PLAN REVIEW
Reviewer	Date
Brian Parrie	12/2/2013
Brian Parrie	4/28/2015

                                                                                                                            

                                                                                              Contact: Larry Mack

218-751-7883

 

ASBESTOS MANAGEMENT

Purpose

The purpose of this program is to establish guidelines and procedures in the operations and maintenance of Asbestos Containing Material (ACM) at St. Philip’s School to protect all employees, contractors, visitors, and vendors from potential health hazards of asbestos-related diseases.

This Program applies to all buildings and structures owned by St. Philip’s School, to all employees and sub-contractors of St. Philip’s School, to occupants St. Philip’s School buildings, and to external organizations that may come into contact with or disturb ACM in St. Philip’s School buildings. The Program applies to routine work during which an employee might encounter asbestos as well as work undertaken to repair or remove ACM.

Policy

It is the policy of St. Philip’s School that only qualified employees shall be involved in any asbestos repairs, maintenance, or removal. All unqualified employees shall be protected from exposure to asbestos fibers by isolating and controlling access to all affected areas during asbestos work. All tasks involving the disturbance of ACM will be conducted only after appropriate work controls have been identified and implemented. A qualified supervisor shall be available at asbestos-controlled work sites during all activities. Proper personal protective equipment, vacuums, and HEPA filters shall be used and properly maintained. If outside contractors are used, the St. Philip’s School shall ensure all contractor employees have been properly trained and have been issued proper equipment and protective gear.

 

Responsibilities

Management

• Ensure all ACM is identified and labeled

• Ensure training is effective for authorized employees

• Conduct medical surveillance of affected employees

• Establish engineering controls for all work with ACM

• Provide adequate and proper equipment and personal protective gear

• Ensure proper disposal of all ACM

• Ensure that annual notifications are published

Supervisors

• Qualified supervisors shall provide effective on-site management during work with ACM.

• Supervisors will notify Asbestos Contact Person immediately upon discovering damaged asbestos material.

Employees

• Qualified employees must follow the exact procedures for repair or removal of ACM, including proper use of containment equipment, clean up equipment, and personal protective gear.

• Unqualified employees are to stay clear of all asbestos work areas and report any damaged ACM to their supervisor.

Hazards

Asbestos is a common, naturally occurring group of fibrous minerals. Asbestos fibers have been used in a variety of building materials; however, the St. Philip’s School takes an aggressive effort to use non-asbestos containing materials in new construction and renovation projects. Generally, most asbestos is found in pipe insulation, doors, textured paints and plasters, structural fireproofing, and floor tiles. Friable asbestos (that is, material that contains more than 0.1% asbestos by weight and can be crumbled by hand) is a potential hazard because it can release fibers into the air if damaged.  Long-term exposure to airborne asbestos is necessary for chronic lung disease. Significant and long-term exposure to asbestos from activities that directly disturb ACM (such as asbestos mining) can lead to a variety of respiratory diseases, including asbestos is and mesothelioma (cancer of the lung lining). Asbestosis is a non-malignant, irreversible disease resulting in fibrosis of the lung. Asbestos-related cancers tend also to result from substantial long-term exposure; however, mesothelioma may result from much smaller exposures to asbestos.

Hazard Control

Engineering Controls

Engineering controls include the use of enclosures such as monitoring equipment, glove bags, tenting, negative pressure work areas, HEPA filters, controlled vacuums, water misters, and other equipment to ensure containment and clean up of asbestos work areas.

Administrative Controls

All qualified workers shall be issued proper personal protective equipment, such as respirators, disposable coveralls, gloves, etc. Written procedures and management authorizations are required for all work involving ACM.

Training Controls

All qualified employees, supervisors, and managers shall receive the proper level of training, as outlined in this program.

Definitions

Asbestos is a generic term describing a family of naturally occurring fibrous silicate minerals. As a group, the minerals are noncombustible, do not conduct heat or electricity, and are resistant to many chemicals. Although there are several other varieties that have been used commercially, the most common asbestos mineral types likely to be encountered in District buildings are chrysotile (white asbestos), amosite (brown asbestos), and crocidolite (blue asbestos). Among these, white asbestos is by far the most common asbestos mineral present in District buildings.

Friable Asbestos means finely divided asbestos or ACM or any ACM that can be crumbled, pulverized, or powdered by hand pressure. Individual fibers in friable ACM can potentially become airborne and can then present a health hazard. Three types of friable material commonly used in buildings are sprayed fibrous fireproofing, decorative or acoustic texture coatings, and thermal insulation.

Non-friable Asbestos includes a range of products in which asbestos fiber is effectively bound in a solid matrix from which asbestos fiber cannot normally escape. Non-friable asbestos includes a variety of products including asbestos cement tiles and boards and asbestos-reinforced vinyl floor tiles. Cutting, braking, sanding, drilling, or similar activities can release asbestos fiber from even non-friable asbestos materials.

Asbestos Work Categories

Category 1 work includes the installation or removal of non-friable asbestos in which the asbestos fiber is locked in a binder such as cement, vinyl, or asphalt that holds the material together.

Category 2 work involves work with friable asbestos that is of short duration in situations which create low levels of airborne asbestos. Examples of category 2 work are enclosure of friable asbestos; application of tape or sealant to asbestos-containing pipe insulation; minor removal of friable asbestos; and minor installation, maintenance, or repair work above false ceilings where sprayed asbestos fireproofing is present on beams.

Category 3 Work involves possible exposure to friable asbestos over long periods of time or work that generates high levels of asbestos. Included in category 3 work are removal projects where relatively large amounts of asbestos are removed from a building (including removal of friable asbestos from structural material), and cleaning or removal of heating or air handling equipment that has been insulated with asbestos. Also included in category 3 work are cutting or grinding of ACM using power tools.

Rules

General Rules

• When in doubt, treat all material as containing asbestos and comply with all applicable rules and regulations and protective measures.

• Certified and licensed asbestos abatement personnel will handle all ACM. The friability of the ACM will dictate the type of removal/maintenance required.

• Employees who are uncertified and unlicensed will not handle any ACM >1%. This will include encapsulation projects, renovation/removal, and/or demolition of any type of structure. This will prevent the potential for accidental exposure from the mishandling of any ACM.

• When an uncertified, unlicensed employee questions whether he/she may be handling suspect ACM, the employee will immediately contact his/her supervisor.  The employee shall not resume working at the site until the area has been checked to verify the material is not ACM.

• Uncertified, unlicensed employees will not cross over a barrier/containment area where asbestos projects are in progress.

• Any employee who discovers ACM or suspect ACM in damaged or poor condition should report it to his/her supervisor so the identified material is repaired.

Rules Regarding Medical Examinations

• Employees assigned to asbestos removal will be given medical examinations at the District’s expense in compliance with 29 CFR 1926.1101 and 40 CFR 763 – Subpart G:
  • Within 30 days of first employment or assignment to a job exposing the employee to asbestos containing material,
  • Annually, and
  • Within 30 days of termination of employment.

• Medical examination for employees assigned to asbestos removal will include:
  • Medical and work history with special emphasis directed to symptoms of the respiratory system, cardiovascular system, and digestive tract;
  • Medical questionnaire contained in 29 CFR 1926.1101; and
  • A physical examination including a chest roentgenogram and pulmonary function test that includes measurement of the employee’s forced vital capacity and expiratory volume.

• No employee shall be assigned to tasks requiring the use of respirators if an examining physician determines the employee will be unable to function normally while using it or that the employee might otherwise be impaired.

• Records of all physical examinations performed for work-related asbestos activities will be maintained permanently by the District.

Rules Regarding Asbestos Inventory

• The District has conducted surveys and prepared a written inventory of the type and locations of ACM to:
  • Allow for periodic condition inspections, and
  • Allow for maintenance and repair of damaged asbestos.

• For each building the inventory contains the following information:
  • Type of ACM (sprayed fireproofing, texture coating, or thermal insulation);
  • The location of the material; and
  • When is has been sampled, the type and percentage of asbestos present.

• Also included in the survey information are sampling results showing the absence of asbestos in material that might be mistaken for an ACM.

Asbestos Identification

An asbestos identification system is used to alert people to the presence of asbestos. Asbestos is identified by tags, stickers, pipe labels, signs, and other high visibility means. Where feasible, stickers indicate the presence of asbestos in thermal insulation, in asbestos board and tiles, and in other locations. Warnings may also be placed near the entrances of rooms, particularly mechanical rooms where unusually large amounts of asbestos may be present.

Inspection

Inspection of the condition of friable asbestos is integrated into the Maintenance Department routine inspection program. Periodic inspections and reports on the status of facilities and equipment in District buildings are produced to note damage to asbestos that might result in release of asbestos. When damaged ACM is discovered a work order will be issued to initiate the assessment/remediation as required.

Access Control

Access to mechanical and electrical rooms, service shafts, tunnels, and other locations is to be restricted where asbestos may be present in unusually large amounts and where other hazards may also be present. Such areas are locked and accessible only to authorized personnel. Where sprayed asbestos-containing fireproofing is present in a building above a false ceiling, access to the space is restricted to Maintenance Department employees, Communications Services, or authorized contractors.

Repair and Maintenance of ACM

Should an employee or a contractor encounter material that is not identified and is not listed in the Asbestos Inventory and which might reasonably be expected to be asbestos, the person will stop any work that could create airborne asbestos and report the discovery to a supervisor. Where it is determined that friable ACM is in a condition that could likely lead to inhalation exposure, the supervisor will immediately limit access to the location and initiate repairs, removal, or encapsulation. Where there is reasonable doubt about the composition of a friable material, it will be treated as asbestos until testing demonstrates that asbestos is present at levels below 1%.  Cleanup and repair of asbestos-containing material will only be carried out by the appropriate clean-up procedure by employees or contractors who have been properly trained.

When routine work is to take place in an area where asbestos is present or when the work might disturb friable asbestos, employees will be informed of the potential for exposure through a notation on the work order. If upon reviewing the work situation, the employee believes that normal work practices do not provide an adequate measure of safety, the employee will report these concerns to the supervisor. The supervisor will review the work situation and authorize any required additional precautions. All employees, visitors, vendors, and contractors will be notified in advance when work involving asbestos is to be carried out in any area of District buildings that they occupy.

Training

All District St. Philip’s School who remove, repair, or work around friable asbestos and those whose work might disturb friable ACM will be trained to carry out their work without endangering themselves, their coworkers, or other building occupants.

Level 1 Training

All affected Maintenance Department employees who do not receive levels 2 or 3 training will receive Level 1 training which will acquaint them with:

• The types, properties, and uses of asbestos;
• Ways to recognize asbestos;
• The hazards of asbestos fiber inhalation;
• Types of activities which could release asbestos fibers; and
• The District Asbestos Inventory and Asbestos Identification State and Federal regulations regarding work with asbestos and disposal of asbestos-containing waste.

Refresher training will be provided every second year. Only those with Level 1 training will be allowed to carry out or supervise Category 1 asbestos work.

Level 2 Training

All District employees who conduct or may be expected to conduct Category 2 or 3 work will receive training in:

• All Level 1 topics;
• Ways to recognize and avoid damage to ACM;
• The use, fitting, limitations, care, and disposal of protective equipment;
• Asbestos containment and ventilation during removal; and
• Wet and dry clean up procedures.

Refresher training will be provided every second year. Except for actual asbestos removal, only those with Level 2 training will be allowed to carry out or supervise Category 2 asbestos work.

Level 3 Training

Level 3 training will be provided for insulators and others who are authorized to remove friable asbestos and for those who supervise asbestos removal work that is performed by either District Employees or external contractors. Level 3 training provides practical hands-on experience in all phases of small and medium scale asbestos removal. Those who will carry out small-scale asbestos removal work will receive additional on-the-job training working with experienced asbestos workers.

Contracted Work

Asbestos Removal Work

Major asbestos removal is normally contracted to external firms who specialize in asbestos removal work. The District requires that all such work be carried out in accord with the requirements established by State and Federal regulations. At all such projects the contractor will ensure that cleanup is properly completed and that all asbestos and asbestos-contaminated material is collected and disposed of in accord with the EPA regulations. The contractor will be required to submit air-testing results to demonstrate that the cleanup has been carried out properly and the area can be reoccupied safely.

Other Work

The District often employs contractors to service equipment such as elevators, telephones, refrigeration, and air conditioning equipment, and to carry out other construction and renovation projects. When contractors are required to work in areas where asbestos is present or there is a possibility of disrupting friable asbestos, the District will provide:

• Notification of the known locations and types of asbestos present (or suspected to be present) in the area where the contractor will work, and

• Information on District asbestos labeling system. The District requires that contractors carrying out tasks which could potentially create asbestos-containing dust:

• Follow work practices that reduce to the extent practical the creation of airborne asbestos dust and which meet the asbestos safety standards set by State and Federal regulations.

• Immediately report to the asbestos program manager when damage occurs to ACM, and

• Employ only workers who have been trained in asbestos safety.

Asbestos Work Procedures

Discovering Damaged Asbestos

When asbestos is discovered the following steps describe the actions to be taken by trade Employees and their supervisors. The steps comply with District Asbestos Policy, which states the long-term goal is to remove all asbestos and the short-term goal is to manage asbestos to minimize exposure to airborne asbestos. It is important to note that all asbestos is to be logged in the inventory, regardless of its state of repair.

• Complete the Asbestos Inventory Form – The employee is to complete the first section of the Asbestos Inventory Form and submit it to his/her Supervisor.

• Sampling – The Supervisor will determine if samples are required to confirm the existence of asbestos. Checking the inventory to see if asbestos in that location has already been tested will do this. If necessary, the Supervisor will close off an area (mechanical spaces) or shut down equipment (air handling units) pending test results and remedial action.

• Repair/Removal and Cleanup – If the asbestos is damaged, it is certain a clean up will be required. The clean up and repair should happen together. The repair and clean up will be charged to a work order and the number recorded on the Inventory Form. If removal is required, the supervisor will determine whether the removal will be carried out by a contractor or by District Employees. The work order number must be logged on the Inventory Form.

• Labeling – All known ACM should be labeled. For asbestos containing pipe insulation, yellow paint will be applied directly to the insulation. In areas where asbestos is present in multiple locations it will be sufficient to provide warning signage at each entry point into a room. Blue paint will be applied to any new insulation that is not readily obvious to be asbestos free.

• Logging in Database – After completing the Asbestos Inventory Form, it will be given to the District asbestos program manager for logging into the Asbestos Inventory.

Clean up of ACM

Asbestos only poses a health hazard when it becomes airborne and people inhale the fiber. When asbestos-containing material has been disturbed, effective clean up will ensure that asbestos does not present a health hazard. Clean up of dust that might contain traces of asbestos, such as a custodian might encounter in routine cleaning in buildings where asbestos is present, will not require special precautions. To ensure that clean up of significant quantities of asbestos will not cause a health hazard, the following procedure will be followed:

• Clean up of significant amounts of ACM will be only be done by Employees who have been trained and who are wearing appropriate protective clothing and a fitted, air-purifying respirator.

