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 trained via the EPA Model Accreditation Plan and licensed by the Illinois Department of Public Health (IDPH).
Authority and Responsibility
Environmental Health and Safety is responsible for:
- Determining the presence and location of ACM;
- Overseeing and managing all work impacting ACM in University facilities (Note: This does not include the University of Chicago Medicine);
- Managing all asbestos abatement activities;
- Procuring the services of licensed asbestos abatement contractors and consultants;
- Covering costs associated with the abatement for operations and maintenance work (see definition of operations and maintenance below);
- Conducting basic asbestos awareness training; and
- Managing the campus-wide asbestos building survey data.
Facilities Services-Operations, Facilities Services Capital Project Delivery, Physical Plant, and BSD-Project Managers are responsible for:
- Notifying Environmental Health and Safety by submitting an Asbestos Request Form if they discover damaged materials or will perform work activities which may disturb suspect asbestos-containing materials;
- Using the abatement contractors and consultants who are approved by Environmental Health and Safety;
- Disclosing the presence of ACM to any outside service contractors;
- Providing outside service contractors a copy of the University of Chicago’s Asbestos Policy;
- Notifying the client and building occupants of abatement activities;
- Covering costs associated with project-related abatement work;
- Re-insulating and/or installing replacement materials;and
- Requesting a certification from the architect of record which states "no asbestos finishes were specified during construction" for new finishes or new buildings and submitting this certification to Environmental Health and Safety.
Supervisors, Facility Managers, or any person coordinating a renovation is responsible for:
- Notifying Environmental Health and Safety by submitting an Asbestos Request Form if they discover damaged materials or will perform work activities which may disturb suspect asbestos-containing materials;
- Notifying Environmental Health and Safety in the case of an emergency where there is the potential for fiber release from damaged ACM;
- Using the abatement contractors and consultants who are approved by Environmental Health and Safety;
- Notifying Environmental Health and Safety to schedule asbestos abatement;
- Procuring the services of a re-insulation company;
- Covering costs associated with any re-installation of materials; and
- Providing outside service contractors with a copy of the University of Chicago’s Asbestos Policy
Outside service contractors are responsible for:
- Providing general awareness training to their employees so employees can identify suspect asbestos-containing materials if found during work activities;
- Notifying Environmental Health and Safety and the Project Manager of suspect asbestos-containing materials which may be disturbed during work activities; and
- Notifying Environmental Health and Safety and the Project Manager of damaged suspect asbestos-containing materials
Activities that may Disturb Asbestos
Examples of activities that may result in the disturbance of suspect asbestos-containing materials include:
- 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.
Most of the University of Chicago campus buildings have been surveyed for the presence and location of asbestos-containing materials. Environmental Health and Safety currently maintain a database with locations of asbestos-containing materials. Select residential and commercial properties have limited inspection reports. All off-site University of Chicago facilities have constructed before 1980 have presumed asbestos-containing materials (PACM). Before any renovation, 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/supervisors who have completed EPA training and are licensed by the IDPH.
Environmental Health and Safety shall assist with the procurement of a licensed abatement contractor to complete abatement work. The University's consultant will monitor the progress of the abatement activities.
Unless the project specifications and/or architect's certification stating asbestos materials were not utilized during the construction of a building, then it is generally good practice to assume any building finish installed before 1990 may contain asbestos.
Notifications
A notification is not automatically submitted when a PM submits an Asbestos Request Form. The contractor selected as the winning bidder is legally responsible for submitting the permit. To submit an asbestos permit application, the following information needs to be present.
- Specific scope: Type of asbestos, quantity (e.g. square footage, linear feet, etc.) within 10% accuracy, and location of asbestos;
- Exact start date and end date;
- Exact shift time;
- Abatement contractor's IDPH Company License number; and
- IDPH License number of the Asbestos Building Inspector (Consultant or Environmental Health and Safety Officer).
Submitting an open-ended permit without a specific scope of work is prohibited per the CDPH and IEPA.
All projects that will disturb any amount of asbestos in any building require a 10-working day notification to the Chicago Department of Public Health before work can begin.
In addition, projects where removal of asbestos-containing materials is greater than 3 linear feet/square feet and up to 260 linear feet also require a two (2) working day notification to be submitted to the IDPH. Projects, where removal is greater than 260 linear feet or 160 square feet, require a 10-working day notification to the Illinois Environmental Protection Agency.
