Identification of Asbestos Hazards

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Asbestos Management / Maintenance Work 29 CFR 1910.1001, Asbestos 29 CFR 1910.1001 App A, OSHA reference method Mandatory 29 CFR 1910.1001 App B, Detailed procedure for asbestos sampling and analysis Non- Mandatory 29 CFR 1910.1001 App C, Qualitative and quantitative fit test procedures - Mandatory 29 CFR 1910.1001 App D, Medical Questionnaire; Mandatory 29 CFR 1910.1001 App E, Interpretation and classification of chest roentgenograms - Mandatory 29 CFR 1910.1001 App F, Work practices and engineering controls for automotive brake and clutch inspection, disassembly, repair and assembly - Mandatory 29 CFR 1910.1001 App G, Substance technical information for asbestos Non-Mandatory 29 CFR 1910.1001 App H, Medical surveillance guidelines for asbestos Non-Mandatory 29 CFR 1910.1001 App I, Smoking Cessation Program Information For Asbestos Non- Mandatory 29 CFR 1910.1001 App J, Polarized light microscopy of asbestos Non-Mandatory 29 CFR 1926.1101, Asbestos ASBESTOS Note: This written asbestos program has been developed to protect our employees from airborne asbestos exposures above the TWA and excursion limit where engineering and work practice controls are insufficient. Compliance with this program will reduce employee exposure to or below the TWA and to or below the excursion limit. Identification of Asbestos Hazards Thermal System Insulation (TSI) and sprayed or troweled on surfacing materials in buildings will be treated as asbestos-containing unless it is demonstrated that it is not by: a. Having an completed inspection conducted pursuant to the requirements of AHERA (40 CFR Part 763, Subpart E) which demonstrates that the material is not ACM; or b. Performing tests of the material containing PACM which demonstrate that no asbestos is present in the material. Such tests shall include analysis of 3 bulk samples of each homogeneous area of PACM collected in a randomly distributed manner. The tests, evaluation and sample collection shall be conducted by an accredited inspector or by a CIH. Analysis of samples shall be performed by persons or laboratories with proficiency demonstrated by current successful participation in a nationally recognized testing program such as the National Voluntary Laboratory Accreditation Program (NVLAP) of the National Institute for Standards and Technology (NIST) of the Round Robin for bulk samples administered by the American Industrial Hygiene Association (AIHA) or an equivalent nationally-recognized round robin testing program. 1 of 58

Asphalt and vinyl flooring material installed no later than 1980 must also be considered as asbestos containing unless it is determined that it is not asbestos-containing. When communicating information to employees, PACM will be identified as ACM. Prior to commencement of ACM and PACM abatement activities, we will: a. identify the presence, location, and quantity of ACM, and/or PACM therein. b. inform the following persons of the location and quantity of ACM and/or PACM present in the area and the precautions to be taken to insure that airborne asbestos is confined to the area: 1. owners of the building/facility; 2. all employees who will perform such work and employers of employees who work and/or will be working in adjacent areas. Within ten (10) days of the completion of such work, the building/facility owner and employers of employees who will be working in the area will be informed of the current location and quantity of PACM and/or ACM remaining in the area and final monitoring results, if any. Upon newly discovered ACM and/or PACM on a worksite, information will be conveyed concerning its presence and location and to the owner and to other employers of employees working at the work site within 24 hours of the discovery. To limit access to regulated area whenever airborne concentrations of asbestos are present at or above the TWA and/or excursion limit (See next page), warning signs that demarcate the regulated work areas will be displayed. This would include each location where Class I, II, and III asbestos work is to be conducted. Signs will be posted at such a distance from such a location that an employee may read the signs and take necessary protective steps before entering the area marked by the signs. The warning signs will contain the following information: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTION CLOTHING ARE REQUIRED IN THIS AREA Labels shall be affixed to all products containing asbestos and to all containers containing such products, including waste containers. Where feasible, installed asbestos products shall contain a visible label. 2 of 58

Labels shall be printed in large, bold letters on a contrasting background containing the following information: Note: The PEL s for asbestos are: DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD Time-weighted average limit (TWA). Exposure to an airborne concentration of asbestos in excess of 0.1 fiber per cubic centimeter of air as an eight (8)- hour time-weighted average. Excursion limit. Exposure to an airborne concentration of asbestos in excess of 1.0 fiber per cubic centimeter of air (1 f/cc) as averaged over a sampling period of thirty (30) minutes. All regulated areas will be identified by posting of signs meeting OSHA requirements. Employees who perform housekeeping activities during and after construction activities are covered by the asbestos construction standard. MULTI-EMPLOYER WORK SITES On multi-employer work sites, other employers on the site will be informed of the nature of our work with asbestos and/or PACM, of the existence of, and requirements pertaining to, regulated areas, and the measures taken to ensure that their employees are not exposed to asbestos. All our personnel should understand that asbestos hazards at a multiemployer work site shall be abated by the contractor who created or controls the source of asbestos contamination. For example, if there is a significant breach of an enclosure containing Class I work, the employer responsible for erecting the enclosure shall repair the breach immediately. Lastly, all general contractors on a construction project which includes work covered by 29 CFR 1926.1101 shall be deemed to exercise general supervisory authority over the work covered 29 CFR 1926.1101 even though the general contractor is not necessarily qualified to serve as the asbestos "competent person". As supervisor of the entire project, the general contractor shall ascertain whether the asbestos contractor is in compliance with 29 CFR 1926.1101 and shall require such contractor to come into compliance with this standard when necessary. 3 of 58

