy and the applicable regulations. As the legal "Building Owner" Teachers College may be liable for all environmentally related incidences regardless of Contractor negligence. This policy shall be incorporated into contracts with outside firms.

 

It is the responsibility of Teachers College to notify outside Contractors of the presence of ACM in the areas which they work.


VII. Procedures for Managing Asbestos Abatement Projects

a.   Preparation of asbestos project specifications/selection of abatement alternative
To summarize, the most common EPA approved asbestos abatement alternatives may be described as the following:

 

Abatement Alternative

Advantages

Disadvantages

1. in-place management/no action (in conjunction with O&M programs

low cost

not permanent remedy ACM must be in good condition

2. complete or partial removal

permanent remedy

highest initial cost

3. encapsulation/wrap & repair

moderate cost

not permanent remedy ACM must be in fair condition

4. enclosure

ACM may be in poor condition

not permanent remedy high initial cost

It is the policy of Teachers College to select the most effective abatement alternative. However, the need for upcoming renovation work (i.e. replacement of the HVAC system) may dictate removal as the most feasible abatement option since it does offer a permanent solution. In many circumstances it is recommended that the Project Manager solicit price quotations for several alternatives such that they may be compared.

 

In addition to asbestos abatement procedures the requirements for 3rd party air monitoring and analysis (including sampling frequency and analytical methodology) shall be outlined in the project specifications. A copy of the project specifications may be forwarded to the appropriate union representatives upon request.

 

b.    Selection of approved licensed Contractor and Project Monitor

If a proposal for asbestos abatement work is approved, a licensed asbestos abatement Contractor and 3rd Party Asbestos Air Monitoring Firm must be retained. Both parties shall be selected from the "Teachers College Approved Asbestos Contractor List" on-file at the EH&S and Facilities Management offices. Standard Facilities Management bidding/contracting rules shall be applied to asbestos abatement projects. Sufficient time should be allotted for the contracting process since the cost of "rush" (i.e. less than 10 days’ notice) is substantially higher than standard projects.

 

c.    Regulatory agency filing requirements/waiting periods

The NYC and NYS asbestos regulations clearly state that it is the abatement Contractor's responsibility to notify the appropriate regulatory agency of the impending abatement project. However, failure to file asbestos abatement projects subjects both the Contractor and the Building Owner to fines.

The filing requirements in NYC are summarized according to the following:

 

Regulatory Agency

Size of Project

Filing Requested

Waiting Period

NYC DEP

Minor (<10 sq./25 ln.ft.)

Small (10-160 sq./25-260 ln.ft.)

Large (<160 sq./260 ln.ft.)

n/a
ACP-7
ACP-7

no
7 days

7 days

NYS DOL

minor
small
large

no
no (full cont.)

yes (glovebag)

yes

n/a
n/a
10 days

10 days

EPA

minor/small
large

no
yes

n/a
10 days

 

It should be mentioned that applicable and special variances to deviate from the regulations normally require three to six weeks to obtain. All variance applications shall be pre-approved by EH&S prior to submittal to the DEP.

 

Copies of asbestos project filings shall be posted in the buildings, on-file at the EH&S office, and be submitted to affected union authorized representatives.

 

The NYC DEP ACP-7 form must be signed and dated by the Contractor, the Building Owner Authorized Representative, and the Project Monitor.

 

d.    Additional air sampling/exposure monitoring required to satisfy union contract requirements:

In addition to the asbestos air monitoring requirements specified in the applicable regulations (only require air monitoring when >10 sq./25 ln.ft. of ACM is disturbed) Teachers College bargaining unit contract may require asbestos air monitoring when any amount of ACM is disturbed. Such additional air monitoring shall be coordinated by the EH&S office.

 

e. Responsibilities of Facilities Project/Construction Managers during abatement projects (see attached checklist):
In order to simplify the construction management aspects of asbestos abatement projects as much as possible an Asbestos Project Management Checklist has been prepared. The items included on the list have been shown to be "critical pathways" to achieving in successful (i.e. no DEP or other violations, content building occupants) projects in a cost effective and timely manner.