• Dry sweeping of asbestos-containing waste and other clean up activities that will create airborne dust are not permitted.

• Large pieces of ACM will be collected by hand and properly bagged in accord with the disposal procedure.

• When ever possible, asbestos dust will be thoroughly wetted and clean up with a wet mop or a HEPA type vacuum. Contaminated water will be discharged to a sewer. Containers, mops and other equipment that might be contaminated with asbestos will be rinsed with water and the rinse water discharged to a sewer.

If additional clean up is need it will be carried out using a vacuum equipped with a HEPA filter. Within Maintenance Department there is one vacuum assigned for asbestos clean up.

Non-friable ACM Work

Asbestos that is effectively bonded in a non-asbestos matrix cannot easily become airborne. As such, provided the material is not broken or abraded, there is little risk of inhalation exposure to asbestos. To ensure that minor work involving non-friable asbestos (including vinyl asbestos tile, asbestos asphalt roofing, and asbestos ceiling and wall tile) the following procedure will be followed:

• Before beginning the work the worker will carefully inspect the ACM to ensure that the planned work will not create airborne asbestos dust.

• Where dust that might contain asbestos fiber is present, the worker will clean the material using a wet method or a HEPA filtered vacuum.

• Following completion of the task the worker will carry out any required clean wet methods or a HEPA filtered vacuum and will then carefully bag for disposal all asbestos-containing waste.

Note: Cutting, drilling, sanding or breaking the material are likely to create airborne asbestos dusts and will require additional precautions.

Work Above False Ceilings

Only workers who have successfully completed Level 2 Asbestos Safety Training and who are authorized to do so by the asbestos program manager may move ceiling tiles or perform work above the dropped ceilings where asbestos insulation is present on building structure. The following procedure shall be used whenever minor work (such as installation of telephone or computer lines, or servicing of ventilation or lighting system components) requires work above the suspended ceiling:

• Before removing a ceiling tile, the area around the tile shall be isolated by creating an enclosure of 4-mil or heavier polyethylene sheeting. The sheeting shall be taped to the ceiling t-bar and the floor using duct tape.

• Those working within the enclosure shall wear a pair of coveralls and a properly fitted, air-purifying respirator equipped with a particulate filter designed to remove asbestos fibers from inhaled air.

• Air supply or return grills located within the enclosure shall be sealed with 4-mil or thicker polyethylene sheeting to prevent contamination of the ventilation system.

• The ceiling tile shall be carefully removed and the upper surface vacuumed with a vacuum fitted with a HEPA filter.

• The worker shall then carefully vacuum the upper surface of surrounding tiles before carrying out the assigned task.

• Following completion of the above-the-ceiling work, the removed ceiling tile shall be replaced and the interior of the enclosure carefully cleaned using wet cleaning techniques or a HEPA filtered vacuum.

Note: Additional precautions may be required depending upon the specific tasks to be undertaken. Any task that is likely to disrupt the sprayed-on insulation will require additional precautions.

Repairs to ACM

Where asbestos is known or believed to be present in damaged insulation, repairs or removal are needed to prevent asbestos fiber from becoming airborne. Only workers who have successfully completed Level 3 Asbestos Safety training and who are authorized to do so may undertake such repairs or removal. The following procedure will be used whenever minor repairs to asbestos containing insulation is undertaken:

• Access to areas where minor repair is to be carried out will be restricted to authorized people only. When necessary, signs will be posted advising of access restrictions.

• Workers repairing asbestos-containing insulation will wear coveralls and a properly fitted, air-purifying respirator equipped with a particulate filter designed to remove asbestos fibers from inhaled air.

• Before beginning the repair, the area will be carefully cleaned using the Clean-up of Asbestos-Containing Material Procedure.

• When feasible a drop cloth shall then be placed beneath the insulation to be repaired.

• Before beginning the repair, all feasible steps (wetting with amended water, encapsulating adjacent asbestos-containing material, etc.) will be taken to prevent the release of asbestos fibers.

• Following the repair the worker will carefully bag for disposal all asbestos- containing waste and clean the surrounding area using wet cleaning techniques or a HEPA filtered vacuum.

Single-Use Glove Bag Procedure

The following procedure will be followed when single-use asbestos removal glove bags are used. The procedure may only be used on tasks that are small enough to be completely enclosed in the glove bag and which do not leave exposed asbestos in place when the bag is removed.

Preparation:

Only a Employee who has completed level 3 training and who is wearing appropriate coveralls and an air-purifying respirator (3M 6000 Series with a purple, 6240 particulate filter or equivalent) will carry out glove bag removal of asbestos.

Before beginning removal work, access to the area will be restricted. If the work site is located in areas where other Maintenance Department Employees might be exposed to asbestos, and in all work sites located in publicly accessible areas, warning notices will be posted.

Steps will be taken to prevent accidental movement, contact with heat, cold or electricity, or release of chemicals.

The work area will be cleaned using a HEPA filtered vacuum or wet cleaning to remove asbestos-containing material contaminating the immediate work area. Where possible a plastic sheet will then be placed beneath the pipe or fitting from which the asbestos is to be removed.

Steps will be taken to prevent exposure where damage to the insulation might allow release of fibers. Steps include making temporary repairs using duck tape or wetting the exposed fiber using amended water.

Glove Bag Removal:

The asbestos-containing material will be thoroughly wetted using amended water.

With tools in bag, the single-use bag will be positioned and secured using adhesive and tape as necessary.

Working through the gloves, the asbestos will be removed exercising care to avoid puncturing the bag.

When removal is compete or bag is full, sprayer (containing amended water) will be inserted into the bag and the pipe or fitting, tools and the bag interior will be washed.

Tools will then be placed in an inverted glove withdrawn from bag and the glove sealed from the bag using duct tape.

The tools will then be removed by cutting through the duct tape ensuring that both the bag and the glove remain sealed.

The tools will then be submerged in water and the glove opened. Tools will be cleaned under water.

The glove bag will then be carefully removed, sealed and placed in a sealed container pending packaging for disposal.

Clean Up:

The surface of the pipe or fitting will be carefully wet wiped and treated with sealer.

The plastic sheet will then be carefully wet wiped and rolled up.

All solid waste created during removal jobs including glove bags, disposable coveralls, wipe rags and plastic sheeting will be treated as asbestos containing waste and handled as detailed in the disposal procedure.

Multiple-Use Glove Bag Procedure

This procedure describes the use of multiple use glove bags. It may be used on tasks that require the bag to be repositioned to complete the entire job.

Preparation:

Only a Employee who has completed level 3 training and who is wearing appropriate coverall and an air purifying respirator (3M 6000 Series with a purple, 6240 particulate filter or equivalent) will carry out glove bag removal of asbestos.

Before beginning removal work, access to the area will be restricted. If the work site is located in areas where other Maintenance Department Employees might be exposed to asbestos and in all work sites located in publicly accessible areas, warning notices will be posted.

Steps will be taken to prevent accidental movement, contact with heat, cold or electricity, or release of chemicals.

The work area will be cleaned using a HEPA filtered vacuum or wet cleaning to remove asbestos-containing material contaminating the immediate work area. Where possible a plastic sheet will then be placed beneath the pipe or fitting from which the asbestos is to be removed.

Steps will be taken to prevent exposure where damage to the insulation might allow release of fibers. Steps include making temporary repairs using duck tape or wetting the exposed fiber using amended water.

Glove Bag Removal:

The asbestos containing material will be thoroughly wetted using amended water.

With tools in bag, the bag will be positioned and secured using adhesive and tape as necessary.

Working through the gloves, the asbestos will be removed exercising care to avoid puncturing the bag.

When removal is compete or bag is full, sprayer (containing amended water) will be connected to the valve and the pipe or fitting, tools and the bag interior will be washed. If the bag is repositioned to remove additional asbestos, remaining exposed ends of asbestos will be thoroughly damped.

Tools will then be placed in an inverted glove withdrawn from bag and the glove sealed from the bag using duct tape.

The tools will then be removed by cutting through the duct tape ensuring that both the bag and the glove remain sealed.

The tools will then be submerged in water and the glove opened. Tools will be cleaned under water.

The glove bag will then be removed and placed in a sealed container pending packaging for disposal.

Clean Up:

The surface of the pipe or fitting will be carefully wet wiped and treated with sealer.

The plastic sheet will then be carefully wet wiped and rolled up.

All solid waste created during removal jobs including glove bags, disposable coveralls, wipe rags and plastic sheeting will be treated as asbestos containing waste and handled as detailed in the disposal procedure.

Modified Enclosure Procedure

The following Modified Enclosure Method may be used for removal of asbestos from ceilings, walls, beams, pipes, or other equipment providing that the job is small enough that it can be completed within one shift without the need for repeated entry into the work area.

The method may not be used for jobs involving:

Amosite, Crocidolite, or Friable asbestos of any type.

Additional precautions will be required if the exhaust air cannot be discharged outdoors. Modified enclosure removals may only be undertaken by Employees who have completed level three training and who have received modified enclosure removal training.

Preparation:

If dust that might contain asbestos is present, pre clean the work site using wet cleaning or HEPA vacuum cleaning.

Protect floor, walls equipment within the work area that might be damaged by water.

Ensure that steps are taken to protect workers from any energized equipment or systems located within the work area.

Post signs and restrict access to work area.

Seal area to prevent air leakage into adjacent areas or air handling system using framing as necessary, 150 mil plastic sheeting, tape, sealants and caulking as required. Construct an overlapping, double curtained entrance to work area.

Install HEPA filtered negative air unit in work area. Unit must provide 4 air changes per hour while maintaining a pressure difference of -0.02 inches of water. Direct filtered exhaust air outdoors.

Removal:

Employees entering the work are shall wear a disposable Tyvek type suit including a head cover and an air purifying respirator (3M 6000 Series with a purple, 6240 particulate filter or equivalent).

With the area sealed and negative air unit in operation, saturate asbestos- containing material with amended water using airless sprayer.

Remove asbestos using additional amended water as needed being careful not to create airborne dust.

Brush the area from which asbestos has been removed and then wet wipe or vacuum to remove final traces of asbestos. Following removal of asbestos, treat the area with slow dry sealer.

Clean up:

Place all waste in specially marked heavy-duty asbestos waste disposal bags. Seal waste bags securely using duct tape before removing from the enclosure. Wipe all tools with a damp cloth to remove traces of asbestos contamination before removing them from the enclosure.

Wet wipe or vacuum (using the designated shop vac marked ASBESTOS ONLY) all areas within the enclosure not covered by plastic to remove traces of asbestos.  If a HEPA filtered shop vac was used, it shall be wiped with a damp cloth and the hose end covered with tape before being removed from the enclosure. If the vac is to be opened to change a filter or bag, the work will be carried out in an enclosure under negative pressure with HEPA filtered air exhausted outdoors.

Wet wipe the interior of plastic sheeting used to form the enclosure. Remove plastic by rolling, wet wiping any visible particulate matter that make be visible. Wet wipe the disposable Tyvek suit and remove. Place the plastic sheeting, the suit and the used respirator cartridges in an asbestos waste bag along with other remaining contaminated material.

Arrange for reconnection of any services running through the work area that were disconnected to accommodate removal work.

Dispose of waste as per waste disposal procedure.
Disposal of Asbestos-Containing Waste Materials

Handling and disposal of asbestos-containing waste is regulated by both State and Federal regulations. To ensure compliance with these regulations and to ensure that no one is exposed to asbestos the following procedure is to be followed:

Only an Employee who has completed Level 2 training and who is wearing appropriate air purifying respirator will package asbestos waste.

Waste asbestos will be thoroughly wetted and then placed in specially labeled 6 mil plastic bags. The bag will be securely sealed using duct tape. The bagged asbestos will then be placed in a second, labeled 6-mil plastic bag that is again taped closed.

Asbestos waste may be transported from the location where it was produced to an interim storage location if the bags are free from punctures or tears and if the outside of the bag is free of asbestos. Asbestos waste will be transported in an enclosed vehicle or beneath a secured tarpaulin. No other cargo may be carried while the waste asbestos is being moved. After the waste asbestos is moved to an interim storage site, the driver will, if necessary clean the vehicle to remove asbestos contamination.

Asbestos waste must be disposed of at a waste disposal site that is approved to receive asbestos by Environmental Protection Agency(EPA) or the state pollution control agency.

Shipment of waste asbestos must be coordinated with the waste disposal site that is to receive the waste. External contractors will normally carry out asbestos disposal.

Shipments for disposal must be done in accord with Minnesota and Federal DOT regulations and must be accompanied by a properly completed shipping document.

 

 

St. Edwards Elementary School Asbestos-Management-Plan

Holy Redeemer School Asbestos-Management-Plan 

St. Mary’s Mission Emergency Action Plan

 

PLAN REVIEW
Reviewer	Date
Brian Parrie	1/22/2014

 

Contact: Diana Mistic

218-679-3388

 

                   EMERGENCY ACTION PLANNING

Purpose

The purpose of this program is to provide the needed tools to respond to emergencies that may occur in the school setting. St. Mary’s Mission Schools has developed a specific response plan for use to prevent and/or respond to emergencies that could occur. The plan is based on the requirements established by Minnesota Executive Order 93-27 and Model Crisis Management Plan. The plan was developed in coordination and cooperation of community leaders, local units of government, and State of Minnesota agencies.

A copy of the plan may be obtained from the school principal’s and/or district office.

 

St. Mary’s’ Mission Community RTK Plan

PLAN REVIEW
Reviewer	Date
Brian Parrie	1/22/2014

 

Contact: Al Branchaud

                                                                                                        218-679-3388

     COMMUNITY RIGHT-TO-KNOW

Introduction

The Emergency Planning and Community Right to Know Act of 1986 established requirements for Federal, State, and local governments and industry regarding emergency planning and “Community Right-to-Know” reporting on hazardous and toxic chemicals. This was part of the Superfund Amendments and Reauthorization Act (SARA), the main purpose of which was to extend the Superfund for cleanup of hazardous waste sites throughout the United States. The law contained in its scope provisions on planning for hazardous chemical emergencies and to allow citizens the right to know about hazardous chemicals in their communities. These Community Right-to-Know provisions will help to increase the public’s knowledge and access to information on the presence of hazardous chemicals in their communities and releases of these chemicals into the environment.

The requirements of the law apply to any facility which stores hazardous substances in quantities equal to or greater than the regulated threshold planning quantity (TPQ) or other general limit which is applicable (500 pounds for extremely hazardous chemicals; 10,000 pounds for all other hazardous chemicals).