GLOSSARY OF TERMS AND DEFINITIONS USED IN THE ASBESTOS ABATEMENT INDUSTRY "AGGRESSIVE METHOD" means removal or disturbance of building material by sanding, abrading, grinding or other method that breaks, crumbles, or disintegrates intact ACM. "AMENDED WATER" means water to which surfactant (wetting agent) has been added to increase the ability of the liquid to penetrate ACM. "ASBESTOS" includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these minerals that has been chemically treated and/or altered. For purposes of this standard, "asbestos" includes PACM, as defined below. "ASBESTOS-CONTAINING MATERIAL (ACM)" means any material containing more than one percent asbestos. "ASSISTANT SECRETARY" means the Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor, or designee. "AUTHORIZED PERSON" means any person authorized by the employer and required by work duties to be present in regulated areas. "BUILDING/FACILITY OWNER" is the legal entity, including a lessee, which exercises control over management and record keeping functions relating to a building and/or facility in which activities covered by this standard take place. "CERTIFIED INDUSTRIAL HYGIENIST (CIH)" means one certified in the comprehensive practice of industrial hygiene by the American Board of Industrial Hygiene. "CLASS I ASBESTOS WORK" means activities involving the removal of TSI and surfacing ACM and PACM. "CLASS II ASBESTOS WORK" means activities involving the removal of ACM which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics. "CLASS III ASBESTOS WORK" means repair and maintenance operations, where "ACM", including thermal system insulation and surfacing material, is likely to be disturbed. 4 of 58

"CLASS IV ASBESTOS WORK" means maintenance and custodial activities during which employees contact ACM and PACM and activities to clean up waste and debris containing ACM and PACM. "CLEAN ROOM" means an uncontaminated room having facilities for the storage of employees' street clothing and uncontaminated materials and equipment. "CLOSELY RESEMBLE" means that the major workplace conditions which have contributed to the levels of historic asbestos exposure, are no more protective than conditions of the current workplace. "COMPETENT PERSON" means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. When dealing with asbestos, the above definition is expanded to deal specifically with asbestos: One who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure, who has the authority to take prompt corrective measures to eliminate them. Additionally, for Class I and Class II work, a competent person is one who is specially trained in a training course which meet the criteria of EPA's Model Accreditation Plan (40 CFR 763) for project designer or supervisor, or its equivalent and, for Class II and Class IV work, one who is trained in an operations and maintenance (O&M) course developed by EPA [40 CFR 763.92 (a)(2)]. "CRITICAL BARRIER" means one or more layers of plastic sealed over all openings into a work area or any other similarly placed physical barrier sufficient to prevent airborne asbestos in a work area from migrating to an adjacent area. "DECONTAMINATION AREA" means an enclosed area adjacent and connected to the regulated area and consisting of an equipment room, shower area, and clean room, which is used for the decontamination of workers, materials, and equipment that are contaminated with asbestos. "DEMOLITION" means the wrecking or taking out of any load-supporting structural member and any related razing, removing, or stripping of asbestos products. "DIRECTOR" means the Director, National Institute for Occupational Safety and Health, U.S. Department of Health and Human Services, or designee. 5 of 58

"DISTURBANCE" means contact which releases fibers from ACM or PACM or debris containing ACM or PACM. This term includes activities that disrupt the matrix of ACM or PACM, render ACM or PACM friable, or generate visible debris. Disturbance includes cutting away small amounts of ACM and PACM, no greater than the amount which can be contained in one standard sized glove bag or waste bag in order to access a building component. In no event shall the amount of ACM or PACM so disturbed exceed that which can be contained in one glove bag or waste bag which shall not exceed 60 inches in length and width. "EMPLOYEE EXPOSURE" means that exposure to airborne asbestos that would occur if the employee were not using respiratory protective equipment. "EQUIPMENT ROOM (CHANGE ROOM)" means a contaminated room located within the decontamination area that is supplied with impermeable bags or containers for the disposal of contaminated protective clothing and equipment. "FIBER" means a particulate form of asbestos, 5 micrometers or longer, with a length-to-diameter ratio of at least 3 to 1. "GLOVEBAG" means an impervious plastic bag-like enclosure affixed around an asbestos-containing material, with glove-like appendages through which material and tools may be handled. "HIGH-EFFICIENCY PARTICULATE AIR (HEPA) FILTER" means a filter capable of trapping and retaining at least 99.97 percent of all monodispersed particles of 0.3 micrometers in diameter. "HOMOGENEOUS AREA" means an area of surfacing material or thermal system insulation that is uniform in color and texture. "INDUSTRIAL HYGIENIST" means a professional qualified by education, training, and experience to anticipate, recognize, evaluate and develop controls for occupational health hazards. "INTACT" means that the ACM has not crumbled, been pulverized, or otherwise deteriorated so that it is no longer likely to be bound with its matrix. "MODIFICATION FOR PURPOSES OF PARAGRAPH (G)(6)(II)," means a changed or altered procedure, material or component of a control system, which replaces a procedure, material or component of a required system. Omitting a procedure or component, or reducing or diminishing the stringency or strength of a material or component of the control system is not a "modification" for purposes of paragraph (g)(6)(ii) of this section. "NEGATIVE INITIAL EXPOSURE ASSESSMENT" means a demonstration by the employer, which complies with the criteria in 6 of 58

