Stockton University

ASBESTOS MANAGEMENT PLAN

January 2024
Asbestos Management Plan Table of Contents

I.	Introduction

II.	Definitions

III.	Identification of Asbestos

IV.	Notification and Labeling

V.	Operations & Maintenance (O&M)

VI.	Asbestos Abatement Removal

VII.	Air Monitoring

VIII.	Disposal of Asbestos

IX.	Training

X.	Recordkeeping

XI.	Contractors

Appendix A – Designated Person
Appendix B – Asbestos Inspection Report
Appendix C - 40 CFR 763.92 Periodic Surveillance Semi-Annual Asbestos O&M Inspection Form	
I.	INTRODUCTION

Stockton University of New Jersey is committed to provide and maintain safe and healthy conditions for its employees, students, and visitors.  The University has developed an Asbestos-Containing Materials (ACM) management program. Any ACM will be managed in accordance with all applicable Federal, State, and Local regulations.

II.	DEFINITIONS

Asbestos: A natural material made up of tiny fibers.  Asbestos is a group of six different fibrous minerals including: amosite, chrysotile, crocidolite, tremolite, actinolite, and anthophyllite.  Chrysotile is the most common.

Asbestos Operations and Maintenance (O&M):  The manner in which (any known friable or potentially friable) asbestos materials are managed, as required by the Environmental Protection Agency (EPA). This may include the repair, removal, inspection or encapsulation of asbestos materials.

Asbestos Regulated Materials: Any material containing more than one percent asbestos that is friable, non-friable, material that becomes friable, or will be made friable by sanding, grinding, cutting or abrasion.  In addition, non-friable material (cannot be crumbled to a powder by hand pressure) that may be subjected to excessive forces during renovation is also regulated.  Asbestos-containing material (ACM) is regulated by the Environmental Protection Agency (EPA), Occupational Health and Safety Administration (OSHA) and the NJ Department of Health, Division of Epidemiology, Environmental and Occupational Health.

Designated Person: An individual assigned by the University to oversee asbestos-related activities and be the liaison between Facilities Operations and Plant Management and the building occupants.

Contractor: Any company, and their employees, hired to perform work for the University. This includes any subcontractors that may be hired to perform work under the direct supervision of a General Contractor.

Friable Asbestos: Material containing more than one percent asbestos which, when dry, can be rumbled, pulverized, or reduced to a powder by hand pressure.
	
Non-Friable Asbestos: Material that contains more than one percent asbestos, but cannot be pulverized under hand pressure.

Presumed Asbestos Containing Material (PACM):  Any material that is suspected of containing asbestos material, until sampled and analyzed by an accredited laboratory, shall be presumed asbestos containing (PACM) in all buildings or renovations constructed prior to 1988.

Asbestos-containing material (ACM): means any material containing more than one percent asbestos. Also known as asbestos-containing building material (ACBM).

Small Scale, Short Duration Asbestos Removal: The removal of a limited amount of asbestos containing material that constitutes less than or equal to one disposal bag/one glove-bag.

Response Action: An approved method, including removal, encapsulation, enclosure, repair, operations and maintenance that protect human health and the environment from asbestos containing material.

Removal: Any operation where ACM or PACM is taken out or stripped from structures
or substrates.

Surfacing ACM: Any ACM which is applied as a surface treatment. Examples include
spray-applied fireproofing and acoustical ceiling textures.

Thermal System Insulation (TSI) ACM: – Any ACM which is applied to pipes, boilers,
boiler tanks, ducts, or other systems to prevent heat loss or gain. Examples include pipe insulation, duct wrap, and boiler tank insulation.

III.	IDENTIFICATION OF ASBESTOS

The Environmental/Health/Safety (EHS) Office and the Office of Facilities Maintenance and Plant Operations (FMPO) have conducted asbestos surveys of facilities for the presence of asbestos containing materials.  The asbestos surveys and inspections for the presence of asbestos were conducted by trained and certified contractors.