Applicability

Facilities Storing Extremely Hazardous Substances

If, at any time, St. Mary’s Mission School stores any of the 360+ extremely hazardous substances listed in SARA Title III above the threshold planning quantities (at any one time), the State Emergency Response Commission will be notified.

Emergency Notification

St. Mary’s Mission School will immediately notify the Local Emergency Planning Committees (LEPCs) and the State Emergency Response Commission (SERC) likely to be affected if there is a release into the environment of a hazardous substance that exceeds the reportable quantity for that substance. Substances subject6 to this requirement are those on the list of 356 extremely hazardous substances as published in Federal Register (40 CFR 355) as well as the more than 700 hazardous substances subject to the emergency notification requirements under CERCLA Section 103 (a) (40CFR 302.4). Some chemicals are common to both lists. The CERCLA hazardous substances also require notification of releases to the National Response Center (NRC), which affect alerts federal responses.

Initial notification will be made by telephone. Emergency notification requirements involving transportation incidents will be met by dialing 911, or in the absence of a 911 emergency number, calling the operator.

This emergency notification will include:

• The chemical name;
• An indication of whether the substance is extremely hazardous;
• An estimate of the quantity released into the environment;
• The time and duration of the release;
• Whether the release occurred into the air, water, and/or land; any known or anticipated acute or chronic health risks associated with the emergency, and where necessary, advice regarding medical attention for the exposed individuals;
• Proper precautions, such as evacuations or sheltering in place; and,
• Name and telephone number of contact person («Com_RTK»).

Chemical Inventory Form

For all chemicals reported under Section 311, St. Mary’s Mission School will report the past year’s quantities to the Emergency Response Commission (MN Tier Two Report).

Regulatory Requirements

Community Right-To-Know Requirements

There are two Community Right-To-Know reporting requirements within the Emergency Planning and Community Right-To-Know Act. Section 311 requires facilities that must prepare material safety data sheets () under Occupational Safety and Health Administration (OSHA) regulations to submit either copies of their SDSs or a list of SDSs chemicals to:

• The LEPC,
• The SERC, and,
• The local fire department with jurisdiction over District facilities.

The initial step a facility coordinator should take in preparing for an emergency should be to inventory and quantify hazardous substances within the facility. The coordinator should begin by focusing on the list of extremely hazardous substances published in the Federal Register. This list is provided under the EHS title in the CHMP section of this program.

If an inventory of the facility’s chemicals indicates that a threshold planning quantity is reached, the District is then required to:

1. Notify the Emergency Response Commission in writing within 60 days after acquiring any of the extremely hazardous substances above the threshold planning quantities, and
2. Assign a Facility Emergency Coordinator.

Emergency Notification

Whenever a hazardous substance is released outside the control of the facility (air, sewer, land, or surface water), there are requirements to:

1. Contact local emergency 911;
2. Contact State Duty Officer (Metro 612-649-5451, outside Metro 1-800-422-0798);
3. Contact National Response Center at 1-800-424-8802; and
4. Submit an Emergency Release Follow-up Report to the Emergency Response Commission.

All spills and releases occurring in Minnesota that are outside the control of the facility should be reported to the State Duty Officer—regardless of whether or not the reportable quantity was reached. Minnesota has a “One Call” system that allows the State Duty Officer to make notification to all applicable state, county, and local agencies. If a spill or release occurs which has met or exceeded the reportable quantity, the caller is still responsible for notifying the 911 emergency system and the National Response Center.

The facility should contact local authorities to inform them of the need for emergency response. When contacting the state emergency response number, the facility should specify that the release is subject to Title III notification. The emergency notification must include:

1. The chemical name or identification of any substance involved in the release;
2. An indication as to whether the substance is on the list of extremely hazardous substances;
3. An estimate of the quantity of any such substance that was released into the environment;
4. The time and duration of the release;
5. Whether the release occurred into air, water, and/or land;
6. Any known or anticipated health risks (acute or chronic) and any advice regarding medical attention for exposed individuals;
7. The proper precautions to be taken in the event of a release, including evacuation; and
8. The name and telephone number of the person or persons to be contacted for further information.

As soon as practical after a release, an Emergency Release Follow-Up Report must be sent to the Emergency Response Commission, and must:

1. Update information included in the initial notice and
2. Provide information on:
   1. Actual response actions taken and
   2. Advice regarding medical attention necessary for exposed individuals.

Chemical List

Any facility required to prepare or have available SDSs under the Minnesota Employee Right to Know or the Hazard Communication Standard must report the following:

1. Any extremely hazardous chemical that is stored in a quantity of 500 pounds or more or greater than the threshold planning quantity (TPQ). If so listed, look up on the list of extremely hazardous substances.
2. Any hazardous chemical for which there is an SDS and which is being stored in a quantity of 10,000 pounds or greater.

Under the reporting requirements, the law states that a list of SDSs or a copy of the SDS sheets themselves must be submitted for any of the extremely hazardous substances above the TPQ, or other hazardous chemicals in excess of 10,000 pounds. Minnesota provides a Hazardous Chemical Report Form that may be submitted in lieu of the SDSs (in fact, a fee is charged if the Minnesota form is not used). This form is submitted one time and is only required to be updated if a new chemical is brought into the facility.

• The chemicals which would potentially be found in quantities greater than 10,000 pounds for “ordinary” hazardous chemicals in a school district would be fuel oil, propane, butane, or diesel fuel.
• The most commonly found extremely hazardous chemical in most schools is chlorine, which has a TPQ of 100 pounds. If liquefied chlorine in tanks is used for swimming pool chlorination, this limit would apply. Dry chlorine compounds, which may have 10% available chlorine, would also apply if stored in quantities greater than 1,000 pounds. This requirement is based on the actual weight of the specific hazardous chemical and not the total weight of a formulated product (e.g., 10% chlorine of 1,000 pounds total product equals 100 pounds of chlorine).
• This chemical report form must be submitted to both the State Emergency Response Commission and the local fire department with jurisdiction over your facility.
• Reporting requirements under Section 311 do not apply to:

—    Wood or wood products;

—    Tobacco or tobacco products;

—    Any food, additive, color, drug, or cosmetic regulated by the Food and Drug Administration; or

—    Any hazardous waste which is regulated by other regulations such as the Solid Waste Disposal Act;

—    Any fertilizer held by a retailer for resale;

—    Any solid substance in a manufacturer item which does not cause exposure under normal conditions of use;

—    Any substance to the extent that it is used for personal, family, or household purposes, or is present in the same form and concentration as a product packaged for distribution and use by the general public; and

—    Any substance to the extent it is used in a research laboratory, hospital, or other medical facility under the direct supervision of a technically qualified individual.

Chemical Inventory Form

• All facilities that have completed an initial Chemical Report Form are also required to submit an annual inventory by March 1, which covers the previous calendar year.

—    This report covers any chemical stored at any time during that year which exceeded the threshold planning quantity or the general limit (over 500 pounds of extremely hazardous chemical or 10,000 pounds of other hazardous chemical).

—    Effective with the 1963 reporting year, the Emergency Response Commission will be electronically scanning data received under this Section.

—    Facilities that are current reporters will receive a Section 312 Tier Two Turnaround Report from the Commission.

• Facilities reporting for the first time should request a new reporter package from the Commission. Tier Two forms will not be able to be supplied with this program because only originals from the Commission may be used.
• The purpose of the Tier Two form is to provide state and local officials and the public with specific information on hazardous chemicals present in your facility during the past year. The Tier Two form must be submitted by March 1 of every year for the previous year and must include:

—    Chemical name or common name as used on the SDS,

—    An estimate of the maximum amount of the chemical present at any one time,

—    A brief description of the manner of storage of the chemical,

—    The location of the chemical, and

—    An indication of whether the administrator elects to withhold location information from disclosure to the public.

 

St. Mary’s Mission Confined Space Entry Program Plan

PLAN REVIEW
Reviewer	Reviewer
Brian Parrie	5-23-2011
Brian Parrie	12/3/2013

 

Contact: Al Branchaud

218-679-3388

CONFINED SPACE ENTRY

Purpose

The St. Mary’s Mission School Confined Space Entry Program is provided to protect authorized employees that will enter confined spaces and may be exposed to hazardous atmospheres, engulfment in materials, conditions which may trap or asphyxiate due to converging or sloping walls, or contains any other safety or health hazards.

Responsibilities

Management

• Ensure proper training for entry and rescue teams
• Provide proper equipment for entry and rescue teams
• Ensure confined space assessments have been conducted
• Ensure all permit required confined spaces are posted
• Annually review this program and all Entry Permits
• Evaluate Rescue Teams/Service to ensure they are adequately trained and prepared
• Ensure rescue team at access during entry into spaces with IDLH atmospheres

Employees

• Follow St. Mary’s Mission School program requirements
• Report any previously unidentified hazards associated with confined spaces

Entry Supervisor

Entry supervisors are responsible for the overall permit space entry and must coordinate all entry procedures, tests, permits, equipment, and other relevant activities. The following entry supervisor duties are required:

• Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure
• Verify, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin
• Terminate the entry and cancel the permit when the entry is complete and there is a need for terminating the permit
• Verify that rescue services are available and that the means for summoning them are operable
• Remove unauthorized persons who enter or attempt to enter the space during entry operations
• Whenever responsibility for a permit space entry operation is transferred, and at intervals dictated by the hazards and operations performed within the space, determine that entry operations remain consistent with the permit terms and that acceptable entry conditions are maintained

The entry supervisor for St. Mary’s Mission School will be the Confined Space Entry Program Manager, «Confined_Space», unless otherwise designated.

Entry Attendants

At least one attendant is required outside the permit space into which entry is authorized for the duration of the entry operation. Responsibilities include:

• To know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure
• To be aware of possible behavioral effects of hazard exposure on entrants
• To continuously maintain an accurate count of entrants in the permit space and ensures a means to accurately identify authorized entrants
• To remain outside the permit space during entry operations until relieved by another attendant (once properly relieved, s/he may participate in other permit space activities, including rescue if they are properly trained and equipped)
• To communicate with entrants as necessary to monitor their status as well as alert entrants of the need to evacuate
• To monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space
• To order the entrants to immediately evacuate if the attendant:
  • Detects a prohibited condition,
  • Detects entrant behavioral effects of hazard exposure
  • Detects a situation outside the space that could endanger the entrants, or
  • Cannot effectively and safely perform all the attendant duties.
• To summon rescue and other emergency services as soon as the attendant determines the entrants need assistance to escape the permit space hazards
• To perform non-entry rescues as specified by that rescue procedure and entry supervisor
• Not to perform duties that might interfere with the attendant’s primary duty to monitor and protect the entrants
• To take the following action when unauthorized persons approach or enter a permit space while entry is under way:
  • Warn the unauthorized persons that they must stay away from the permit space,
  • Advise unauthorized persons that they must exit immediately if they have entered the space, and
  • Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space.

Entrants

All entrants must be authorized by the entry supervisor to enter permit spaces, have received the required training, use the proper equipment, and observe the entry procedures and permit. The following entrant duties are required:

• Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure
• Properly use the equipment required for safe entry
• Communicate with the attendant as necessary to enable the attendant to monitor the status of the entrants and to enable the attendant to alert the entrants of the need to evacuate the space if necessary
• Alert the attendant whenever the entrant recognizes any warning signs or symptoms of exposure to a dangerous situation, or any prohibited condition is detected
• Exit the permit space as quickly as possible whenever the attendant or entry supervisor gives an order to evacuate the permit space, the entrant recognized any warning signs or symptoms of exposure to a dangerous situation, the entrant detects a prohibited condition, or an evacuation alarm activated.

Hazards

• Explosive / Flammable Atmospheres
• Toxic Atmospheres
• Engulfment
• Asphyxiation
• Entrapment
• Slips and falls
• Chemical Exposure
• Electric Shock
• Thermal/Chemical Burns
• Noise and Vibration

Hazard Control

Engineering Controls

• Locked entry points
• Temporary ventilation
• Temporary lighting

Administrative Controls

• Signs
• Employee training
• Entry procedures
• Atmospheric monitoring
• Rescue procedures
• Use of prescribed PPE

Definitions

Confined space

A confined space:

• Is large enough or so configured that an employee can bodily enter and perform work
• Has limited or restricted means for entry or exit (e.g., tanks, vessels, silos, storage bins, hoppers, vaults, and pits)
• Is not designed for continuous employee occupancy

Permit-required confined space (permit space)

A permit-required confined space is a confined space that has one or more of the following characteristics:

• Contains or has a potential to contain a hazardous atmosphere
• Contains a material that has the potential for engulfing an entrant
• Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly covering walls or by a floor that slopes downward and tapers to a smaller cross-section
• Contains any other recognized serious safety or health hazard

Each permit-required confined space will be marked “Confined Space—Entry Permit Required”.

Entry Standard Operating Procedures

A Standard Operating Procedure (SOP) has been developed for each space to standardize the entry procedure. The SOP outlines:

• Hazards
• Hazard Control and Abatement
• Acceptable Entry Conditions
• Means of Entry
• Entry Equipment Required
• Emergency Procedures

Permit-Required Confined Space Entry General Rules

During all permit-required confined space entries, the following safety rules must be strictly enforced:

1. Only authorized and trained employees may enter a confined space or act as Entry Attendants.
2. No smoking is permitted in a confined space or near entrance/exit area.
3. During confined space entries, an Entry Attendant must be present at all times.
4. Constant visual or voice communication will be maintained between the Entry Attendant and Entrants.
5. No bottom or side entry will be made or work conducted below the level any hanging material or material which could cause engulfment.
6. Air and oxygen monitoring is required before entering any permit-required confined space.

—    Oxygen levels in a confined space must be between 19.5% and 23.5%.

—    Levels above or below will require the use of an SCBA or other approved air supplied respirator.

—    Additional ventilation and oxygen level monitoring is required when welding is performed.

—    The monitoring will check oxygen levels, explosive gas levels, and carbon monoxide levels.

—    Entry will not be permitted if explosive gas is detected above one-half the Lower Explosive Limit (LEL).

7. To prevent injuries to others, all openings to confined spaces will be protected by a barricade when covers are removed.

Confined Space Entry Procedures

Each employee who enters or is involved in the entry must:

1. Understand the procedures for confined space entry;
2. Know the hazards of the specific space;
3. Review the specific procedures for each entry; and
4. Understand how to use entry and rescue equipment.

Confined Space Entry Permits

Confined Space Entry Permits must be completed before any employee enters a permit-required confined space. The permit must be completed and signed by an authorized member of management before entry.

• Permits will expire before the completion of the shift or if any pre-entry conditions change.
• Permits will be maintained on file for 12 months.

Contractor Entry

All work by non-school employees that involves the entry into confined spaces will follow the procedures of this program. The information of this program and specific hazards of the confined spaces to be entered will be provided to Contractor Management prior to commencing entry or work.