paragraph (f)(2)(iii) of this section, that employee exposure during an operation is expected to be consistently below the PELs. "PACM" means "presumed asbestos containing material". "PRESUMED ASBESTOS CONTAINING MATERIAL" means thermal system insulation and surfacing material found in buildings constructed no later than 1980. The designation of a material as "PACM" may be rebutted pursuant to paragraph (k)(4) of this section. "PROJECT DESIGNER" means a person who has successfully completed the training requirements for an abatement project designer established by 40 U.S.C. Sec. 763.90(g). "REGULATED AREA" means: an area established by the employer to demarcate areas where Class I, II, and III asbestos work is conducted, and any adjoining area where debris and waste from such asbestos work accumulate; and a work area within which airborne concentrations of asbestos, exceed or there is a reasonable possibility they may exceed the permissible exposure limit. Requirements for regulated areas are set out in paragraph (e)(6) of this section. "REMOVAL" means all operations where ACM and/or PACM is taken out or stripped from structures or substrates, and includes demolition operations. "RENOVATION" means the modifying of any existing structure, or portion thereof. "REPAIR" means overhauling, rebuilding, reconstructing, or reconditioning of structures or substrates, including encapsulation or other repair of ACM or PACM attached to structures or substrates. "SURFACING MATERIAL" means material that is sprayed, troweled-on or otherwise applied to surfaces (such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, and other purposes). "SURFACING ACM" means surfacing material which contains more than 1% asbestos. "THERMAL SYSTEM INSULATION (TSI)" means ACM applied to pipes, fittings, boilers, breeching, tanks, ducts or other structural components to prevent heat loss or gain. "THERMAL SYSTEM INSULATION ACM" is thermal system insulation which contains more than 1% asbestos. 7 of 58

MEDICAL SURVEILLANCE PROGRAM A medical surveillance program will be instituted for all employees who for a combined total of 30 or more days per year are engaged in Class I, II and III work or are exposed at or above the permissible exposure limit or excursion limit, and for employees who wear negative pressure respirators. Medical examinations will be scheduled at a reasonable time and be performed either by a licensed physician or under the supervision of a licensed physician. All costs associated with medical examinations will be borne by: NOTE: If the person who administers the required pulmonary function test is not a licensed physician, he or she must have had training in spirometry sponsored by an appropriate academic or professional institution. Frequency of Medical Examinations: a. Prior to assignment to an area where negative-pressure respirators are worn; b. When assigned to an area where exposure to asbestos may be at or above the permissible exposure for 30 or more days per year, a medical examination must be given within 10 working days following the thirtieth day of exposure; c. And at least annually thereafter. If the examining physician determines that any of the examinations should be provided more frequently than specified, they will be provided to affected employees at the frequencies specified by the physician. Exception to the above: No medical examination is required of any employee if adequate records show that the employee has been examined in accordance with this paragraph within the past 1-year period. Medical examinations made as indicated above shall include: a. A medical and work history with special emphasis directed to the pulmonary, cardiovascular, and gastrointestinal systems. b. On initial examination, the standardized questionnaire (Part 1) will be completed by the employee receiving the initial medical examination.. On annual examinations the abbreviated standardized questionnaire (Part 2) will be completed by the employee receiving the annual medical examination.. 8 of 58

c. A physical examination directed to the pulmonary and gastrointestinal systems, including a chest roentgenogram to be administered at the discretion of the physician, and pulmonary function tests of forced vital capacity (FVC) and forced expiratory volume at one second (FEV(1)). Interpretation and classification of chest shall be conducted in accordance with Appendix E to 29 CFR 1926.1101., a copy of which is included in this Section of this Project Manual and which is to be provided the examining physician d. Any other examinations or tests deemed necessary by the examining physician. The following will be provided to the examining physician: a. a copy of 29 CFR 1926.1101, Asbestos, as well as copies of Appendices D, E, G, and I to 29 CFR 1926.1101. b. a description of the affected employee's duties as they relate to the employee's exposure; c. the employee's representative exposure level or anticipated exposure level; d. a description of any personal protective and respiratory equipment used or to be used; and e. information from previous medical examinations of the affected employee that is not otherwise available to the examining physician. The Safety Director will obtain a written opinion from the examining physician. This written opinion shall contain the results of the medical examination and shall include: a. the physician's opinion as to whether the employee has any detected medical conditions that would place the employee at an increased risk of material health impairment from exposure to asbestos; b. any recommended limitations on the employee or on the use of personal protective equipment such as respirators; and c. a statement that the employee has been informed by the physician of the results of the medical examination and of any medical conditions that may result from asbestos exposure. d. a statement that the employee has been informed by the physician of the increased risk of lung cancer attributable to the combined effect of smoking and asbestos exposure. 9 of 58

