Lafayette College’s Asbestos Management Plan has been developed to comply with the requirements of the Occupational Safety and Health Administration (OSHA) Asbestos Standards for General Industry (29 CFR 1910.1001) and Construction (29 CFR 1926.1101), and the Environmental Protection Agency (EPA) Title 40 Part 61 and Part 763.
Due to the presence of asbestos-containing materials (ACM) in various buildings location on campus, this plan includes a number of elements which are designed to protect employees, students, visitors, contractors and other building occupants from potential exposure to asbestos. The Plan also ensures ACM will be handled in compliance with all applicable federal, state and local regulations.
The objectives of the Plan include the inspection and identification of ACM, hazard communication, training and maintenance and repair, or removal, of ACM in Lafayette College-owned facilities.
The requirements of this program apply to all college-owned buildings and employees, including contracted employees, performing maintenance, repair and housekeeping services. In addition, all capital planning, construction, renovation and demolition projects are subject to the provisions of this program.
Facilities Operations and Facilities Planning & Construction must contact EHS during the initial planning stages of a project to reduce the potential for regulatory liability and to ensure an adequate source of funding in the project to address asbestos issues. The Asbestos Coordinator must be notified before physically disturbing any building material, structure or other potential ACM building material.
EHS is responsible for administration of the program. Various departments across campus may be affected by the provisions of the program, as described in the plan. Contractors performing work for the college are also affected by the provisions of the program, to the extent that they must be made aware of the existence of and proper handling of ACM, and that such material must be handled in accordance with this document.
The Asbestos Program Administrator is a member of the EHS staff, who has completed the OSHA 2-hour Asbestos Awareness Training, and has the knowledge and experience related to asbestos and asbestos regulatory requirements to successfully administer the program.
A Permissible Exposure Limit (PEL) has been established by OSHA for airborne asbestos concentration of 0.1 fibers per cubic centimeter (f/cc) for an eight (8) hour time-weighted average. No employee may be exposed above this level without proper personal protective equipment (PPE) and medical surveillance.
A survey was conducted in 2011 to identify the locations of ACM in college-owned buildings, including academic, administrative, athletic and residential buildings on campus, and off campus. A full list of locations where ACM was identified and confirmed is included in the plan, and full reports detailing the results of the survey and sampling can be requested from EHS.
If suspect materials are identified, and evidence of previous sampling cannot be confirmed in previous reports, prior to renovations the following steps should be taken to identify and confirm the existence or non-existence of ACM.
The National Emissions Standard for Hazardous Air Pollutants (NESHAPs) and the Asbestos Hazard Emergency Response Act (AHERA) define an asbestos-containing material as any material containing greater than 1% asbestos as determined by laboratory analysis. ACM is classified by three general uses and three categories of friability, all of which are described in detail in the plan.
OSHA has defined specific categories for various types of asbestos work, which are used in part to determine the level of training, PPE, work area preparation and engineering controls necessary to safely perform asbestos related work. Refer to the plan for an explanation of these categories.
Lafayette College does not perform OSHA Class I, II or III work in-house; it is College protocol to procure the services of a pre-qualified licensed asbestos abatement firm to perform such tasks. All projects involving asbestos abatement, or the potential for disturbance of ACM, must be coordinated through the Asbestos Coordinator.
Designated employees in certain departments are not required to handle, but may come in contact with ACM, which is defined as Class IV work by OSHA. Applicable employees must receive Asbestos Awareness training on an annual basis.
Details and specific guidance in the following categories is covered in the plan.