IV.	NOTIFICATION AND LABELING

EHS will notify building workers, occupants, and outside contractors about the location and physical condition of ACM and stress the need to avoid disturbing the materials. Contractors and subcontractors shall review the Asbestos Management Plan and the Asbestos Inspection Report for their information.

EHS will decide which notification procedure will be most appropriate for the building occupants. The following forms of employee / occupant notifications are used.

Written Notice – Sending annual email notification to faculty and staff and direct them to the EHS Asbestos Awareness web page

Awareness / Information Session – Annual awareness training will be provided to custodial / maintenance / trades individuals. 

Area Posting and Material Labeling – In service and maintenance areas, postings and labeling will be used to remind maintenance / custodial employees / trades not to inadvertently disturb the ACM. Labeling, as opposed to notification, is not intended as general information. It serves as a final line of defense to prevent unprotected individuals from disturbing ACM or entering areas where repair or renovation activities involving ACM are underway.
In addition, supervisory personnel have received competent person training and are provided with summary sheets of the Asbestos Inspection Report for quick reference.

Signs that can be placed at entrances to areas (KK001 Boiler Room) where ACM is prevalent shall read:

CAUTION ASBESTOS-HAZARD DO NOT DISTURB WITHOUT PROPER
TRAINING AND EQUIPMENT

Warnings signs placed directly on ACM shall read:

DANGER 
CONTAINS ASBESTOS FIBERS AVOID CREATING DUST
CANCER AND LUNG DISEASE HAZARD 

Facilities Maintenance and Plant Operations (FMPO), Facilities Planning and Construction Management (FPCM) and other Departments may contact the EHS Department for assistance and/or procedures where their work, or contractors, may disturb any suspect asbestos materials prior to starting such activities.

EHS, FMPO or FPCM will notify personnel of asbestos abatement projects and provide a timeframe for their start and finish.

V.	OPERATIONS AND MAINTENANCE (O&M)

EHS and FMPO coordinate all asbestos Operations and Maintenance (O&M) abatements. This includes, but is not limited to, established activities such as floor care, ceiling material, pipe insulation, and other standard maintenance responses that have the potential to disturb presumed asbestos or asbestos containing materials. 

Periodic surveillance. 

(1) At least once every 6 months after a management plan is in effect the University shall conduct periodic surveillance in each building that contains ACM/ACBM or is assumed to contain ACM/ACBM.

(2) Each person performing periodic surveillance shall:

(i) Visually inspect all areas that are identified in the management plan/Asbestos Inspection Report as ACM/ACBM or assumed ACM/ACBM.
(ii) Record the date of the surveillance, his or her name, and any changes in the condition of the materials.
(iii) Submit to the Designated Person for inclusion in the management plan recordkeeping.
(3) A copy of the semi-annual surveillance report can be found on Appendix C.
 
University employees are not trained for asbestos abatements and are prohibited from attempting any abatement or clean-up work.  This work will only be performed by qualified contractors who meet the OSHA worker protection regulations.

VI.	ASBESTOS ABATEMENT REMOVAL

There are several types of asbestos abatements that may be conducted on campus; Operations & Maintenance (O&M), large-scale abatements, and Emergency Response abatements.

OSHA Class I asbestos work is work involving the removal of ACM or PACM Surfacing Materials and TSI.

OSHA Class II asbestos work is work involving the removal of ACM which is not
Surfacing or TSI.

OSHA Class III asbestos work is work involving the repair and maintenance of building
systems which may involve the disturbance of ACM or PACM.

OSHA Class IV asbestos work is work which may put employees in contact with ACM
or PACM materials, but where no disturbance occurs.

Emergency Response abatements.

All asbestos abatement removal projects will be performed by approved asbestos contractors. 

VII.	AIR MONITORING

EHS will assure that the asbestos contractor provides all required air monitoring where applicable. Records of such monitoring will be maintained indefinitely in the Office of EHS as part of this Asbestos Management Plan.