The examining physician will be instructed not to reveal in the written opinion given to the Safety Director specific findings or diagnoses unrelated to occupational exposure to asbestos. The Safety Director will provide a copy of the physician's written opinion to the affected employee within 30 days from its receipt. 10 of 58

MEDICAL OPINION FOR RESPIRATOR WEAR (Date) (Applicant's Name) (Applicant's SSN) TO: Robert Evans Respiratory Protection Program Administrator RE: Medical Opinion for Respirator Use On this date, a chest X-ray, spirometry and physical examination were completed on the above named applicant. It is found that he/she is: a. Eligible to use a respirator. b. Not eligible to use a respirator. a. Eligible to use a respirator. (Respirator type, i.e., ½ face; full face; PAPR; SCBA) b. Eligible to use a respirator with the following restrictions: (Respirator type, i.e., ½ face; full face; PAPR; SCBA) c. Not eligible to use a respirator. (Signature of physician or licensed healthcare professional) (Typed or Printed Name) (Street Address) (City, State, ZIP) 11 of 58

RESPIRATORY PROTECTION PROGRAM FOR ASBESOTS OVERVIEW The best respiratory protection one can have is clean, breathable air. Engineering controls are our first line of defense against contaminated or oxygen deficient air. These controls include, but are not limited to, using measures such as enclosure or confinement to keep atmospheric hazards away from employees, general or local ventilation to exhaust hazardous atmospheres, and/or substitution of less toxic materials to avoid hazardous atmospheres in the first place. When effective engineering controls are not feasible, or during the time frame they are being instituted, appropriate respirators will be used. The concept of respiratory protection is quite simple. Certain types of atmospheric hazards are merely particles that can be filtered out of the air through the use of an air-purifying respirator. Air-purifying respirators force the harmful particles into a filter specifically designed for the hazard(s) where they are trapped or absorbed. The air reaching the employee s lungs is essentially free of the hazard. a. If the action of inhalation causes the ambient air to be sucked through the filter, the respirator is considered a negative pressure respirator. b. If the ambient air is forced through the respirator filter (with a blower, for example), the respirator is considered a positive pressure respirator. A respirator that removes harmful contaminants is of no value in an oxygen deficient (less than 19.5% oxygen) or oxygen enriched (more than 23.5 % oxygen) atmosphere. An atmosphere-supplying respirator will be used in oxygen deficient atmospheres or in atmospheres where a filter cannot reduce the particulate hazard to an acceptable level. This type of respirator provides clean, breathable air from a source independent of the ambient atmosphere. Different types of respirators provide different levels of protection. Never may an air-purifying respirator be substituted for a required atmospheresupplying respirator. Unfortunately, respiratory protection is more complicated than it first appears. Because of the variety and severity of respiratory hazards, the 12 of 58

types of respirators and their limitations, the methods for fitting and testing, and, most importantly, the detrimental ramifications of respirator misuse, this respiratory protection program is required. Proper respirator selection and use can prevent occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays and vapors. In atmospheres that are immediately dangerous to life or health, proper respirator selection and use will save your life. Approved respirators will be used in the four (4) following circumstances; work practice controls, work operations, to reduce exposure, and in emergencies. When required, employees will be supplied appropriate respirators and all incidental costs associated with respirator use (respirators, fit testing, repair parts, filters, medical examinations, cleaning supplies, etc.) will be borne by the company. DUTIES OF THE PROGRAM ADMINISTRATOR The Respiratory Protection Program Administrator will keep abreast of developments in the respiratory protection field and ensure that our personnel are provided safe respiratory working conditions. Our Program Administrator is: Additionally, the Program Administrator will: a. measure, estimate, or review data on the concentration of airborne contaminants in the work area prior to respirator selection. b. select the appropriate type of respirator that will provide adequate protection from the airborne contaminants or provide clean, breathable air. c. explain the purpose, use, and limitations associated with each type of respirator. d. maintain applicable records including: 1. fit test records. 2. medical records. 3. inspection records. 4. evaluation records. 5. training records. Robert Evans 13 of 58

DEFINITIONS There are a number of terms and phrases, not used in ordinary everyday life, which must be understood by affected employees. Air-purifying respirator: a respirator with an air-purifying filter, cartridge, or canister that removes specific air contaminants by passing ambient air through the air-purifying element. Atmosphere-supplying respirator: a respirator that supplies the respirator user with breathing air from a source independent of the ambient atmosphere, and includes supplied-air respirators (SARs) and selfcontained breathing apparatus (SCBA) units. Canister or cartridge: a container with a filter, sorbent, or catalyst, or combination of these items, which removes specific contaminants from the air passed through the container. Demand respirator: an atmosphere-supplying respirator that admits breathing air to the facepiece only when a negative pressure is created inside the facepiece by inhalation. Emergency situation: any occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment that may or does result in an uncontrolled significant release of an airborne contaminant. Employee exposure: exposure to a concentration of an airborne contaminant that would occur if the employee were not using respiratory protection. End-of-service-life indicator (ESLI): a system that warns the respirator user of the approach of the end of adequate respiratory protection, for example, that the sorbent is approaching saturation or is no longer effective. Escape-only respirator: a respirator intended to be used only for emergency exit. Filter or air-purifying element: a component used in respirators to remove solid or liquid aerosols from the inspired air. Filtering facepiece (dust mask): a negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium. 14 of 58