Training

Training for confined space entry includes:

1. Duties of Entry Supervisor, Entrant, and Attendants
2. Confined Space Entry Permits
3. Hazards of Confined Spaces
4. Use of Air Monitoring Equipment
5. First Aid and CPR Training
6. Emergency Action and Rescue Procedures
7. Confined Space Entry and Rescue Equipment
8. Rescue training, including entry and removal from representative spaces

Confined Space Hazards

Flammable Atmospheres

A flammable atmosphere generally arises from enriched oxygen atmospheres, vaporization of flammable liquids, byproducts of work, chemical reactions, concentrations of combustible dusts, and desorption of chemical from inner surfaces of the confined space.

An atmosphere becomes flammable when the ratio of oxygen to combustible material in the air is neither too rich nor too lean for combustion to occur. Combustible gases or vapors will accumulate when there is inadequate ventilation in areas such as a confined space. Flammable gases such as acetylene, butane, propane, hydrogen, methane, natural or manufactured gases, or vapors from liquid hydrocarbons can be trapped in confined spaces, and since many gases are heavier than air, they will seek lower levels as in pits, sewers, and various types of storage tanks and vessels. In a closed top tank, it should also be noted that lighter than air gases may rise and develop a flammable concentration if trapped above the opening.

The byproducts of work procedures can generate flammable or explosive conditions within a confined space. Specific kinds of work such as spray painting can result in the release of explosive gases or vapors. Welding in a confined space is a major cause of explosions in areas that contain combustible gas.

Chemical reactions forming flammable atmospheres occur when surfaces are initially exposed to the atmosphere, or when chemicals combine to form flammable gases. This condition arises when dilute sulfuric acid reacts with iron to form hydrogen or when calcium carbide makes contact with water to form acetylene. Other examples of spontaneous chemical reactions that may produce explosions from small amounts of unstable compounds are acetylene-metal compounds, peroxides, and nitrates. In a dry state, these compounds have the potential to explode upon percussion or exposure to increased temperature. Another class of chemical reactions that form flammable atmospheres arises from deposits of pyrophoric substances (e.g., carbon, ferrous oxide, ferrous sulfate, iron, etc.) that can be found in tanks used by the chemical and petroleum industry. These tanks containing flammable deposits will spontaneously ignite upon exposure to air.

Combustible dust concentrations are usually found during the process of loading, unloading, and conveying grain products, nitrated fertilizers, finely ground chemical products, and any other combustible material. High charges of static electricity, which rapidly accumulate during periods of relatively low humidity (below 50%), can cause certain substances to accumulate electrostatic charges of sufficient energy to produce sparks and ignite a flammable atmosphere. These sparks may also cause explosions when the right air- or oxygen-to-dust or gas mixture is present.

Toxic Atmospheres

The substances to be regarded as toxic in a confined space can cover the entire spectrum of gases, vapors, and finely divided airborne dust in industry. The sources of toxic atmospheres encountered may arise from the following:

• The manufacturing process (e.g., in producing polyvinyl chloride, hydrogen chloride is used as well as vinyl chloride monomer, which is carcinogenic)
• The product stored [removing decomposed organic material from a tank can liberate toxic substances, such as hydrogen sulfide (H₂S)]
• The operation performed in the confined space (for example, welding or brazing with metals capable of producing toxic fumes)

During loading, unloading, formulation, and production, mechanical and/or human error may also produce toxic gases that are not part of the planned operation. Carbon monoxide (CO) is a hazardous gas that may build up in a confined space. This odorless, colorless gas that has approximately the same density as air is formed from incomplete combustion of organic materials such as wood, coal, gas, oil, and gasoline; it can also be formed from microbial decomposition of organic matter in sewers, silos, and fermentation tanks. Carbon monoxide is an insidious toxic gas because of its poor warning properties. Early stages of CO intoxication are nausea and headache. Carbon monoxide may be fatal at 1000 ppm in air, and is considered dangerous at 200 ppm, because it forms carboxyhemoglobin in the blood that prevents the distribution of oxygen in the body.

Carbon monoxide is a relatively abundant colorless, odorless gas; therefore, any untested atmosphere must be suspect. It must also be noted that a safe reading on a combustible gas indicator does not ensure that CO is not present. Carbon monoxide must be tested for specifically.

The formation of CO may result from chemical reactions or work activities; therefore fatalities due to CO poisoning are not confined to any particular industry. There have been fatal accidents in sewage treatment plants due to decomposition products and lack of ventilation in confined spaces. Another area where CO results as a product of decomposition is in the formation of silo gas in grain storage elevators. In another area, the paint industry, varnish is manufactured by introducing the various ingredients into a kettle, and heating them in an inert atmosphere, usually town gas, which is a mixture of carbon dioxide and nitrogen. In welding operations, oxides of nitrogen and ozone are gases of major toxicologic importance, and incomplete oxidation may occur and carbon monoxide can form as a byproduct.

Another poor work practice, which has led to fatalities, is the recirculation of diesel exhaust emissions. Increased CO levels can be prevented by strict control of the ventilation and the use of catalytic converters.

Irritant (Corrosive) Atmospheres

Irritant or corrosive atmospheres can be divided into primary and secondary groups. The primary irritants exert no systemic toxic effects (effects on the entire body). Examples of primary irritants are chlorine, ozone, hydrochloric acid, hydrofluoric acid, sulfuric acid, nitrogen dioxide, ammonia, and sulfur dioxide. A secondary irritant is one that may produce systemic toxic effects in addition to surface irritation. Examples of secondary irritants include benzene, carbon tetrachloride, ethyl chloride, trichloroethane, trichloroethylene, and chloropropene.

Irritant gases vary widely among all areas of industrial activity. They can be found in plastics plants, chemical plants, the petroleum industry, tanneries, refrigeration industries, paint manufacturing, and mining operations.

Prolonged exposure at irritant or corrosive concentrations in a confined space may produce little or no evidence of irritation. This may result in a general weakening of the defense reflexes from changes in sensitivity. The danger in this situation is that the worker is usually not aware of any increase in his/her exposure to toxic substances.

Asphyxiating Atmospheres

The normal atmosphere is composed approximately of 20.9% oxygen and 78.1% nitrogen, and 1% argon with small amounts of various other gases. Reduction of oxygen in a confined space may be the result of either consumption or displacement.

The consumption of oxygen takes place during combustion of flammable substances, as in welding, heating, cutting, and brazing. A more subtle consumption of oxygen occurs during bacterial action, as in the fermentation process. Oxygen may also be consumed during chemical reactions as in the formation of rust on the exposed surface of the confined space (iron oxide). The number of people working in a confined space and the amount of their physical activity will also influence the oxygen consumption rate.

A second factor in oxygen deficiency is displacement by another gas. Examples of gases that are used to displace air, and therefore reduce the oxygen level, are helium, argon, and nitrogen. Carbon dioxide may also be used to displace air and can occur naturally in sewers, storage bins, wells, tunnels, wine vats, and grain elevators. Aside from the natural development of these gases, or their use in the chemical process, certain gases are also used as inerting agents to displace flammable substances and retard pyrophoric reactions. Gases such as nitrogen, argon, helium, and carbon dioxide are frequently referred to as non-toxic inert gases but have claimed many lives. The use of nitrogen to inert a confined space has claimed more lives than carbon dioxide. The total displacement of oxygen by nitrogen will cause immediate collapse and death. Carbon dioxide and argon, with specific gravities greater than air, may lie in a tank or manhole for hours or days after opening. Since these gases are colorless and odorless, they pose an immediate hazard to health unless appropriate oxygen measurements and ventilation are adequately carried out.

Oxygen deprivation is one form of asphyxiation. While it is desirable to maintain the atmospheric oxygen level at 21% by volume, the body can tolerate deviation from this ideal. When the oxygen level falls to 17%, the first sign of hypoxia is deterioration to night vision that is not noticeable until a normal oxygen concentration is restored. Physiologic effects are increased breathing volume and accelerated heartbeat. Between 14% and 16%, physiologic effects are increased breathing volume, accelerated heartbeat, very poor muscular coordination, rapid fatigue, and intermittent respiration. Between 6% and 10%, the effects are nausea, vomiting, inability to perform, and unconsciousness. When the body’s oxygen level is less than 6%, the results are spasmatic breathing, convulsive movements, and death in minutes.

Mechanical Hazards

If activation of electrical or mechanical equipment would cause injury, each piece of equipment should be manually isolated to prevent inadvertent activation before workers enter or while they work in a confined space. The interplay of hazards associated with a confined space, such as the potential of flammable vapors or gases being present and the build-up of static charge due to mechanical cleaning (such as abrasive blasting) all influence the precautions that must be taken.

To prevent vapor leaks, flashbacks, and other hazards, workers should completely isolate the space. To completely isolate a confined space, the closing of valves is not sufficient. All pipes must be physically disconnected or isolation blanks bolted in place. Other special precautions must be taken in cases where flammable liquids or vapors may re-contaminate the confined space. The pipes blanked or disconnected should be inspected and tested for leakage to check the effectiveness of the procedure. Other areas of concern are steam valves, pressure lines, and chemical transfer pipes. A less apparent hazard is the space referred to as a void, such as double-walled vessels, which must be given special consideration in blanking off and inerting.

Thermal Effects

Four factors influence the interchange of heat between people and their environment. They are:

1. air temperature
2. air velocity
3. moisture contained in the air
4. radiant heat.

Because of the nature and design of most confined spaces, moisture content and radiant heat are difficult to control. As the body temperature rises progressively, workers will continue to function until the body temperature reaches approximately 102^o F. When this body temperature is exceeded, the workers are less efficient and are prone to heat exhaustion, heat cramps, or heat stroke.

In a cold environment, certain physiologic mechanisms come into play, which tend to limit heat loss and increase heat production. The most severe strain in cold conditions is chilling of the extremities so that activity is restricted. Special precautions must be taken in cold environments to prevent frostbite, trench foot, and general hypothermia.

Protective insulated clothing for both hot and cold environments will add additional bulk to the worker and must be considered in allowing for movement in the confined space and exit time. Therefore, air temperature of the environment becomes an important consideration when evaluating working conditions in confined spaces.

Noise

Noise problems are usually intensified in confined spaces because the interior tends to cause sound to reverberate and thus expose the worker to higher sound levels than those found in an open environment. This intensified noise increases the risk of hearing damage to workers, which could result in temporary or permanent loss of hearing. Noise in a confined space that may not be intense enough to cause hearing damage may still disrupt verbal communication with the emergency standby person on the exterior of the confined space. If the workers inside are not able to hear commands or danger signals due to excessive noise, the probability of severe accidents can increase.

Vibration

Whole body vibration may affect multiple body parts and organs depending upon the vibration characteristics. Segmental vibration, unlike whole body vibration, appears to be more localized in creating injury to the fingers and hands of workers using tools, such as pneumatic hammers, rotary grinders, or other hand tools that cause vibration.

Other Hazards

Some physical hazards cannot be eliminated because of the nature of the confined space or the work to be performed. These hazards include such items as scaffolding, surface residues, and structural hazards. The use of scaffolding in confined spaces has contributed to many accidents caused by workers or materials falling, improper use of guardrails, and lack of maintenance to insure worker safety. The choice of material used for scaffolding depends upon the type of work to be performed, the calculated weight to be supported, and the surface on which the scaffolding is placed, and the substance previously stored in the confined space.

Surface residues in confined spaces can increase the already hazardous conditions of electrical shock, reaction of incompatible materials, liberation of toxic substances, and bodily injury due to slips and falls. Without protective clothing, additional hazards to health may arise due to surface residues.

Structural hazards within a confined space such as baffles in horizontal tanks, trays in vertical towers, bends in tunnels, overhead structural members, or scaffolding installed for maintenance constitute physical hazards, which are exacerbated by the physical surroundings. In dealing with structural hazards, workers must review and enforce safety precautions to assure safety.

St. Bernards AWAIR Program Plan

PLAN REVIEW
Reviewer	Date
Lee Carlson	10-14-09
Brian Parrie	12/4/2013
Brian Parrie	4/23/2015

Contact: Randy Schantz

(707) 443-2735

AWAIR – A WORKPLACE

ACCIDENT AND INJURY REDUCTION PROGRAM

I. POLICY STATEMENT

The safety of our employees is the foremost consideration in the operations of St. Bernard’s Parochial School .  Accidents and injuries are not only costly to the school and the individual workers, but are often disastrous to the future of their families. St. Bernard’s Parochial School endeavors to provide our employees with a work place free of recognized health and safety hazards in an effort to conserve our human and financial resources. It is our school policy that everything within reason will be done to maintain a safe workplace for all employees.St. Bernard’s Parochial School supports the concept of returning injured employees to work in a productive position within our school at the earliest, medically possible opportunity. We believe that each employee has a place in our accident prevention program and is expected to cooperate fully in all measures taken to control and prevent losses.

II. SAFETY AND HEALTH PROGRAM DESCRIPTION

The objective of our health and safety program is to reduce employee accidents, injuries and illnesses through:

1. Maintenance of safe and healthful working conditions.
2. Insuring employee adherence to proper operating practices and procedures designed to prevent accidents, injuries and illnesses.
3. Observing, applying and complying with all Federal, State and Local safety regulations. Including, but not limited to:

School Emergency Action Plan

Employee Right to Know Program

Personal Protective Equipment Standard

Lock out \ Tag Out Program

Confined Space Entry Program

Hearing Conservation Program

Blood borne Pathogen Program

Respirator Program

4. Ensuring that each employee is properly trained and instructed in job procedures prior to job assignments.
5. Providing regular safety meetings for all employees as a means of obtaining new and updated information and training.
6. Conducting periodic safety and fire inspections to identify potential workplace hazards.
7. Conducting accident investigations to determine the cause of accidents and what actions are necessary to prevent future reoccurrence.
8. Implementing a management/labor safety committee.

III. RESPONSIBILITIES FOR WORKPLACE ACCIDENT AND INJURY CONTROL

Although safety is the responsibility of every employee, District management is responsible for the implementation, maintenance and enforcement of safety and health policies and procedures. These efforts will be in the form of employee education in safety and health practices, periodic safety inspections of the facilities and work sites and school safety meetings to review safety concerns and provide a forum for employee education. Specific responsibilities/accountabilities for safety are as follows:

The District has appointed «AWAIR» to be the school SAFETY COORDINATOR.

The Safety Coordinator will:

• Establish and maintain a health and safety reference library.
• Keep apprised of changes in health and safety regulations.
• Conduct accident investigations and safety inspections.
• File appropriate reports concerning accidents or illnesses.
• Provide safety-training programs to new and existing employees.
• Train managers and supervisors in their safety responsibilities.
• Accompany outside safety inspectors and consultants on tours of the facilities.
• Follow up on recommendations made by management, employees, the safety committee, outside inspectors and consultants.
• Maintain the accident record keeping systems and the OSHA logs.
• Maintain safety-training records (date, topic, content, attendance).
• Audit school safety performance and the goals of the AWAIR program.