VIII.	DISPOSAL OF ASBESTOS

ACM material removed during an Asbestos O&M operation by the contractor shall be placed in properly labeled asbestos disposal bags.

Contractors performing asbestos abatement projects will dispose of abated ACM in a certified asbestos disposal facility and follow all federal, state and local notification requirements.

A waste manifest or similar tracking document shall be completed for each shipment of material to an asbestos landfill. For waste manifest recordkeeping see Section X Recordkeeping.

IX.	TRAINING

There are many levels of asbestos training. OSHA requires worker training programs for all employees exposed to fiber levels (either measured or anticipated) at or above the action level (0.1 f/cc 8 hour TWA) or the excursion limit (1.0 f/cc, 30 minute TWA). Since University employees will not be involved in asbestos abatement projects that could expose them to asbestos fibers the University will only provide Awareness Training.

Awareness Training

Awareness level training is designed for departments whom, in the course of their duties, may accidentally disturb asbestos containing materials. The employees shall attend an asbestos awareness level training session.

Per 40 CFR 763.92(a)(1) new custodial and maintenance/trades employees must receive awareness training within 60-days after starting work.

X.	RECORDKEEPING

EHS will maintain records of all known asbestos containing materials. The information shall be updated as new information becomes available through building surveys and project inspections.  The following records will be maintained indefinitely:

•	Location from which asbestos was removed
•	Amount of friable and non-friable asbestos removed
•	Name and address of abatement contractors or name of person on staff that conducted removal
•	Copies of training certifications
•	Information describing the response action procedures
•	Copies of any disposal/shipment paperwork 
•	Exposure monitoring, training, and medical surveillance of campus employees.
•	Asbestos disposal records and manifests for all asbestos projects.
•	Copies of all New Jersey Department of Health and Senior Services (NJDOH), New Jersey Department of Labor & Workforce Development (NJDLWD), New Jersey Department of Community Affairs (DCA), New Jersey Department of Environmental Protection (NJDEP) and Public Employees Occupational Safety and Health (PEOSH) notifications.
•	All additional records as indicated throughout this procedure.

On large scale asbestos projects, Facilities Planning and Construction or EHS will maintain a comprehensive file for all asbestos related projects which includes: location, amounts, and certifications of appropriate personnel, response actions, and project submittals from private asbestos contractors per 40 CFR part 763.

Waste Manifests - All completed asbestos waste manifests must be sent to the EHS Department.

XI.	CONTRACTORS

All contractors will be selected and awarded projects based on the University’s Purchasing Department requirements and the Office of General Counsel contract procedures.

All contractors must provide documentation of proper federal, state and local training and certifications to the Office of EHS.

The following requirements must be followed by all contractors; 

•	Access to the contaminated/regulated area should be secured and signs posted to prevent unauthorized persons from entering the work area. Signs should read:

DANGER - ASBESTOS CANCER AND LUNG DISEASE HAZARD
AUTHORIZED PERSONNEL ONLY RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA

•	Emergency exits must remain in operation.
•	Regulatory Notification is required.
•	All procedures recommended or required by federal, state and local agencies for abatements should be used. These include containment barriers, negative pressure ventilation, personal respiratory protection, protective clothing,
decontamination facilities, HEPA vacuums, wet cleaning and air testing.
•	All debris and materials used should be discarded as asbestos waste. 
•	Following completion of the above actions, conduct appropriate air monitoring to determine if response actions were sufficient.
•	Use visual and air clearance protocols prescribed by federal, state and local regulation prior to re-occupancy.
•	
Appendix A

The Designated Person for the University is the Assistant Vice President of Facilities Management and Plant Operations.

Designated Person: An individual assigned by the University to oversee asbestos-related activities and be the liaison between Facilities Operations and Plant Management and the building occupants.