 

* Asbestos Project Management Checklist

In order to efficiently manage asbestos abatement projects Facilities Project and Construction Managers should confirm that the following Issues are addressed:

 

Bidding issues

(1) Has the abatement Contractor's scope of work been clearly defined? The project specifications/work plan should provide clear instructions on how to conduct the project (including how the Contractor should file, what engineering controls should be used, etc.)

(2) Have the quantities of ACM, which the cost of the project is primarily based upon, been verified by someone other than the Contractor (i.e. Project Engineer, Director of Environmental Health & Safety)?

(3) Is re-insulation of the removal substrate required by NYC Fire/Building Code? If so, has re-insulation been included in the project bidding specifications?

 

Pre-project administrative issues

The following should be addressed at least 10 days prior to the start of abatement work:

(4) Selection of licensed asbestos abatement Contractor found on EH&S "approved Contractor list"

(5) Selection of licensed 3rd party asbestos air monitoring firm found on EH&S "approved Contractor list" [asbestos air monitoring is typically 15-20% of the total contract value]

(6) Has the project been filed with the NYC DEP, NYS DOL, and EPA as required? If required, have variance applications been prepared and submitted?

(7) Have copies of the filings been forwarded to the EH&S office, the appropriate union representatives, and posted in the building?

(8) Have the appropriate Faculty been notified of the abatement project?

(9) A definite start date for abatement work must be selected (may only be amended one time without monetary penalty from the NYC DEP)

 

Logistical & scheduling issues

The following items should be addressed at least 24 hours to one week prior to the onset of abatement work:

(10) Has a list of emergency phone/beeper numbers been prepared & distributed?; the following individuals should be included:

      Director of Environmental Health  & Safety

      Facilities Project/Construction Manager

      Contractor Supervisor

      Air Monitoring Technician

(11) Has the Contractor provided a written work schedule; has it been distributed to EH&S, the Faculty involved the Project Manager, etc.?

(12) Does the Contractor have access to the space? Have arrangements been made with Public Safety?

(13) The College is normally responsible for providing a source of water and electricity; the Contractor must identify the source and provide suitable hook-ups/panels; have such arrangements been made?

(14) Is there a service elevator available for use by the Contractor for equipment mobilization and bag-out?

(15) Is there space available for the Contractor to store equipment?

 

(16) For full containment abatement projects utility lines running through the work area must be de-activated including electrical, steam heat, and fire alarms; have work orders been completed to accomplish this? [failure to de-activate such lines may result in a DEP violation]

 

Construction phase issues

(17) Are daily air monitoring results being posted in the building, faxed to union representatives, and the EH&S Department within 24 hours of sample collection? Failure to post results may result in a DEP violation and is a violation of the in-house union contract agreements

(18) Are asbestos hazard signs posted in appropriate locations?

(19) Is the asbestos Contractor posing a nuisance hazard to building occupants by generating excessive levels of noise, dust, chemical hazards, etc.?

(20) The Project/Air Monitor must conduct a final visual inspection and clearance air sampling prior to dismantling of the containment; such events should be documented.

 

Project closeout issues prior to payment of Contractor & Consultant

(21) Has the landfill copy of the waste manifest been returned to the EH&S office?

(22) Has the Project Monitor's final report been submitted to the EH&S office?

(23) Has the work area sustained damages (e.g. water damaged carpets, ceiling tiles) which the Contractor should be back charged for?

 

Approved Task Order Vendors

 

Environmental Consulting Services


 

1.    Hillman Environmental Group, LLC

1600 Route 22 East

Union, NJ  07083

(908) 688-7800

 

 

Abatement Consultants

 

1.    Affiliated Environmental Services

450 South River Street

Hackensack, NJ  07601

(201) 931-0313

 

2.    Asbestos Corp. of America

791 Nepperhan Avenue

Yonkers, NY  10703

(914) 965-5829