VI. Obtaining Building Permits

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Environmental Health and Safety

The Office of

Environmental Hazards Policy & Responsibilities

VI. Obtaining Building Permits

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.