 School Administration – Is responsible for the development, implementation and maintenance of the health and safety program. Managers will assign specific safety responsibilities and establish accountability measures. They will provide the resources needed to comply with all safety regulations and programs. Management will insure that accident investigations are conducted after every reported incident, regardless of whether an illness or injury occurred. These incident reports will be analyzed by managers to determine corrective measures for preventing reoccurrence.

Supervisors – are responsible for overall safety of the specific operations of the school.

Supervisors will consistently enforce all safety rules and ensure that safe practices are followed. In the event of an accident, supervisors will insure employees receive proper medical attention and that an accident report is completed. Supervisors will arrange for the correction of unsafe work conditions or procedures.

Employees – are responsible for day to day work activities and are responsible for complying with all safety regulations, school safety rules, following safe job procedures and notifying the lead worker or supervisor in the event of accident or unsafe work conditions.

IV. SAFETY COMMITTEE

The purpose of the safety committee is to assist in the detection and elimination of unsafe conditions and work procedures utilizing the following measures:

• «AWAIR» will oversee the committee and maintain records of committee activities. Copies of minutes shall be provided to:
  • Management
  • Committee members
  • Employees by posting on bulletin boards
• Management representatives from each work area ( i.e. office, warehouse, shop, etc.) should be present at each meeting. In the event they are unable to attend an alternate should attend.
• Employees shall select fellow workers from each work area to represent them on the committee.
• The terms for all committee members should be no more than one year (with the exception of the safety coordinator). Should a vacancy occur a new member from the represented area shall be selected.
• The frequency of meetings shall be determined by the committee, but shall not be less that once per month.
• The committee shall determine the date, hour and location of meetings.
• The length of each meeting shall not exceed one hour.

Scope of activities:

• Conduct safety inspections
• Assist in accident investigations to uncover trends
• Review accident reports to determine means of eliminating accidents
• Accept and evaluate employee suggestions and concerns
• Promote and publicize safety
• Monitor safety program effectiveness
• Review job procedures and recommend improvements

V. INSPECTIONS

Safety inspections of District facilities will occur on a continual basis and may be performed by the safety coordinator, managers, supervisors, consultants, insurance agents, government representatives and/or the safety committee.

These inspections will take the following form:

Departmental or work site analysis – inspections involve wall-to-wall inspection of a given department or work site and are normally performed in the presence of a departmental supervisor. These inspections will include:

• Art Facilities
• Dark Room
• Wood Shop
• Kitchen
• Metals shop
• Agricultural Shop
• Graphic Arts
• Maintenance/Custodial
• Grounds/garage
• Sciences
• Halls, gyms, etc.

Critical Items – involve the inspection of stationary and hand tools, processes, or areas, with a critical eye for possible sources of injury and methods of making these areas safer to employees.

Special Purpose – inspections will involve specialized tests or evaluations including, but not exclusive to:

Air quality

Noise

Ventilation

Ergonomics

VI. SCHOOL SAFETY RULES AND STANDARD OPERATING PROCEDURES

Each District employee is part of the safety team. Co-workers are dependent on each person correctly performing their assigned duties. The keys to preventing accidents are; following safety rules and procedures by all employees, the proper use of all machines, equipment and personal protective equipment. The following rules are provided to help employees perform their jobs safely and correctly. Compliance with these rules is required to help prevent injuries to individual employees or others and to prevent damage to property.

These rules apply throughout the school, although some departments, because of their specialized work, may have special, additional rules. Employees are required to read all safety rules, to know and follow them. A copy of the safety rules will be given to each employee and will be posted on school bulletin boards. New employees will receive a copy of the safety rules upon hire. Employees are asked to sign an acknowledgment form that states that they have read the safety rules and understand them. This form will be kept with the employees personnel file. Violations of safety rules or safety instructions may be followed by disciplinary action even though the particular violation did not result in an accident. These rules may not be completely detailed or all-inclusive, therefore, whenever unique or unusual problems arise or more specific information is necessary employees are to contact their supervisor.

SAFETY RULES

All Employees will:

1. Observe all St. Bernard’s Parochial School safety and health rules and apply the principles of accident prevention in all day-to-day activities.
2. Refrain from horseplay, throwing objects, scuffling, fooling around and/or distracting others in ways that may lead to injuries.
3. Obey all posted rules, warning signs and no smoking areas.
4. Read safety bulletins.
5. Never report to work under the influence of alcoholic beverages or drugs nor shall any employee consume, purchase or possess these items while on school premises.
6. Never climb upon, through, under or around racking, pallets, trucks, equipment, forklifts, rail cars or other obstructions.
7. Not attempt to lift or push objects that may be too heavy for them. Ask for help when needed. Learn to use correct lifting techniques to avoid strains: bend knees, keep upper body erect, push with the legs.
8. Advise fellow employees to work safely and warn workers who are working carelessly.
9. Remove jewelry, rings, bracelets and chains as these items may get caught in machinery or cause accidents.
10. Always use proper personal protective equipment for each assigned job.
11. Report hazards to lead workers or supervisors immediately.
12. Never wear frayed or loose clothing or unrestrained hair in areas where it may get caught in machinery.
13. Check to make sure ladders are free from defects, broken rungs and have solid feet.
14. Never use makeshift ladders, scaffolding or climb on boxes.
15. Never tamper with electrical switches, extension cords or circuits unless authorized.
16. Always shut down machines before cleaning, adjusting or repairing. Lock and tag the machine and switches.
17. Never oil machines while in motion.
18. Never use hands to remove obstructions from equipment unless equipment is shut off and locked and tagged.
19. Never use defective hand tools.
20. Never operate equipment for which you have not been properly trained and authorized. Observe safe operating procedures for equipment or processes.
21. Always insure that they follow safe procedures and use all safety devices and equipment. Never operate machines when guards are not in place. Guards must never be removed except when necessary to make adjustments or repairs or when their use is impractical, and they should be replaced immediately upon completion of work.
22. Never alter equipment without prior authorization.
23. Always wear respirators when there are heavy fumes or dust present. Insure that proper training in the use, care and cleaning of respirators has been received prior to use.
24. Always wear appropriate footwear for each assigned task.
25. Always keep work areas and floor clean. Put all oily and wet materials in proper containers. Put all rubbish in containers provided. Pick up all broken pallets and wrapping from floor.
26. Keep doors, aisles, control switches, emergency equipment, fire extinguishers eyewashes, first aid kits and exits clear.
27. Learn the location of fire fighting equipment, safety exits and evacuation procedures for their department.
28. Report all accidents, near misses and injuries to their supervisor immediately.
29. Always find out the safe way to perform a task.
30. Actively support and participate in the school’s efforts to provide a workplace accident and injury reduction program.

VIII. ENFORCEMENT

The following procedures will be followed in dealing with safety infractions:

1. Any employee observed committing an unsafe act, violation of safety rules or    causing an unsafe condition to exist will be stopped immediately and questioned.
2. The reason for the violation will be determined.
3. Instruction in the safe procedure will be given. When this instruction is given the following will be observed:
   • Tell the employee what is to be done.
   • Show the employee the correct way to do the job.
   • Test the employee, let them practice, observe and suggest improvements as needed.
   • Check the employee by following up after the employee has returned to work to see that the safety rules are being followed.
   • Unsafe conditions will be corrected at once. If unable to do so, all employees involved will be warned of the hazard. Prompt notification of those responsible for making the correction will be made.
   • Employees will be spot checked occasionally to see that they are following instructions.

ACTION REQUIRED FOR VIOLATION OF SCHOOL SAFETY RULES.

1. Verbal warning – Employee will be given a verbal warning for a minor offense. A record of this warning should be placed in employees personnel file.
2. Written warning – Employee will be given a written warning for relatively serious or repeat offenses. Copies of the written warning are filed in employees personnel file.
3. Suspension – Employees may be suspended from duty without pay and with a written warning for continual repeated offenses or severe violations that result in injury to him/herself and /or others.
4. Termination of employment – may occur for flagrant violations of school policies and procedures. Dismissal may also occur if employees persist in continued or repeated violations of school rules and/or their work, after repeated warnings, continues at an unacceptable level of performance.

IX. ACTION PLAN FOR IMPLEMENTATION

A. WRITTEN EMPLOYEE TRAINING PROGRAM

• Communications – Each employee will receive a copy of this program for review and training. All new employees will receive this information through the new employee orientation process. Additionally, employees will be kept aware of changes and additions to the program through: notices on bulletin boards, signs, school newsletters, booklets and accident alert notices.

• Supervisor training – All supervisors will receive copies of this AWAIR program and instructions on how to train their employees in this material. Supervisors will receive training in new processes and procedures, as these programs are developed and prior to the assignment of employees in these areas. School management, vendors or consultants will conduct this training. Refresher training will be provided as needed, but not less than annually.
• New employee orientation – Orientation will begin the first day of employment for all new employees, rehires, and part-time employees. The orientation program will include school policies and rules and will provide a thorough safety briefing, as it relates to the job the employee will be performing. The orientation will include:
  1. A tour of the facilities to acquaint employees with the scope of operations. This tour will identify: Emergency facilities, locations of emergency exits, telephones, warning sirens, first aid kits, supervisors offices, eye washes and other emergency equipment.
  2. Explanation of how the employee’s job is important to the finished product or service.
  3. Applicable training sections on:
     1. School safety and health policy
     2. Employee responsibilities
     3. Safety rules and enforcement
     4. School emergency action plan
     5. Employee Right to Know
     6. Blood borne pathogens
     7. Lock out/tag out procedures
     8. Confined space entry
     9. Personal protective equipment

4. The employee’s immediate supervisor will thoroughly instruct the employee in the specific safety and health requirements of each job before assigning the employee. A safety orientation checklist must be completed by checking each item as it is covered, signed by the supervisor, the employee and placed in the employees personnel file.

5. Existing employee training will include:
   1. Regular safety meetings
   2. Training on new hazards or operations
   3. Training prior to all work assignments, including specific hazards
   4. Annual refreshers on all existing school safety programs
   5. Specialized training would include, one time use of certain equipment, first aid training, emergency response training, etc.

B. HAZARD ASSESSMENT AND CONTROL

St. Bernard’s Parochial School will conduct safety surveys of all departments and work sites on a periodic basis to determine potential hazards that may be encountered in the normal course of duty.

Periodic follow-up surveys and/or environmental sampling may be conducted when it is believed employees may be exposed to hazardous materials in concentrations that may be above recognized OSHA standards. Qualified individuals retained by the school may conduct this sampling. Results of the sampling will be provided to employees on a timely basis.

Employees are encouraged to report potential hazards and unsafe conditions to their supervisor or lead worker. It will be the responsibility of the supervisor to verify whether or not a hazardous condition actually exists and to initiate corrective actions should they be necessary.

It will be the responsibility of the supervisor to report noted hazards to the safety coordinator who will document the identified hazard and the corrective actions taken. This documentation will be kept on file with the safety coordinator.

Once hazards are identified we will take measures either eliminate the hazards by removing them from our operations or work sites or to control those hazards through:

• Engineering controls – which would include replacing defective equipment, changing processes, utilizing different procedures or making additions or modifications to facilities, equipment or processes that would eliminate or control identified hazards.
• Administrative controls– that will be implemented after all practical engineering controls have been reviewed, include: new procedures, limits on employee exposures, written policies and training.
• Personal protective equipment – is the final method of controlling hazards and will be implemented upon review of engineering and administrative controls. Personal protective equipment will be provided for all tasks that present risks that cannot be reasonably controlled using the other two methods. The use of PPE will always require administrative controls in the form of written policies and formal training of the employees exposed to the identified hazard.

C. ACCIDENT INVESTIGATION

The school recognizes that accidents do not “just happen”, rather they are caused by a series of actions, steps or failures. Once these steps are identified, they can be eliminated or controlled. The purpose of accident investigations is not to place blame, but rather to determine the cause of the accident or “near miss” and eliminate the causative factors. Accident investigations begin with prompt reporting of accidents by employees to supervisors. It is then the responsibility of the supervisor to insure that employees receive prompt medical attention as required. Basic information collected at the scene of the accident should be entered on the District accident report form. Supervisors have access to copies of these forms. Upon completion of the form it should be sent to the safety coordinator to review and corrective actions should be taken to prevent a reoccurrence.

The safety coordinator will monitor all workplace injuries and illnesses. These injuries and illnesses will be recorded on the OSHA 200 log which will be posted on school bulletin boards each February.

The safety coordinator, managers and insurance staff will be responsible for monitoring these records to identify trends that may indicate previously unidentified hazards or additional training that may be required.

D. ACCOUNTABILITY

All employees are responsible for safety; therefore safety will be one item that is included in every employee’s job description.

Safety attitude and participation will also be considered as part of all employee performance reviews.

For employees – accountability includes adherence to safety rules and procedures, using protective equipment as required, participation on the safety committee and prompt reporting of any hazard.

For Supervisors– accountabilities include training new and existing employees in safe practices, enforcement of safety rules and procedures, prompt reporting and correction of hazards, accident investigations, department safety inspections, positive reinforcement of safe behavior and timely employee communications.

For Managers – accountabilities include all of the areas required for supervisors with the addition of participation on the safety committee, reductions in injury rates and workers compensation costs, accident investigations, proactive elimination of hazards and demonstrated leadership in safety related matters.

E. ESTABLISHED GOALS

The number one goal of the St. Bernard’s Parochial School AWAIR program is to establish a safe work environment for all school employees. In order to measure the effectiveness of our program the school has established the following additional goals:

1. Reduction in lost workday incidence rate (LWDIR) that is calculated using the following formula:

• Number of lost time injuries/illnesses per year X 200,000
• LWDIR = Total number of employee hours worked during the year

2. Reduction in workers compensation premium.
3. Reduction in accident reports filed.
4. Reduction in near miss accidents.
5. Actual documentation of hazards removed from the work place.

X. ANNUAL PROGRAM REVIEW

District safety and health efforts are ongoing and will be reviewed and updated annually or as often as necessary to help us meet our program goals.

St. Bernards Asbestos Program Plan

 

PLAN REVIEW
Reviewer	Date
Lee Carlson	10-14-09
Brian Parrie	12/4/2013
Brian Parrie	4/23/2015

 

Contact: Mitch Hoard

(707) 443-2735

ASBESTOS MANAGEMENT

Purpose

The purpose of this program is to establish guidelines and procedures in the operations and maintenance of Asbestos Containing Material (ACM) at St. Bernard’s Parochial School to protect all employees, contractors, visitors, and vendors from potential health hazards of asbestos-related diseases.