Appendix B

Asbestos Inspection Report dated May 20, 2014
Cardno ATC Project Number 068/45719.0001

This information is also found on the EHS Asbestos Awareness webpage:

https://stockton.edu/environment-health-safety/documents/asbestos-awareness/asbestos-survey-report-2014.pdf

Appendix C

40 CFR 763.92 Periodic Surveillance Semi-Annual Asbestos O&M Inspection Form 
(Sample of Inspections, Not All Inclusive)
						
Visual Inspections Conducted By:___________________________________________

Visual Assessment Ranking (1 thru 4)

1 = None – materials appear to have complete integrity, no deterioration from physical damage, product deterioration, water damage, etc.

2 = Slight – select areas appear to have minor deterioration from physical damage, product deterioration, water damage, etc.

3 = Moderate – Noticeable damage and deterioration from physical damage, product deterioration, water damage, etc.

4 = Extreme – Visible deterioration, visibly friable, crumbling, flaking from physical damage, product deterioration, water damage, etc.

Note:  Any ranking above the number 1 must be reported to the Office of Risk Management & E/H/S so corrective action can be initiated.

Materials known or assumed to contain asbestos/asbestos containing building materials (ACBM)

Location	Material Description	Quantity
(approximate)	Visual Physical Assessment (1-4)	Date of Inspection	Comments/Notes
	
A Wing – upper level of wing near ceiling deck	Roof Drain Mud Fitting
	35 Fittings
				
B Wing – upper level of wing near ceiling deck	Roof Drain Mud Fitting	35 Fittings				
C Wing – upper level of wing near ceiling deck	Roof Drain Mud Fitting	24 Fittings				
C Wing – CC005 (CM005)	3” Mud Fitting on
Fiberglass Pipe  Insulation	24 Fittings

C Wing – CC005 (CM005)	4” Mud Fitting on
Fiberglass Pipe  Insulation	11 Fittings
				
C Wing – CC005 (CM005)
	6” Mud Fitting on
Fiberglass Pipe  Insulation	25 Fittings
				
C Wing – Tank 470008009U (above ceiling)	6” Mud Fitting on
Fiberglass Pipe  Insulation	100 SF
				
D Wing  – upper level of wing near ceiling deck	Roof Drain Mud Fitting	26 Fittings
				
E Wing – Throughout upper level of wing	Roof Drain Mud Fitting	42 Fittings
				
E Wing – Throughout upper level of wing along interior roofline	Roof Drain Collar	20 collars
				
F003 General Chemistry	Slate Lab Table Tops
	2,000 SF				
F005 Bio Methods	Slate Lab Table Tops
	1,300 SF				
F006 Physiology	Slate Lab Table Tops
	1,300 SF				
F006 Physiology	Slate Beaker Drying Racks
	50 SF				
F007 Ind. Chem	Slate Lab Table Tops
	1,800 SF				
F007 Ind. Chem	Slate Beaker Drying Racks
	40 SF				
F022 Print Shop	Mastic associated with 12” speckled Beige Floor Tile	770 SF				
Hallways Lower F Wings	Mastic associated with 12” speckled Beige Floor Tile	5 SF				
K Wing -  Boiler Room K001
	Mud Fitting on 8” Hot Water Supply Line	26 Fittings
				
K Wing -  Boiler Room K001
	4” Mud Fitting on 3” Boiler Hot Water Pipes	12 Fittings
				
K Wing -  Boiler Room K001 (Boilers 4990 & 4991)	Breeching Collar
	260 SF
				
K Wing – Halls (above ceilings/in wall chases)	3” Mud Fitting on Fiberglass Pipe Insulation 	600 fittings
				
K Wing – Halls (above ceilings/in wall chases)	6” Mud Fitting on fiberglass Pipe Insulation	20 fittings
				
L Wing -  Boiler Room K001
	6” Mud Fitting on fiberglass Pipe Insulation 	18 fittings
				
M Wing -  Dressing Rooms
	Pink Sink Undercoat
	8 SF
				
Stairwells	Fire Doors
	280 SF