The University of Chicago
Safety Manual
Environmental Compliance Programs

Asbestos Policy

Please note that this program has a glossary.   The glossary contains the definitions for various terms used in the program.   These terms are highlighted in bold print the first time they appear in the body of the program.

Policy

No employee of the University of Chicago shall perform any type of asbestos work. All removal or disturbance of asbestos-containing materials (ACM) shall be performed under controlled conditions by asbestos abatement workers appropriately trained and licensed by the Illinois Department of Public Health (IDPH).

Authority and Responsibility

Environmental Health and Safety is responsible for:

1. Determining the presence and location of ACM;
2. Overseeing and managing all work impacting ACM in University facilities (Note: This does not include the University of Chicago Hospitals);
3. Managing all asbestos abatement activities;
4. Procuring the services of licensed asbestos abatement contractors and consultants;
5. Covering costs associated with the abatement for operations and maintenance work (see definition of operations and maintenance below);
6. Conducting training to inform, provide knowledge and basic awareness on asbestos issues; and
7. Managing campus wide asbestos building survey database.

Project Management for Facilities Services, Real Estate Operations and Residence Halls and Commons is responsible for:

1. Notifying Environmental Health and Safety of projects that have the potential to disturb suspect asbestos-containing materials by submitting Appendix A - "Asbestos Request Form" through email so that the scope of the project can be evaluated and testing be performed on suspect asbestos-containing materials;
2. Disclosing the presence of ACM to any outside service contractors;
3. Providing outside service contractors a copy of the University of Chicago’s Asbestos Policy; 
4. Notifying the client and building occupants of abatement activities; 
5. Covering costs associated with abatement for project-related work;
6. Re-insulating abated materials; and
7. Covering costs associated with the abatement and any reinstallation of materials.

Supervisors are responsible for:

1. Notifying Environmental Health and Safety by submitting Appendix A - "Asbestos Request Form" through email when work activities may disturb suspect asbestos-containing materials;
2. Notifying Environmental Health and Safety in the case of an emergency where there is the potential for fiber release from damaged ACM;
3. Notifying Environmental Health and Safety to schedule asbestos abatement;
4. Procuring the services of a re-insulation company;
5. Covering costs associated with any reinstallation of materials; and
6. Providing outside service contractors with a copy of the University of Chicago’s Asbestos Policy

Outside Service Contractors are responsible for:

1. Providing general awareness training for their employees so that employees are able to identify suspect asbestos-containing materials if found during work activities;
2. Notifying Environmental Health and Safety and the Project Manager of suspect asbestos-containing materials which may be disturbed during work activities; and
3. Notifying Environmental Health and Safety and the Project Manager of suspect asbestos-containing materials that are discovered during work activities.

Asbestos Disturbing Activities

• Removing or repairing floor tile;
• Drilling into floor tile;
• Removing or repairing ceiling tiles;
• Removing pipe insulation or pipe joint compound to access pipes;
• Knocking holes in plaster ceilings or walls; and/or
• Removing carpet which has floor tile underneath it.

All University of Chicago campus buildings have been surveyed for the presence and location of asbestos-containing materials.  Environmental Health and Safety currently maintains a database with locations of asbestos containing materials.  All off-site University of Chicago facilities have presumed asbestos containing materials (PACM).  Contact Environmental Health and Safety to determine if a material contains asbestos.  

Abatement Projects

All asbestos abatement projects within the University of Chicago shall be performed under controlled conditions by an asbestos abatement contractor utilizing asbestos abatement workers who are trained and licensed by the IDPH.

Environmental Health and Safety shall procure the services of a licensed abatement contractor and monitor the progress of the abatement activities.

Notifications

Projects greater than three liner feet or three square feet of asbestos-containing material to be removed require a two working day notification submitted to the Illinois Environmental Protection Agency (IEPA) before work begins.  For projects over 260 linear feet or 160 square feet of asbestos-containing materials to be removed, a ten day notice is required.

All asbestos abatement work which requires notification to federal and state officials shall be completed by the asbestos abatement contractor and submitted to Environmental Health and Safety prior to the commencement of the abatement project.