Fit factor: a quantitative estimate of the fit of a particular respirator to a specific individual, and typically estimates the ratio of the concentration of a substance in ambient air to its concentration inside the respirator when worn. Fit test: the use of a protocol to qualitatively or quantitatively evaluate the fit of a respirator on an individual. Helmet: a rigid respiratory inlet covering that also provides head protection against impact and penetration. High efficiency particulate air (HEPA) filter: a filter that is at least 99.97% efficient in removing monodisperse particles of 0.3 micrometers in diameter. The equivalent NIOSH 42 CFR 84 particulate filters are the N100, R100, and P100 filters. Hood: a respiratory inlet covering that completely covers the head and neck and may also cover portions of the shoulders and torso. Immediately dangerous to life or health (IDLH): an atmosphere that poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individual's ability to escape from a dangerous atmosphere. Loose-fitting facepiece: a respiratory inlet covering that is designed to form a partial seal with the face. Negative pressure respirator (tight fitting): a respirator in which the air pressure inside the facepiece is negative during inhalation with respect to the ambient air pressure outside the respirator. Oxygen deficient atmosphere: an atmosphere with an oxygen content below 19.5% by volume. Physician or other licensed health care professional (PLHCP): an individual whose legally permitted scope of practice allows him or her to independently provide, or be delegated the responsibility to provide, some or all of the health care services required medical evaluation. Positive pressure respirator: a respirator in which the pressure inside the respiratory inlet covering exceeds the ambient air pressure outside the respirator. Powered air-purifying respirator (PAPR): an air-purifying respirator that uses a blower to force the ambient air through air-purifying elements to the inlet covering. Pressure demand respirator: a positive pressure atmosphere-supplying respirator that admits breathing air to the facepiece when the positive pressure is reduced inside the facepiece by inhalation. 15 of 58

Qualitative fit test (QLFT): a pass/fail fit test to assess the adequacy of respirator fit that relies on the individual's response to the test agent. Quantitative fit test (QNFT): an assessment of the adequacy of respirator fit by numerically measuring the amount of leakage into the respirator. Respiratory inlet covering: that portion of a respirator that forms the protective barrier between the user's respiratory tract and an air-purifying device or breathing air source, or both. It may be a facepiece, helmet, hood, suit, or a mouthpiece respirator with nose clamp. Self-contained breathing apparatus (SCBA): an atmosphere-supplying respirator for which the breathing air source is designed to be carried by the user. Service life: the period of time that a respirator, filter or sorbent, or other respiratory equipment provides adequate protection to the wearer. Supplied-air respirator (SAR) or airline respirator: an atmospheresupplying respirator for which the source of breathing air is not designed to be carried by the user. Tight-fitting facepiece: a respiratory inlet covering that forms a complete seal with the face. User seal check: an action conducted by the respirator user to determine if the respirator is properly sealed to the face. 16 of 58

RESPIRATOR SELECTION/AREA SURVEILLANCE Appropriate respirators will be selected and used as required on Asbestos Projects as noted below: a. during all Class I asbestos jobs. b. during all Class II work where the ACM is not removed in a substantially intact state. c. during all Class II and III work which is not performed using wet methods. d. during all Class II and III asbestos jobs where the employer does not produce a "negative exposure assessment". e. during all Class III jobs where TSI or surfacing ACM or PACM is being disturbed. f. during all Class IV work performed within regulated areas where employees performing other work are required to wear respirators. g. during all work covered by this section where employees are exposed above the TWA or excursion limit. h. in emergencies. An employee will be provided with a tight fitting powered, air-purifying respirator in lieu of any negative-pressure respirator when it is requested and the chosen respirator will provide adequate protection to the employee. Respirators, filters, cleaning materials and all costs associated with respirator use will be provided at no cost to the employee. 17 of 58

RESPIRATORY PROTECTION FOR ASBESTOS FIBERS Airborne concentration of asbestos or conditions of use Not in excess of 1 f/cc (10 X PEL), or otherwise as required independent of exposure pursuant to (h)(2)(iv) Not in excess of 5 f/cc (50 X PEL) Not in excess of 10 f/cc (100 X PEL) Required respirator Half-mask air purifying respirator other than a disposable, respirator equipped with high efficiency filters. Full facepiece air-purifying respirator equipped with high efficiency filters. Any powered air-purifying respirator equipped with high efficiency filters or any supplied air respirator operated in continuous flow mode. Not in excess of 100 f/cc (1,000 X PEL). Full facepiece supplied air respirator operated in pressure demand mode. Greater than 100 f/cc (1,000 X PEL) or unknown concentration. Full facepiece supplied air operated in pressure demand mode equipped with an auxiliary positive pressure self-contained breathing apparatus. Note: a. Respirators assigned for high environmental concentrations may be used at lower concentrations, or when required respirator use is independent of concentration. b. A high efficiency filter means a filter that is at least 99.97 percent efficient against mono-dispersed particles of 0.3 micrometers in diameter or larger. c. If an employee opts to use a PAPR (that provides adequate protection), he/she will be supplied with a PAPR at no cost. A half-mask air purifying respirator, other than a disposable respirator, equipped with high efficiency filters will be provided whenever employees perform the following activities: a. Class II and III asbestos work and a negative-exposure assessment has not been conducted. b. Class III jobs where TSI or surfacing ACM or PACM is being disturbed. 18 of 58