If the project will take place in a school building (kindergarten - 12th grade) then any project requiring the abatement of asbestos greater than 3 linear feet/3 square feet requires the following notification before work can begin:
- 10-working day notification submitted to the CDPH;
- 10-working day notification submitted to the IEPA; and
- 10-working day notification submitted to the IDPH.
All asbestos abatement work that requires notification to federal, state, and local officials shall be completed by the asbestos abatement contractor and submitted to Environmental Health and Safety before 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 the Asbestos Request Form to Environmental Health and Safety. Environmental Health and Safety shall evaluate materials that will be disturbed during the renovation to identify all suspect asbestos-containing materials involved.
Convey the entire renovation scope to ensure a licensed asbestos inspector can properly determine the abatement scope. If feasible, then furnish the demolition drawings to properly convey surfaces that will be impacted by the renovation (e.g., walls, floors, ceilings, ductwork, pipes, air handlers, chillers, fume hoods, roofs, facades, windows)
If it is determined that asbestos removal is required for the project to proceed, then Environmental Health and Safety shall arrange for the following:
- Procuring the services of a state-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.
If asbestos material is intact and won't be disturbed by project activities, it does not have to be removed. There is no regulation stating that asbestos must be removed if discovered.
Project Managers shall be responsible for notifying building occupants of upcoming abatement activities and may use the notification template provided by Environmental Health and Safety.
Project managers are responsible for covering all asbestos survey and abatement costs which are associated with their projects.
Only the vendors who are currently under contract or have been approved by Environmental Health and Safety may perform asbestos abatement for the University. This ensures all pre-project notifications and post-project close-out documents are centrally stored in the EHS office in compliance with Federal and State recordkeeping regulations.
Immediately notify your supervisor and Environmental Health and Safety if you discover damaged suspect material or witness any contractor disturbing suspect materials. Isolate the area if the material is damaged and debris is present.
Operations and Maintenance
Operations and Maintenance work is defined by Environmental Health and Safety 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 the Asbestos Request Form when any activities will disturb 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.
A separate O&M permit has been submitted to CDPH and IEPA for the South Steam Plant and the Steam Tunnels and a waiting period of two (2) working days is required before abatement related to maintenance of buildings can commence. A single O&M event cannot exceed 260 linear feet or 160 square feet.
Note: Exception for designated Environmental Health and Safety employees that hold current IDPH asbestos inspector licenses, no University of Chicago employee shall collect samples of suspect asbestos-containing materials. Do not collect samples and bring them to your supervisor or deliver them to Environmental Health and Safety.
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. The two (2) day or ten (10) day notification can be submitted the next workday in the event of a confirmed emergency. Justification/documentation (including pictures) of the emergency must be submitted to the necessary regulatory agency.
Immediately contact Environmental Health and Safety at 773.702.9999 if an emergency occurs. After hours, contact the University of Chicago Police Department at 123 or 773.702.8181 and the on-call Safety Officer will be paged.
Outside contractors shall notify their University contact who should contact Environmental Health and Safety.
Training
All employees (e.g., Facilities Operations, Facilities Services Project Managers, 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:
- Asbestos standard (29 CFR 1910.1001);
- Asbestos abatement projects;
- Background information on asbestos;
- Health effects related to asbestos exposure;
- Preventing exposure to asbestos;
- Methods for controlling asbestos fiber release; and
- Asbestos abatement basics.
If a University of Chicago employee will conduct activities described as custodial or housekeeping, they must attend asbestos awareness training on an annual basis. If the custodian and/or housekeeping staff is an external vendor operating under a contract agreement, the employer is responsible for compliance with the annual training requirement.
If a University of Chicago employee will conduct maintenance work (e.g., custodial, HVAC engineers, electricians, plumbers, etc.) in the K-12 Laboratory Schools (Judd, Belfield, Blaine, U-High, or Sunny Gymnasium) then they must complete a two-hour Asbestos Awareness class within 60 days of their employment. (per EPA 40 CFR 763.92)
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 confirmed and suspected asbestos-containing materials before 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 if suspect asbestos-containing materials are discovered during work activities. Contractors shall be made aware of the University of Chicago’s Asbestos Policy before the commencement of work.
Guidance Documents
Reviewed: November 2023