This Program applies to all buildings and structures owned by St. Bernard’s Parochial School, to all employees and sub contractors of St. Bernard’s Parochial School, to occupants St. Bernard’s Parochial School buildings, and to external organizations that may come into contact with or disturb ACM in St. Bernard’s Parochial School buildings. The Program applies to routine work during which an employee might encounter asbestos as well as work undertaken to repair or remove ACM.

Policy

It is the policy of St. Bernard’s Parochial School that only qualified employees shall be involved in any asbestos repairs, maintenance, or removal. All unqualified employees shall be protected from exposure to asbestos fibers by isolating and controlling access to all affected areas during asbestos work. All tasks involving the disturbance of ACM will be conducted only after appropriate work controls have been identified and implemented. A qualified supervisor shall be available at asbestos-controlled work sites during all activities. Proper personal protective equipment, vacuums, and HEPA filters shall be used and properly maintained. If outside contractors are used, the St. Bernard’s Parochial School shall ensure all contractor employees have been properly trained and have been issued proper equipment and protective gear.

Responsibilities

Management

• Ensure all ACM is identified and labeled
• Ensure training is effective for authorized employees
• Conduct medical surveillance of affected employees
• Establish engineering controls for all work with ACM
• Provide adequate and proper equipment and personal protective gear
• Ensure proper disposal of all ACM
• Ensure that annual notifications are published

Supervisors

• Qualified supervisors shall provide effective on-site management during work with ACM.
• Supervisors will notify «Asbestos» immediately upon discovering damaged asbestos material.

Employees

• Qualified employees must follow the exact procedures for repair or removal of ACM, including proper use of containment equipment, clean up equipment, and personal protective gear.
• Unqualified employees are to stay clear of all asbestos work areas and report any damaged ACM to their supervisor.

Hazards

Asbestos is a common, naturally occurring group of fibrous minerals. Asbestos fibers have been used in a variety of building materials, however, the St. Bernard’s Parochial School takes an aggressive effort to use non-asbestos containing materials in new construction and renovation projects. Generally, most asbestos is found in pipe insulation, doors, textured paints and plasters, structural fireproofing, and floor tiles. Friable asbestos (that is, material that contains more than 0.1% asbestos by weight and can be crumbled by hand) is a potential hazard because it can release fibers into the air if damaged.  Long-term exposure to airborne asbestos is necessary for chronic lung disease. Significant and long-term exposure to asbestos from activities that directly disturb ACM (such as asbestos mining) can lead to a variety of respiratory diseases, including asbestosis and mesothelioma (cancer of the lung lining). Asbestosis is a non-malignant, irreversible disease resulting in fibrosis of the lung. Asbestos-related cancers tend also to result from substantial long-term exposure; however, mesothelioma may result from much smaller exposures to asbestos.

Hazard Control

Engineering Controls

Engineering controls include the use of enclosures such as monitoring equipment, glove bags, tenting, negative pressure work areas, HEPA filters, controlled vacuums, water misters, and other equipment to ensure containment and clean up of asbestos work areas.

Administrative Controls

All qualified workers shall be issued proper personal protective equipment, such as respirators, disposable coveralls, gloves, etc. Written procedures and management authorizations are required for all work involving ACM.

Training Controls

All qualified employees, supervisors, and managers shall receive the proper level of training, as outlined in this program.

Definitions

 Asbestos is a generic term describing a family of naturally occurring fibrous silicate minerals. As a group, the minerals are noncombustible, do not conduct heat or electricity, and are resistant to many chemicals. Although there are several other varieties that have been used commercially, the most common asbestos mineral types likely to be encountered in District buildings are chrysotile (white asbestos), amosite (brown asbestos), and crocidolite (blue asbestos). Among these, white asbestos is by far the most common asbestos mineral present in District buildings.

Friable Asbestos means finely divided asbestos or ACM or any ACM that can be crumbled, pulverized, or powdered by hand pressure. Individual fibers in friable ACM can potentially become airborne and can then present a health hazard. Three types of friable material commonly used in buildings are sprayed fibrous fireproofing, decorative or acoustic texture coatings, and thermal insulation.

Non-friable Asbestos includes a range of products in which asbestos fiber is effectively bound in a solid matrix from which asbestos fiber cannot normally escape. Non-friable asbestos includes a variety of products including asbestos cement tiles and boards and asbestos-reinforced vinyl floor tiles. Cutting, braking, sanding, drilling, or similar activities can release asbestos fiber from even non-friable asbestos materials.

Asbestos Work Categories

 Category 1 work includes the installation or removal of non-friable asbestos in which the asbestos fiber is locked in a binder such as cement, vinyl, or asphalt that holds the material together.

Category 2 work involves work with friable asbestos that is of short duration in situations which create low levels of airborne asbestos. Examples of category 2 work are enclosure of friable asbestos; application of tape or sealant to asbestos-containing pipe insulation; minor removal of friable asbestos; and minor installation, maintenance, or repair work above false ceilings where sprayed asbestos fireproofing is present on beams.

Category 3 Work involves possible exposure to friable asbestos over long periods of time or work that generates high levels of asbestos. Included in category 3 work are removal projects where relatively large amounts of asbestos are removed from a building (including removal of friable asbestos from structural material), and cleaning or removal of heating or air handling equipment that has been insulated with asbestos. Also included in category 3 work are cutting or grinding of ACM using power tools.

Rules

General Rules

• When in doubt, treat all material as containing asbestos and comply with all applicable rules and regulations and protective measures.
• Certified and licensed asbestos abatement personnel will handle all ACM. The friability of the ACM will dictate the type of removal/maintenance required.
• Employees who are uncertified and unlicensed will not handle any ACM >1%. This will include encapsulation projects, renovation/removal, and/or demolition of any type of structure. This will prevent the potential for accidental exposure from the mishandling of any ACM.
• When an uncertified, unlicensed employee questions whether he/she may be handling suspect ACM, the employee will immediately contact his/her supervisor.  The employee shall not resume working at the site until the area has been checked to verify the material is not ACM.
• Uncertified, unlicensed employees will not cross over a barrier/containment area where asbestos projects are in progress.
• Any employee who discovers ACM or suspect ACM in damaged or poor condition should report it to his/her supervisor so the identified material is repaired.

Rules Regarding Medical Examinations

• Employees assigned to asbestos removal will be given medical examinations at the District’s expense in compliance with 29 CFR 1926.1101 and 40 CFR 763 – Subpart G:
  • Within 30 days of first employment or assignment to a job exposing the employee to asbestos containing material,
  • Annually, and
  • Within 30 days of termination of employment.

• Medical examination for employees assigned to asbestos removal will include:
  • Medical and work history with special emphasis directed to symptoms of the respiratory system, cardiovascular system, and digestive tract;
  • Medical questionnaire contained in 29 CFR 1926.1101; and
  • A physical examination including a chest roentgenogram and pulmonary function test that includes measurement of the employee’s forced vital capacity and expiratory volume.

• No employee shall be assigned to tasks requiring the use of respirators if an examining physician determines the employee will be unable to function normally while using it or that the employee might otherwise be impaired.

• Records of all physical examinations performed for work-related asbestos activities will be maintained permanently by the District.

Rules Regarding Asbestos Inventory

• The District has conducted surveys and prepared a written inventory of the type and locations of ACM to:
  • Allow for periodic condition inspections, and
  • Allow for maintenance and repair of damaged asbestos.

• For each building the inventory contains the following information:
  • Type of ACM (sprayed fireproofing, texture coating, or thermal insulation);
  • The location of the material; and
  • When is has been sampled, the type and percentage of asbestos present.

• Also included in the survey information are sampling results showing the absence of asbestos in material that might be mistaken for an ACM.

Asbestos Identification

An asbestos identification system is used to alert people to the presence of asbestos. Asbestos is identified by tags, stickers, pipe labels, signs, and other high visibility means. Where feasible, stickers indicate the presence of asbestos in thermal insulation, in asbestos board and tiles, and in other locations. Warnings may also be placed near the entrances of rooms, particularly mechanical rooms where unusually large amounts of asbestos may be present.

Inspection

Inspection of the condition of friable asbestos is integrated into the Maintenance Department routine inspection program. Periodic inspections and reports on the status of facilities and equipment in District buildings are produced to note damage to asbestos that might result in release of asbestos. When damaged ACM is discovered a work order will be issued to initiate the assessment/remediation as required.

Access Control

Access to mechanical and electrical rooms, service shafts, tunnels, and other locations is to be restricted where asbestos may be present in unusually large amounts and where other hazards may also be present. Such areas are locked and accessible only to authorized personnel. Where sprayed asbestos-containing fireproofing is present in a building above a false ceiling, access to the space is restricted to Maintenance Department employees, Communications Services, or authorized contractors.

Repair and Maintenance of ACM

Should an employee or a contractor encounter material that is not identified and is not listed in the Asbestos Inventory and which might reasonably be expected to be asbestos, the person will stop any work that could create airborne asbestos and report the discovery to a supervisor. Where it is determined that friable ACM is in a condition that could likely lead to inhalation exposure, the supervisor will immediately limit access to the location and initiate repairs, removal, or encapsulation. Where there is reasonable doubt about the composition of a friable material, it will be treated as asbestos until testing demonstrates that asbestos is present at levels below 1%.  Cleanup and repair of asbestos-containing material will only be carried out by the appropriate clean-up procedure by employees or contractors who have been properly trained.

When routine work is to take place in an area where asbestos is present or when the work might disturb friable asbestos, employees will be informed of the potential for exposure through a notation on the work order. If upon reviewing the work situation, the employee believes that normal work practices do not provide an adequate measure of safety, the employee will report these concerns to the supervisor. The supervisor will review the work situation and authorize any required additional precautions. All employees, visitors, vendors, and contractors will be notified in advance when work involving asbestos is to be carried out in any area of District buildings that they occupy.

Training

All District St. Bernard’s Parochial School who remove, repair, or work around friable asbestos and those whose work might disturb friable ACM will be trained to carry out their work without endangering themselves, their coworkers, or other building occupants.

Level 1 Training

All affected Maintenance Department employees who do not receive levels 2 or 3 training will receive Level 1 training which will acquaint them with:

• The types, properties, and uses of asbestos;
• Ways to recognize asbestos;
• The hazards of asbestos fiber inhalation;
• Types of activities which could release asbestos fibers; and
• The District Asbestos Inventory and Asbestos Identification State and Federal regulations regarding work with asbestos and disposal of asbestos-containing waste.

Refresher training will be provided every second year. Only those with Level 1 training will be allowed to carry out or supervise Category 1 asbestos work.

Level 2 Training

All District employees who conduct or may be expected to conduct Category 2 or 3 work will receive training in:

• All Level 1 topics;
• Ways to recognize and avoid damage to ACM;
• The use, fitting, limitations, care, and disposal of protective equipment;
• Asbestos containment and ventilation during removal; and
• Wet and dry clean up procedures.

Refresher training will be provided every second year. Except for actual asbestos removal, only those with Level 2 training will be allowed to carry out or supervise Category 2 asbestos work.

Level 3 Training

Level 3 training will be provided for insulators and others who are authorized to remove friable asbestos and for those who supervise asbestos removal work that is performed by either District Employees or external contractors. Level 3 training provides practical hands-on experience in all phases of small and medium scale asbestos removal. Those who will carry out small-scale asbestos removal work will receive additional on-the-job training working with experienced asbestos workers.

Contracted Work

Asbestos Removal Work

Major asbestos removal is normally contracted to external firms who specialize in asbestos removal work. The District requires that all such work be carried out in accord with the requirements established by State and Federal regulations. At all such projects the contractor will ensure that cleanup is properly completed and that all asbestos and asbestos-contaminated material is collected and disposed of in accord with the EPA regulations. The contractor will be required to submit air-testing results to demonstrate that the cleanup has been carried out properly and the area can be reoccupied safely.

Other Work

The District often employs contractors to service equipment such as elevators, telephones, refrigeration, and air conditioning equipment, and to carry out other construction and renovation projects. When contractors are required to work in areas where asbestos is present or there is a possibility of disrupting friable asbestos, the District will provide:

• Notification of the known locations and types of asbestos present (or suspected to be present) in the area where the contractor will work, and
• Information on District asbestos labeling system. The District requires that contractors carrying out tasks which could potentially create asbestos-containing dust:
• Follow work practices that reduce to the extent practical the creation of airborne asbestos dust and which meet the asbestos safety standards set by State and Federal regulations.
• Immediately report to the asbestos program manager when damage occurs to ACM, and
• Employ only workers who have been trained in asbestos safety.

Asbestos Work Procedures

Discovering Damaged Asbestos

When asbestos is discovered the following steps describe the actions to be taken by trade Employees and their supervisors. The steps comply with District Asbestos Policy, which states the long-term goal is to remove all asbestos and the short-term goal is to manage asbestos to minimize exposure to airborne asbestos. It is important to note that all asbestos is to be logged in the inventory, regardless of its state of repair.

• Complete the Asbestos Inventory Form – The employee is to complete the first section of the Asbestos Inventory Form and submit it to his/her Supervisor.
• Sampling – The Supervisor will determine if samples are required to confirm the existence of asbestos. Checking the inventory to see if asbestos in that location has already been tested will do this. If necessary, the Supervisor will close off an area (mechanical spaces) or shut down equipment (air handling units) pending test results and remedial action.
• Repair/Removal and Cleanup – If the asbestos is damaged, it is certain a clean up will be required. The clean up and repair should happen together. The repair and clean up will be charged to a work order and the number recorded on the Inventory Form. If removal is required, the supervisor will determine whether the removal will be carried out by a contractor or by District Employees. The work order number must be logged on the Inventory Form.
• Labeling – All known ACM should be labeled. For asbestos containing pipe insulation, yellow paint will be applied directly to the insulation. In areas where asbestos is present in multiple locations it will be sufficient to provide warning signage at each entry point into a room. Blue paint will be applied to any new insulation that is not readily obvious to be asbestos free.
• Logging in Database – After completing the Asbestos Inventory Form, it will be given to the District asbestos program manager for logging into the Asbestos Inventory.

Clean up of ACM

Asbestos only poses a health hazard when it becomes airborne and people inhale the fiber. When asbestos-containing material has been disturbed, effective clean up will ensure that asbestos does not present a health hazard. Clean up of dust that might contain traces of asbestos, such as a custodian might encounter in routine cleaning in buildings where asbestos is present, will not require special precautions. To ensure that clean up of significant quantities of asbestos will not cause a health hazard, the following procedure will be followed:

• Clean up of significant amounts of ACM will be only be done by Employees who have been trained and who are wearing appropriate protective clothing and a fitted, air-purifying respirator.
• Dry sweeping of asbestos-containing waste and other clean up activities that will create airborne dust are not permitted.
• Large pieces of ACM will be collected by hand and properly bagged in accord with the disposal procedure.
• When ever possible, asbestos dust will be thoroughly wetted and clean up with a wet mop or a HEPA type vacuum. Contaminated water will be discharged to a sewer. Containers, mops and other equipment that might be contaminated with asbestos will be rinsed with water and the rinse water discharged to a sewer.