TYPES OF RESPIRATORS TO BE USED All respirators will be NIOSH approved. In oxygen-deficient atmospheres as well as atmospheres in which the respiratory hazard exposure cannot be determined (Immediately Dangerous to Life or Health atmospheres), one of the below respirators will be used: a. a full facepiece pressure demand SCBA certified by NIOSH for a minimum service life of thirty minutes, or b. a combination full facepiece pressure demand supplied-air respirator (SAR) with auxiliary self-contained air supply. NOTE: Respirators provided only for escape from IDLH atmospheres shall be NIOSHcertified for escape from the atmosphere in which they will be used. Generally, but not always, atmospheres work areas that require respiratory protection are not IDLH and in these cases respirator selection offers more options. The respirator selected will be adequate to protect the health of the employee and ensure compliance with all other OSHA statutory and regulatory requirements under routine and reasonably foreseeable emergency situations. Of course, the respirator selected will be appropriate for the chemical state and physical form of the contaminant. For protection against gases and vapors, the respirator provided will be: a. atmosphere-supplying. b. air-purifying, provided that: 1. it is equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant; or 2. if there is no ESLI appropriate for conditions in respiratory hazard area, a change schedule for canisters and cartridges will be used that is based on objective data that will ensure that canisters and cartridges are changed before the end of their service life. The Program Administrator will rely on past experience and cartridge manufacturer recommendations. If the competent person on site or any respirator user notices that breathing becomes more strained, the change schedule will be modified. 19 of 58

For protection against particulates, the respirator provided will be: a. atmosphere-supplying; or b. air-purifying equipped with a filter certified by NIOSH under 30 CFR part 11 like a HEPA filter; or Note: Filters manufactured under 30 CFR part 11 standards may continued to be used, however, as of July 10, 1998, other than PAPR s, they are not to be purchased. Only 42 CFR part 84 type filters will be used. Note: c. air-purifying equipped with a filter certified for particulates by NIOSH under 42 CFR part 84; or These respirators and filters, other than PAPR s are identified on the packaging with numbers that take the form: TC-84A-XXX. a. Filters will have an N, R, or P designation followed by 100, 99 or 95. Examples: N100 or R99 1. N indicates the filter is for any solid or non-oil containing particulate contaminant. 2. R indicates the filter is for any particulate contaminant. If used for an oil containing particulate, a one shift use limit applies. 3. P indicates the filter may be used with any particulate contaminant. b. The number indicates the filter efficiency -- the higher the number, the more efficient. 100 = 99.97% efficiency; 99 = 99% efficiency; and 95 = 95% efficiency. d. air-purifying equipped with any filter certified for particulates by NIOSH for contaminants consisting primarily of particles with mass median aerodynamic diameters (MMAD) of at least 2 micrometers. PARTICULATE RESPIRATOR SELECTION Prior to respirator selection, the following factors must be known: a. The identify and concentration of the particulates in the workplace air. b. The permissible exposure limit (PEL), the NIOSH recommended exposure limit (REL) or other occupational exposure limit. c. The hazard ratio (HR). The (HR) is obtained by dividing the airborne particulate concentration by the exposure limit. d. The assigned protection factor (APF) for the type of respirator to be used. The (APF) is the minimum anticipated level of protection provided by each type of respirator worn in accordance with an adequate respiratory protection program. For example, an (APF) of 10 means that the respirator should reduce the airborne concentration of a particulate by a factor of 10 (or to 10% of the workplace concentration). 20 of 58

e. The immediately dangerous to lift or health (IDLH) concentration, including oxygen deficiency. The (APF) should be greater that the (HR) and multiplying the occupational exposure limit by the APF give the maximum workplace concentration in which the respirator may be used. All filters will have a 99.97% efficiency rating indicated by the number 100. SERVICE LIFE OF FILTERS If the selected filters have an end-of-service-life indicator (ESLI), the filters will be used until the indicator shows that it is time to be replaced. In the absence of an ESLI, the following is our policy of service life of filters: All HEPA filters manufactured under 30 CFR part 11 (for PAPR s) will be replaced at least daily (once each work shift) or if breathing resistance becomes excessive or if the filter suffers physical damage (tears, holes, etc.) If PAPR filters become available under 42 CFR part 84 standards, they will be used and fall under the below schedule: All filters will be replaced whenever they are damaged, soiled, or causing noticeably increased breathing resistance. N-series filters may be used and reused subject only to considerations of hygiene, damage, and increased breathing resistance. If the competent person determines the workplace to be exceptionally dirty, the filters will be changed each work shift. R-series filter will be changed every work shift if oil is present. If oil is not present, they be used and reused subject only to considerations of hygiene, damage, and increased breathing resistance. If the competent person determines the workplace to be exceptionally dirty, the filters will be changed each work shift. P-series filters will be used and reused in accordance with the manufacturer s time-use limitations when oil aerosols are present. P-series filters can be used and reused subject only to consideration of hygiene, damage, and increased breathing resistance if oil aerosols are not present. 21 of 58