Renovation and Construction

During the design phase of all renovation or construction activities, Project Managers shall submit a copy of Appendix A - "Asbestos Request Form" to Environmental Health and Safety.  Environmental Health and Safety shall evaluate materials which will be disturbed during the renovation to identify all suspect asbestos-containing materials involved.

Carpet Removal With Asbestos Floor Tile Underneath

Operations and maintenance or renovations involving the removal of glued down carpet with asbestos floor tile under it shall be done by an asbestos abatement contractor.  Prior to the beginning of the project, Environmental Health and Safety shall be notified to identify the presence or absence of floor tile under the carpet.

NOTE:  Painting asbestos floor tile is prohibited.

If it is determined that asbestos removal is required for the project to proceed, Environmental Health and Safety shall make arrangements for the following:

• Procuring the services of a licensed asbestos abatement contractor;
• Procuring the services of a consultant to monitor and conduct any necessary design, construction, administration and monitoring as deemed necessary or as required by law; and
• Notifying building engineers and electricians for water and electrical hook-up for the project.

Project Managers shall be responsible for notifying building occupants of upcoming abatement activities using the notification provided by Environmental Health and Safety.

Operations and Maintenance

Operations and Maintenance work is defined as damaged thermal insulation systems less than 100 linear feet, and loose, cracked, or damaged floor tile less than 50 square feet.  Anything greater than these quantities is considered project work.

Environmental Health and Safety shall be notified by submitting Appendix A - "Asbestos Request Form" through email when any activities performed by University of Chicago employees that will result in the disturbance of suspect asbestos-containing materials.

University of Chicago employees shall not remove or disturb any suspect asbestos-containing materials until the materials have been sampled by Environmental Health and Safety and it has been determined that they do not contain asbestos.  All sampling shall only be conducted by licensed asbestos building inspectors on staff through Environmental Health and Safety.

NOTE:  With the exception of designated Environmental Health and Safety employees, no University of Chicago employee shall collect samples of suspect asbestos-containing materials.

Asbestos Emergencies

All emergency asbestos work shall be conducted by a licensed asbestos abatement contractor.  Emergencies include situations where a rapid response is necessary to mitigate damage or prevent further serious damage to the building or its occupants in which ACM or suspect ACM has become damaged and has the potential to become airborne. 

In a case of an emergency, immediately contact Environmental Health and Safety at 702-9999. After hours, contact the University of Chicago Police at 123 or 702-8181.

Outside contractors shall notify their University contact.

Training

All employees (e.g., Operations and Maintenance, Project Management, Planning Group, Building Managers, Custodial Staff) shall receive training consistent with the Occupational Safety and Health Administration (OSHA) Class IV asbestos worker training requirements.  This training shall utilize the “Asbestos Awareness” training booklet generated by Environmental Health and Safety.  This training booklet shall be revised to include provisions of the revised standard, as revisions to the standard are published.

Employees shall be trained in the following by representatives from Environmental Health and Safety:

1. Asbestos standard (29 CFR 1910.1001);
2. Asbestos abatement projects;
3. Background information on asbestos;
4. Health effects related to asbestos exposure;
5. Preventing exposure to asbestos;
6. Methods for controlling asbestos fiber release; and
7. Asbestos abatement basics. 

All asbestos abatement contractors shall be responsible for meeting these OSHA training requirements in addition to all IDPH training requirements.

Outside Service Contractor Information

All outside service contractors shall be notified of the presence of asbestos-containing materials prior to beginning work activities.  All outside service contractors shall provide general awareness training for their employees to allow employees to identify suspect asbestos-containing materials if found during work activities.  Contractors shall contact Environmental Health and Safety in the event that suspect asbestos-containing materials are discovered during work activities.  Contractors shall be made aware of the University of Chicago’s Asbestos Policy prior to the commencement of work.

Regulations

All asbestos abatement projects performed at the University of Chicago shall be in accordance with the following regulations: OSHA - 29 CFR 1910.1001; IDPH; and EPA - 40 CFR Part 61.

Section 6 Index

 Table of Contents

Environmental Health and Safety
Issued: 01/01/00
Revised:  02/27/09