If additional clean up is need it will be carried out using a vacuum equipped with a HEPA filter. Within Maintenance Department there is one vacuum assigned for asbestos clean up.

Non-friable ACM Work

Asbestos that is effectively bonded in a non-asbestos matrix cannot easily become airborne. As such, provided the material is not broken or abraded, there is little risk of inhalation exposure to asbestos. To ensure that minor work involving non-friable asbestos (including vinyl asbestos tile, asbestos asphalt roofing, and asbestos ceiling and wall tile) the following procedure will be followed:

• Before beginning the work the worker will carefully inspect the ACM to ensure that the planned work will not create airborne asbestos dust.
• Where dust that might contain asbestos fiber is present, the worker will clean the material using a wet method or a HEPA filtered vacuum.
• Following completion of the task the worker will carry out any required clean wet methods or a HEPA filtered vacuum and will then carefully bag for disposal all asbestos-containing waste.

Note: Cutting, drilling, sanding or breaking the material are likely to create airborne asbestos dusts and will require additional precautions.

Work Above False Ceilings

Only workers who have successfully completed Level 2 Asbestos Safety Training and who are authorized to do so by the asbestos program manager may move ceiling tiles or perform work above the dropped ceilings where asbestos insulation is present on building structure. The following procedure shall be used whenever minor work (such as installation of telephone or computer lines, or servicing of ventilation or lighting system components) requires work above the suspended ceiling:

• Before removing a ceiling tile, the area around the tile shall be isolated by creating an enclosure of 4-mil or heavier polyethylene sheeting. The sheeting shall be taped to the ceiling t-bar and the floor using duct tape.
• Those working within the enclosure shall wear a pair of coveralls and a properly fitted, air-purifying respirator equipped with a particulate filter designed to remove asbestos fibers from inhaled air.
• Air supply or return grills located within the enclosure shall be sealed with 4-mil or thicker polyethylene sheeting to prevent contamination of the ventilation system.
• The ceiling tile shall be carefully removed and the upper surface vacuumed with a vacuum fitted with a HEPA filter.
• The worker shall then carefully vacuum the upper surface of surrounding tiles before carrying out the assigned task.
• Following completion of the above-the-ceiling work, the removed ceiling tile shall be replaced and the interior of the enclosure carefully cleaned using wet cleaning techniques or a HEPA filtered vacuum.

Note: Additional precautions may be required depending upon the specific tasks to be undertaken. Any task that is likely to disrupt the sprayed-on insulation will require additional precautions.

Repairs to ACM

Where asbestos is known or believed to be present in damaged insulation, repairs or removal are needed to prevent asbestos fiber from becoming airborne. Only workers who have successfully completed Level 3 Asbestos Safety training and who are authorized to do so may undertake such repairs or removal. The following procedure will be used whenever minor repairs to asbestos containing insulation is undertaken:

• Access to areas where minor repair is to be carried out will be restricted to authorized people only. When necessary, signs will be posted advising of access restrictions.
• Workers repairing asbestos-containing insulation will wear coveralls and a properly fitted, air-purifying respirator equipped with a particulate filter designed to remove asbestos fibers from inhaled air.
• Before beginning the repair, the area will be carefully cleaned using the Clean-up of Asbestos-Containing Material Procedure.
• When feasible a drop cloth shall then be placed beneath the insulation to be repaired.
• Before beginning the repair, all feasible steps (wetting with amended water, encapsulating adjacent asbestos-containing material, etc.) will be taken to prevent the release of asbestos fibers.
• Following the repair the worker will carefully bag for disposal all asbestos- containing waste and clean the surrounding area using wet cleaning techniques or a HEPA filtered vacuum.

Single-Use Glove Bag Procedure

The following procedure will be followed when single-use asbestos removal glove bags are used. The procedure may only be used on tasks that are small enough to be completely enclosed in the glove bag and which do not leave exposed asbestos in place when the bag is removed.

Preparation:

Only a Employee who has completed level 3 training and who is wearing appropriate coveralls and an air-purifying respirator (3M 6000 Series with a purple, 6240 particulate filter or equivalent) will carry out glove bag removal of asbestos.

Before beginning removal work, access to the area will be restricted. If the work site is located in areas where other Maintenance Department Employees might be exposed to asbestos, and in all work sites located in publicly accessible areas, warning notices will be posted.

Steps will be taken to prevent accidental movement, contact with heat, cold or electricity, or release of chemicals.

The work area will be cleaned using a HEPA filtered vacuum or wet cleaning to remove asbestos-containing material contaminating the immediate work area. Where possible a plastic sheet will then be placed beneath the pipe or fitting from which the asbestos is to be removed.

Steps will be taken to prevent exposure where damage to the insulation might allow release of fibers. Steps include making temporary repairs using duck tape or wetting the exposed fiber using amended water.

Glove Bag Removal:

The asbestos-containing material will be thoroughly wetted using amended water.

With tools in bag, the single-use bag will be positioned and secured using adhesive and tape as necessary.

Working through the gloves, the asbestos will be removed exercising care to avoid puncturing the bag.

When removal is compete or bag is full, sprayer (containing amended water) will be inserted into the bag and the pipe or fitting, tools and the bag interior will be washed.

Tools will then be placed in an inverted glove withdrawn from bag and the glove sealed from the bag using duct tape.

The tools will then be removed by cutting through the duct tape ensuring that both the bag and the glove remain sealed.

The tools will then be submerged in water and the glove opened. Tools will be cleaned under water.

The glove bag will then be carefully removed, sealed and placed in a sealed container pending packaging for disposal.

Clean Up:

The surface of the pipe or fitting will be carefully wet wiped and treated with sealer.

The plastic sheet will then be carefully wet wiped and rolled up.

All solid waste created during removal jobs including glove bags, disposable coveralls, wipe rags and plastic sheeting will be treated as asbestos containing waste and handled as detailed in the disposal procedure.

Multiple-Use Glove Bag Procedure

This procedure describes the use of multiple use glove bags. It may be used on tasks that require the bag to be repositioned to complete the entire job.

Preparation:

Only a Employee who has completed level 3 training and who is wearing appropriate coverall and an air purifying respirator (3M 6000 Series with a purple, 6240 particulate filter or equivalent) will carry out glove bag removal of asbestos.

Before beginning removal work, access to the area will be restricted. If the work site is located in areas where other Maintenance Department Employees might be exposed to asbestos and in all work sites located in publicly accessible areas, warning notices will be posted.

Steps will be taken to prevent accidental movement, contact with heat, cold or electricity, or release of chemicals.

The work area will be cleaned using a HEPA filtered vacuum or wet cleaning to remove asbestos-containing material contaminating the immediate work area. Where possible a plastic sheet will then be placed beneath the pipe or fitting from which the asbestos is to be removed.

Steps will be taken to prevent exposure where damage to the insulation might allow release of fibers. Steps include making temporary repairs using duck tape or wetting the exposed fiber using amended water.

Glove Bag Removal:

The asbestos containing material will be thoroughly wetted using amended water.

With tools in bag, the bag will be positioned and secured using adhesive and tape as necessary.

Working through the gloves, the asbestos will be removed exercising care to avoid puncturing the bag.

When removal is compete or bag is full, sprayer (containing amended water) will be connected to the valve and the pipe or fitting, tools and the bag interior will be washed. If the bag is repositioned to remove additional asbestos, remaining exposed ends of asbestos will be thoroughly damped.

Tools will then be placed in an inverted glove withdrawn from bag and the glove sealed from the bag using duct tape.

The tools will then be removed by cutting through the duct tape ensuring that both the bag and the glove remain sealed.

The tools will then be submerged in water and the glove opened. Tools will be cleaned under water.

The glove bag will then be removed and placed in a sealed container pending packaging for disposal.

Clean Up:

The surface of the pipe or fitting will be carefully wet wiped and treated with sealer.

The plastic sheet will then be carefully wet wiped and rolled up.

All solid waste created during removal jobs including glove bags, disposable coveralls, wipe rags and plastic sheeting will be treated as asbestos containing waste and handled as detailed in the disposal procedure.

Modified Enclosure Procedure

The following Modified Enclosure Method may be used for removal of asbestos from ceilings, walls, beams, pipes, or other equipment providing that the job is small enough that it can be completed within one shift without the need for repeated entry into the work area.

The method may not be used for jobs involving:

Amosite, Crocidolite, or Friable asbestos of any type.

Additional precautions will be required if the exhaust air cannot be discharged outdoors. Modified enclosure removals may only be undertaken by Employees who have completed level three training and who have received modified enclosure removal training.

Preparation:

If dust that might contain asbestos is present, pre clean the work site using wet cleaning or HEPA vacuum cleaning.

Protect floor, walls equipment within the work area that might be damaged by water.

Ensure that steps are taken to protect workers from any energized equipment or systems located within the work area.

Post signs and restrict access to work area.

Seal area to prevent air leakage into adjacent areas or air handling system using framing as necessary, 150 mil plastic sheeting, tape, sealants and caulking as required. Construct an overlapping, double curtained entrance to work area.

Install HEPA filtered negative air unit in work area. Unit must provide 4 air changes per hour while maintaining a pressure difference of -0.02 inches of water. Direct filtered exhaust air outdoors.

Removal:

Employees entering the work are shall wear a disposable Tyvek type suit including a head cover and an air purifying respirator (3M 6000 Series with a purple, 6240 particulate filter or equivalent).

With the area sealed and negative air unit in operation, saturate asbestos- containing material with amended water using airless sprayer.

Remove asbestos using additional amended water as needed being careful not to create airborne dust.

Brush the area from which asbestos has been removed and then wet wipe or vacuum to remove final traces of asbestos. Following removal of asbestos, treat the area with slow dry sealer.

Clean up:

Place all waste in specially marked heavy-duty asbestos waste disposal bags. Seal waste bags securely using duct tape before removing from the enclosure. Wipe all tools with a damp cloth to remove traces of asbestos contamination before removing them from the enclosure.

Wet wipe or vacuum (using the designated shop vac marked ASBESTOS ONLY) all areas within the enclosure not covered by plastic to remove traces of asbestos.  If a HEPA filtered shop vac was used, it shall be wiped with a damp cloth and the hose end covered with tape before being removed from the enclosure. If the vac is to be opened to change a filter or bag, the work will be carried out in an enclosure under negative pressure with HEPA filtered air exhausted outdoors.

Wet wipe the interior of plastic sheeting used to form the enclosure. Remove plastic by rolling, wet wiping any visible particulate matter that make be visible. Wet wipe the disposable Tyvek suit and remove. Place the plastic sheeting, the suit and the used respirator cartridges in an asbestos waste bag along with other remaining contaminated material.

Arrange for reconnection of any services running through the work area that were disconnected to accommodate removal work.

Dispose of waste as per waste disposal procedure.
Disposal of Asbestos-Containing Waste Materials

Handling and disposal of asbestos-containing waste is regulated by both State and Federal regulations. To ensure compliance with these regulations and to ensure that no one is exposed to asbestos the following procedure is to be followed:

Only an Employee who has completed Level 2 training and who is wearing appropriate air purifying respirator will package asbestos waste.

Waste asbestos will be thoroughly wetted and then placed in specially labeled 6 mil plastic bags. The bag will be securely sealed using duct tape. The bagged asbestos will then be placed in a second, labeled 6-mil plastic bag that is again taped closed.

Asbestos waste may be transported from the location where it was produced to an interim storage location if the bags are free from punctures or tears and if the outside of the bag is free of asbestos. Asbestos waste will be transported in an enclosed vehicle or beneath a secured tarpaulin. No other cargo may be carried while the waste asbestos is being moved. After the waste asbestos is moved to an interim storage site, the driver will, if necessary clean the vehicle to remove asbestos contamination.

Asbestos waste must be disposed of at a waste disposal site that is approved to receive asbestos by Environmental Protection Agency(EPA) or the state pollution control agency.

Shipment of waste asbestos must be coordinated with the waste disposal site that is to receive the waste. External contractors will normally carry out asbestos disposal.

Shipments for disposal must be done in accord with [STATE] and Federal DOT regulations and must be accompanied by a properly completed shipping document.

 

St. Mary’s Mission AWAIR Program Plan

PLAN REVIEW
Reviewer	Reviewer
Brian Parrie	5/23/2011

 

Contact: Al Branchaud

218-679-3388

AWAIR – A WORKPLACE

ACCIDENT AND INJURY REDUCTION PROGRAM

I. POLICY STATEMENT

The safety of our employees is the foremost consideration in the operations of St. Mary’s Mission.  Accidents and injuries are not only costly to the school and the individual workers, but are often disastrous to the future of their families. St. Mary’s Mission endeavors to provide our employees with a work place free of recognized health and safety hazards in an effort to conserve our human and financial resources. It is our school policy that everything within reason will be done to maintain a safe workplace for all employees. St. Mary’s Mission supports the concept of returning injured employees to work in a productive position within our school at the earliest, medically possible opportunity. We believe that each employee has a place in our accident prevention program and is expected to cooperate fully in all measures taken to control and prevent losses.

II. SAFETY AND HEALTH PROGRAM DESCRIPTION

The objective of our health and safety program is to reduce employee accidents, injuries and illnesses through:

1. Maintenance of safe and healthful working conditions.
2. Insuring employee adherence to proper operating practices and procedures designed to prevent accidents, injuries and illnesses.
3. Observing, applying and complying with all Federal, State and Local safety regulations. Including, but not limited to:

School Emergency Action Plan

Employee Right to Know Program

Personal Protective Equipment Standard

Lock out \ Tag Out Program

Confined Space Entry Program

Hearing Conservation Program

Blood borne Pathogen Program

Respirator Program

4. Ensuring that each employee is properly trained and instructed in job procedures prior to job assignments.
5. Providing regular safety meetings for all employees as a means of obtaining new and updated information and training.
6. Conducting periodic safety and fire inspections to identify potential workplace hazards.
7. Conducting accident investigations to determine the cause of accidents and what actions are necessary to prevent future reoccurrence.
8. Implementing a management/labor safety committee.

III. RESPONSIBILITIES FOR WORKPLACE ACCIDENT AND INJURY CONTROL

Although safety is the responsibility of every employee, District management is responsible for the implementation, maintenance and enforcement of safety and health policies and procedures. These efforts will be in the form of employee education in safety and health practices, periodic safety inspections of the facilities and work sites and school safety meetings to review safety concerns and provide a forum for employee education. Specific responsibilities/accountabilities for safety are as follows:

The District has appointed «AWAIR» to be the school SAFETY COORDINATOR.