RESPIRATOR FIT TEST There are various protocols for fit testing respirators and they can be found in Appendix A, 29 CFR 1910.134. One of the four qualitative protocols listed below will be used: Protocol/Fit Test Procedure Appendix A to 29 CFR 1910.134 a. Isoamyl Acetate Paragraph B2 Fit Test Procedure Paragraph B2(b) b. Saccharin Solution Aerosol Paragraph B3 Fit Test Procedure Paragraph B3(b) c. BitrexTM Solution Aerosol Paragraph B4 Fit Test Procedure Paragraph B4(b) d. Irritant Smoke (Stannic Chloride) Paragraph B5 Fit Test Procedure Paragraph B5(c) The purpose of fit testing is to ensure that the respirator selected will actually do the job for which it was intended. Different manufacturers make different sizes of each model. Fit testing, following the OSHA approved protocols, will ensure that the specific make, model and size is appropriate for the user. An employee may only use the specific respirator(s) on which he/she has passed a fit test. Eye glasses and contact lenses pose special problems when dealing with respirators. Contact lenses will not be worn during the fit test or during respirator use. Normal eye glasses, while they do not interfere with the skin to facepiece seal of a ½ face respirator, will prevent a proper seal on a full face respirator and thus will not be worn. If glasses are needed, special adapters can be provided to hold lenses within the respirator. Upon successful completion of respirator fit testing, a Record of Respirator Fit Test form will be completed and maintained with the employee s records. Only the latest fit test record need be retained. The Respirator Fit Test will be repeated at least annually or when: a. a different respirator facepiece (size, style, model or make) is used. b. there has been a weight change of at least 20 pounds. c. there has been significant facial scarring in the area of the facepiece seal. d. there has been significant dental changes; i.e., multiple extractions without prosthesis or acquiring dentures. e. reconstructive or cosmetic surgery. f. any other condition that may interfere with facepiece sealing. 22 of 58

As explained in the protocols, the fit tests shall not be conducted if there is any hair growth between the skin and the facepiece sealing surface. Further, there shall not be mustaches that are so long as to interfere with the inlet or exhaust valves in the respirator. Of course, these requirements apply not only to fit testing procedures, they apply to actual on the job use where the seal between face and respirator must be maintained. USER SEAL CHECK A user seal check, performed in accordance with the manufacturer's instructions (or Appendix B-1 to 29 CFR 1910.134), will be made prior to each use by the wearer of a tight-fitting respirator. A user seal check is solely for respiratory protection of the employee and without this check there is no way of knowing if the selected respirator is actually working. Failure to perform a seal check may result in the use of a respirator which is of little or no value. MEDICAL SURVEILLANCE Medical Surveillance is found elsewhere in this Project Manual. However, all persons require medical approval for respirator wear. Medical surveillance determines the fitness for asbestos abatement work and establishes a set of medical data to be used as a baseline against which future medical data can be compared. HAZARD COMMUNICATION & EMERGENCY PROCEDURES One would not be wearing a respirator in the first place if there were not some detrimental health consequences of non-use. Often, these consequences are chronic (long term) and immediately unnoticeable. If respirator failure would lead to noticeable physical or mental impairment, then, in these situations, two (2) employees will be assigned in the same area and in view of each other. If one employee presents symptoms of physical or mental distress, the second employee will remove the first employee from the area. If there is not an immediate, total recovery, the affected employee will be provided medical care by emergency responders. In the event work is being performed in an IDLH atmosphere, a safety harness and safety lines will be used so that the employee may be pulled to safety. Suitable rescue equipment will be available and a standby man or men with suitable self-contained breathing apparatus shall be at the nearest fresh air base for emergency rescue. All personnel should be aware of the appropriate MSDS for the products they are working with, and particular attention should be given to health hazards, both acute and chronic; symptoms of overexposure; first aid measures; emergency procedures; and exposure limits. 23 of 58