The Safety Coordinator will:

• Establish and maintain a health and safety reference library.
• Keep apprised of changes in health and safety regulations.
• Conduct accident investigations and safety inspections.
• File appropriate reports concerning accidents or illnesses.
• Provide safety-training programs to new and existing employees.
• Train managers and supervisors in their safety responsibilities.
• Accompany outside safety inspectors and consultants on tours of the facilities.
• Follow up on recommendations made by management, employees, the safety committee, outside inspectors and consultants.
• Maintain the accident record keeping systems and the OSHA logs.
• Maintain safety-training records (date, topic, content, attendance).
• Audit school safety performance and the goals of the AWAIR program.

 School Administration – Is responsible for the development, implementation and maintenance of the health and safety program. Managers will assign specific safety responsibilities and establish accountability measures. They will provide the resources needed to comply with all safety regulations and programs. Management will insure that accident investigations are conducted after every reported incident, regardless of whether an illness or injury occurred. These incident reports will be analyzed by managers to determine corrective measures for preventing reoccurrence.

Supervisors – are responsible for overall safety of the specific operations of the school.

Supervisors will consistently enforce all safety rules and ensure that safe practices are followed. In the event of an accident, supervisors will insure employees receive proper medical attention and that an accident report is completed. Supervisors will arrange for the correction of unsafe work conditions or procedures.

Employees – are responsible for day to day work activities and are responsible for complying with all safety regulations, school safety rules, following safe job procedures and notifying the lead worker or supervisor in the event of accident or unsafe work conditions.

IV. SAFETY COMMITTEE

The purpose of the safety committee is to assist in the detection and elimination of unsafe conditions and work procedures utilizing the following measures:

• «AWAIR» will oversee the committee and maintain records of committee activities. Copies of minutes shall be provided to:
  • Management
  • Committee members
  • Employees by posting on bulletin boards
• Management representatives from each work area ( i.e. office, warehouse, shop, etc.) should be present at each meeting. In the event they are unable to attend an alternate should attend.
• Employees shall select fellow workers from each work area to represent them on the committee.
• The terms for all committee members should be no more than one year (with the exception of the safety coordinator). Should a vacancy occur a new member from the represented area shall be selected.
• The frequency of meetings shall be determined by the committee, but shall not be less that once per month.
• The committee shall determine the date, hour and location of meetings.
• The length of each meeting shall not exceed one hour.

Scope of activities:

• Conduct safety inspections
• Assist in accident investigations to uncover trends
• Review accident reports to determine means of eliminating accidents
• Accept and evaluate employee suggestions and concerns
• Promote and publicize safety
• Monitor safety program effectiveness
• Review job procedures and recommend improvements

V. INSPECTIONS

Safety inspections of District facilities will occur on a continual basis and may be performed by the safety coordinator, managers, supervisors, consultants, insurance agents, government representatives and/or the safety committee.

These inspections will take the following form:

Departmental or work site analysis – inspections involve wall-to-wall inspection of a given department or work site and are normally performed in the presence of a departmental supervisor. These inspections will include:

• Art Facilities
• Dark Room
• Wood Shop
• Kitchen
• Metals shop
• Agricultural Shop
• Graphic Arts
• Maintenance/Custodial
• Grounds/garage
• Sciences
• Halls, gyms, etc.

Critical Items – involve the inspection of stationary and hand tools, processes, or areas, with a critical eye for possible sources of injury and methods of making these areas safer to employees.

Special Purpose – inspections will involve specialized tests or evaluations including, but not exclusive to:

Air quality

Noise

Ventilation

Ergonomics

VI. SCHOOL SAFETY RULES AND STANDARD OPERATING PROCEDURES

Each District employee is part of the safety team. Co-workers are dependent on each person correctly performing their assigned duties. The keys to preventing accidents are; following safety rules and procedures by all employees, the proper use of all machines, equipment and personal protective equipment. The following rules are provided to help employees perform their jobs safely and correctly. Compliance with these rules is required to help prevent injuries to individual employees or others and to prevent damage to property.

These rules apply throughout the school, although some departments, because of their specialized work, may have special, additional rules. Employees are required to read all safety rules, to know and follow them. A copy of the safety rules will be given to each employee and will be posted on school bulletin boards. New employees will receive a copy of the safety rules upon hire. Employees are asked to sign an acknowledgment form that states that they have read the safety rules and understand them. This form will be kept with the employees personnel file. Violations of safety rules or safety instructions may be followed by disciplinary action even though the particular violation did not result in an accident. These rules may not be completely detailed or all-inclusive, therefore, whenever unique or unusual problems arise or more specific information is necessary employees are to contact their supervisor.

SAFETY RULES

All Employees will:

1. Observe all St. Mary’s Mission safety and health rules and apply the principles of accident prevention in all day-to-day activities.
2. Refrain from horseplay, throwing objects, scuffling, fooling around and/or distracting others in ways that may lead to injuries.
3. Obey all posted rules, warning signs and no smoking areas.
4. Read safety bulletins.
5. Never report to work under the influence of alcoholic beverages or drugs nor shall any employee consume, purchase or possess these items while on school premises.
6. Never climb upon, through, under or around racking, pallets, trucks, equipment, forklifts, rail cars or other obstructions.
7. Not attempt to lift or push objects that may be too heavy for them. Ask for help when needed. Learn to use correct lifting techniques to avoid strains: bend knees, keep upper body erect, push with the legs.
8. Advise fellow employees to work safely and warn workers who are working carelessly.
9. Remove jewelry, rings, bracelets and chains as these items may get caught in machinery or cause accidents.
10. Always use proper personal protective equipment for each assigned job.
11. Report hazards to lead workers or supervisors immediately.
12. Never wear frayed or loose clothing or unrestrained hair in areas where it may get caught in machinery.
13. Check to make sure ladders are free from defects, broken rungs and have solid feet.
14. Never use makeshift ladders, scaffolding or climb on boxes.
15. Never tamper with electrical switches, extension cords or circuits unless authorized.
16. Always shut down machines before cleaning, adjusting or repairing. Lock and tag the machine and switches.
17. Never oil machines while in motion.
18. Never use hands to remove obstructions from equipment unless equipment is shut off and locked and tagged.
19. Never use defective hand tools.
20. Never operate equipment for which you have not been properly trained and authorized. Observe safe operating procedures for equipment or processes.
21. Always insure that they follow safe procedures and use all safety devices and equipment. Never operate machines when guards are not in place. Guards must never be removed except when necessary to make adjustments or repairs or when their use is impractical, and they should be replaced immediately upon completion of work.
22. Never alter equipment without prior authorization.
23. Always wear respirators when there are heavy fumes or dust present. Insure that proper training in the use, care and cleaning of respirators has been received prior to use.
24. Always wear appropriate footwear for each assigned task.
25. Always keep work areas and floor clean. Put all oily and wet materials in proper containers. Put all rubbish in containers provided. Pick up all broken pallets and wrapping from floor.
26. Keep doors, aisles, control switches, emergency equipment, fire extinguishers eyewashes, first aid kits and exits clear.
27. Learn the location of fire fighting equipment, safety exits and evacuation procedures for their department.
28. Report all accidents, near misses and injuries to their supervisor immediately.
29. Always find out the safe way to perform a task.
30. Actively support and participate in the school’s efforts to provide a workplace accident and injury reduction program.

VIII. ENFORCEMENT

The following procedures will be followed in dealing with safety infractions:

1. Any employee observed committing an unsafe act, violation of safety rules or    causing an unsafe condition to exist will be stopped immediately and questioned.
2. The reason for the violation will be determined.
3. Instruction in the safe procedure will be given. When this instruction is given the following will be observed:
   • Tell the employee what is to be done.
   • Show the employee the correct way to do the job.
   • Test the employee, let them practice, observe and suggest improvements as needed.
   • Check the employee by following up after the employee has returned to work to see that the safety rules are being followed.
   • Unsafe conditions will be corrected at once. If unable to do so, all employees involved will be warned of the hazard. Prompt notification of those responsible for making the correction will be made.
   • Employees will be spot checked occasionally to see that they are following instructions.

ACTION REQUIRED FOR VIOLATION OF SCHOOL SAFETY RULES.

1. Verbal warning – Employee will be given a verbal warning for a minor offense. A record of this warning should be placed in employees personnel file.
2. Written warning – Employee will be given a written warning for relatively serious or repeat offenses. Copies of the written warning are filed in employees personnel file.
3. Suspension – Employees may be suspended from duty without pay and with a written warning for continual repeated offenses or severe violations that result in injury to him/herself and /or others.
4. Termination of employment – may occur for flagrant violations of school policies and procedures. Dismissal may also occur if employees persist in continued or repeated violations of school rules and/or their work, after repeated warnings, continues at an unacceptable level of performance.

IX. ACTION PLAN FOR IMPLEMENTATION

A. WRITTEN EMPLOYEE TRAINING PROGRAM

• Communications – Each employee will receive a copy of this program for review and training. All new employees will receive this information through the new employee orientation process. Additionally, employees will be kept aware of changes and additions to the program through: notices on bulletin boards, signs, school newsletters, booklets and accident alert notices.

• Supervisor training – All supervisors will receive copies of this AWAIR program and instructions on how to train their employees in this material. Supervisors will receive training in new processes and procedures, as these programs are developed and prior to the assignment of employees in these areas. School management, vendors or consultants will conduct this training. Refresher training will be provided as needed, but not less than annually.
• New employee orientation – Orientation will begin the first day of employment for all new employees, rehires, and part-time employees. The orientation program will include school policies and rules and will provide a thorough safety briefing, as it relates to the job the employee will be performing. The orientation will include:
  1. A tour of the facilities to acquaint employees with the scope of operations. This tour will identify: Emergency facilities, locations of emergency exits, telephones, warning sirens, first aid kits, supervisors offices, eye washes and other emergency equipment.
  2. Explanation of how the employee’s job is important to the finished product or service.
  3. Applicable training sections on:
     1. School safety and health policy
     2. Employee responsibilities
     3. Safety rules and enforcement
     4. School emergency action plan
     5. Employee Right to Know
     6. Blood borne pathogens
     7. Lock out/tag out procedures
     8. Confined space entry
     9. Personal protective equipment

4. The employee’s immediate supervisor will thoroughly instruct the employee in the specific safety and health requirements of each job before assigning the employee. A safety orientation checklist must be completed by checking each item as it is covered, signed by the supervisor, the employee and placed in the employees personnel file.

5. Existing employee training will include:
   1. Regular safety meetings
   2. Training on new hazards or operations
   3. Training prior to all work assignments, including specific hazards
   4. Annual refreshers on all existing school safety programs
   5. Specialized training would include, one time use of certain equipment, first aid training, emergency response training, etc.

B. HAZARD ASSESSMENT AND CONTROL

St. Mary’s Mission will conduct safety surveys of all departments and work sites on a periodic basis to determine potential hazards that may be encountered in the normal course of duty.

Periodic follow-up surveys and/or environmental sampling may be conducted when it is believed employees may be exposed to hazardous materials in concentrations that may be above recognized OSHA standards. Qualified individuals retained by the school may conduct this sampling. Results of the sampling will be provided to employees on a timely basis.

Employees are encouraged to report potential hazards and unsafe conditions to their supervisor or lead worker. It will be the responsibility of the supervisor to verify whether or not a hazardous condition actually exists and to initiate corrective actions should they be necessary.

It will be the responsibility of the supervisor to report noted hazards to the safety coordinator who will document the identified hazard and the corrective actions taken. This documentation will be kept on file with the safety coordinator.

Once hazards are identified we will take measures either eliminate the hazards by removing them from our operations or work sites or to control those hazards through:

• Engineering controls – which would include replacing defective equipment, changing processes, utilizing different procedures or making additions or modifications to facilities, equipment or processes that would eliminate or control identified hazards.
• Administrative controls– that will be implemented after all practical engineering controls have been reviewed, include: new procedures, limits on employee exposures, written policies and training.
• Personal protective equipment – is the final method of controlling hazards and will be implemented upon review of engineering and administrative controls. Personal protective equipment will be provided for all tasks that present risks that cannot be reasonably controlled using the other two methods. The use of PPE will always require administrative controls in the form of written policies and formal training of the employees exposed to the identified hazard.

C. ACCIDENT INVESTIGATION

The school recognizes that accidents do not “just happen”, rather they are caused by a series of actions, steps or failures. Once these steps are identified, they can be eliminated or controlled. The purpose of accident investigations is not to place blame, but rather to determine the cause of the accident or “near miss” and eliminate the causative factors. Accident investigations begin with prompt reporting of accidents by employees to supervisors. It is then the responsibility of the supervisor to insure that employees receive prompt medical attention as required. Basic information collected at the scene of the accident should be entered on the District accident report form. Supervisors have access to copies of these forms. Upon completion of the form it should be sent to the safety coordinator to review and corrective actions should be taken to prevent a reoccurrence.

The safety coordinator will monitor all workplace injuries and illnesses. These injuries and illnesses will be recorded on the OSHA 200 log which will be posted on school bulletin boards each February.

The safety coordinator, managers and insurance staff will be responsible for monitoring these records to identify trends that may indicate previously unidentified hazards or additional training that may be required.

D. ACCOUNTABILITY

All employees are responsible for safety; therefore safety will be one item that is included in every employee’s job description.

Safety attitude and participation will also be considered as part of all employee performance reviews.

For employees – accountability includes adherence to safety rules and procedures, using protective equipment as required, participation on the safety committee and prompt reporting of any hazard.

For Supervisors– accountabilities include training new and existing employees in safe practices, enforcement of safety rules and procedures, prompt reporting and correction of hazards, accident investigations, department safety inspections, positive reinforcement of safe behavior and timely employee communications.

For Managers – accountabilities include all of the areas required for supervisors with the addition of participation on the safety committee, reductions in injury rates and workers compensation costs, accident investigations, proactive elimination of hazards and demonstrated leadership in safety related matters.

E. ESTABLISHED GOALS

The number one goal of the St. Mary’s Mission AWAIR program is to establish a safe work environment for all school employees. In order to measure the effectiveness of our program the school has established the following additional goals:

1. Reduction in lost workday incidence rate (LWDIR) that is calculated using the following formula:

• Number of lost time injuries/illnesses per year X 200,000
• LWDIR = Total number of employee hours worked during the year

2. Reduction in workers compensation premium.
3. Reduction in accident reports filed.
4. Reduction in near miss accidents.
5. Actual documentation of hazards removed from the work place.

X. ANNUAL PROGRAM REVIEW

District safety and health efforts are ongoing and will be reviewed and updated annually or as often as necessary to help us meet our program goals.