WORK AREA SURVEILLANCE The competent person at the work area where respirator use is required will maintain appropriate surveillance of work area conditions and degree of employee exposure or stress. When there is a change in work area conditions or degree of employee exposure or stress that may affect respirator effectiveness, the Program Administrator or competent person will reevaluate the continued effectiveness of the respirator. Employees are to leave the respirator use area: a. to wash their faces and respirator facepieces as necessary to prevent eye or skin irritation associated with respirator use. b. if they detect vapor or gas breakthrough, changes in breathing resistance, or leakage of the facepiece. c. to replace the respirator or the filter, cartridge, or canister elements. Defective respirators will be repaired or replaced before returning to the respirator use area. AIR QUALITY Atmosphere-supplying respirators, depending on the type (supplied-air or SCBA) use compressed air, compressed oxygen, liquid air or liquid oxygen. Compressed and liquid oxygen must meet the requirements of the United States Pharmacopoeia for medical or breathing oxygen. Compressed breathing air must meet the requirements of Grade "D" breathing air including: oxygen content (v/v) of 19.5-23.5%; hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less; carbon monoxide content of 10 ppm or less; carbon dioxide content of 1,000 ppm or less; and lack of noticeable odor. Compressed oxygen shall not be used in supplied-air respirators or open circuit self-contained breathing apparatus that have previously used compressed air. Oxygen must never be used with air line respirators. Breathing air may be supplied to respirators from cylinders or air compressors. If cylinders are used, they will be tested and maintained as prescribed in the Shipping Container Specification Regulations of the Department of Transportation (49 CFR part 178). If a compressor is used for supplying breathable air by way of air line hoses to a respirator mask, it is a Type "C" system. The hose couplings used on these systems must not be compatible with any other gas systems. Breathable air -- not pure oxygen -- is used in these systems. All safety and standby devices will be maintained in working order such as alarms to warn of compressor failure or overheating. Compressors will be located so that contaminated air does not enter the system and suitable in-line filters 24 of 58

will be installed. A receiver of sufficient capacity to enable the respirator wearer to escape from a contaminated atmosphere in the event of a compressor failure shall be in place. If an oil lubricated system is used, it shall have a high temperature and carbon monoxide alarm. Compressed air, compressed oxygen, liquid air, and liquid oxygen used for respiration must accord with the following specifications: a. oxygen concentrations greater than 23.5% are used only in equipment designed for oxygen service or distribution. Cylinders used to supply breathing air to respirators must meet the following requirements: a. cylinders are tested and maintained as prescribed in the Shipping Container Specification Regulations of the Department of Transportation (49 CFR part 173 and part 178); b. cylinders of purchased breathing air have a certificate of analysis from the supplier that the breathing air meets the requirements for Grade D breathing air; and c. the moisture content in the cylinder does not exceed a dew point of - 50 deg.f (-45.6 deg.c) at 1 atmosphere pressure. d. compressors used to supply breathing air to respirators are constructed and situated so as to: 1. prevent entry of contaminated air into the air-supply system; 2. minimize moisture content so that the dew point at 1 atmosphere pressure is 10 degrees F (5.56 deg.c) below the ambient temperature; 3. have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air quality. Sorbent beds and filters shall be maintained and replaced or refurbished periodically following the manufacturer's instructions. 4. have a tag containing the most recent change date and the signature of the person authorized by the employer to perform the change. The tag shall be maintained at the compressor. For compressors that are not oil-lubricated, the competent person will ensure that carbon monoxide levels in the breathing air do not exceed 10 ppm. For oil-lubricated compressors, a high temperature or carbon monoxide alarm, or both, will be used to monitor carbon monoxide levels. If only 25 of 58

high-temperature alarms are used, the air supply will be monitored at intervals sufficient to prevent carbon monoxide in the breathing air from exceeding 10 ppm. CLEANING; INSPECTION; AND MAINTENANCE Respirators issued for the exclusive use of one worker will be cleaned and disinfected after each day's use or more often, if necessary. A respirator used by more than one person will be cleaned and disinfected after each use by the employee who used it. Cleaning should be done using the manufacturer s recommendations or the guidelines in Appendix B-2 to 29 CFR 1910.134. Remove or protect the filters/cartridges before cleaning because moisture can defeat the effectiveness of a filter. During cleaning, an inspection of the respirator will be made to ensure it retains its original effectiveness. Valves, straps, canisters, elasticity, facepieces, if applicable, will be inspected per the manufacturer s instructions. Defective parts will be replaced before reuse. Employees who use respirators will be instructed in the replacement of parts as allowed by the manufacturer (such as valves and straps). Respirators that require a higher level of repair will be returned to the manufacturer. All replacement parts will be of the same manufacture as the respirator and all replacement parts will be NIOSH approved. Maintenance will be limited to replacing parts (straps, filters, valves, etc.) allowed by the manufacturer. Only respirators in 100% working order will be used. Cleaning supplies and replacement parts will be provided at no cost. In the event a respirator is not used for thirty (30) days, it will be inspected by a competent person. Particular attention will be paid to SCBA apparatus and Type "C" connections. SCBA apparatus shall be inspected monthly and air and oxygen cylinders will be fully charged according to the manufacturer s instructions. All warning devices will be checked to ensure they are properly functioning. MAINTENANCE OF EMERGENCY/UNASSIGNED RESPIRATORS Emergency and unassigned respirators (respirators used by more than one person) will be cleaned and inspected for defects every thirty (30) days and after each use. Particular attention will be given to the elasticity of the respirator and ensuring that the respirator is defect free. Only the latest record of this inspection will be maintained. A tag showing the name of inspector, the date, and condition of the respirators will be attached to the respirator. 26 of 58