ASBESTOS AND LEAD

1. ASBESTOS AND LEAD Cover Slide - No required Elements Note the Postal Service has relied on World-Class Expertise to develop the compliance programCover Slide - No required Elements Note the Postal Service has relied on World-Class Expertise to develop the compliance program

2. PM Asbestos ResponsibilitiesSummary Employee Awareness Labeling Custodial Operations & Maintenance Annual Re-inspections Contractor EH&S Documentation

3. Employee Awareness Hazard Communication Training Required Annually Video – “Asbestos and US Postal Worker” and Service Talk PEDC - Toolkit Show and Tell – Office Walk Around

4. Labeling The BIG A On or adjacent to ACBM Explanation Posting Other Labeling Systems in Place

5. Asbestos Signage Labeling Use of the “A” label & sign

6. Custodial Operations and Maintenance Class IV Asbestos Awareness and Work Practices Training Postmasters and Custodians Contract Custodians (per USPS policy) Class III Training 16 hour Initial 4 hour annual refresher Competent Person 4 hr annual Typically field and plant maintenance staff Annual Refreshers

7. Annual Re-inspections Review condition Submitted to ECS Repairs Initial point of contact = Windsor FSO Performed by Field Maintenance or FSO Keep copies of Re-inspection forms with your Asbestos Operations and Management Plan

8. Contractor EH&S Review ALL contract work Custodial and Trades PS Form 8210 – “Asbestos Work Authorization” is required for all contracts irregardless of whether asbestos is impacted Refer to your Asbestos Operations Management Plan and the NEA Environmental Health & Safety Guidebook for Contractors for more details Blanket Work Authorizations have been issued by the NEA to cover in-house Class IV and III work practices conducted by trained postal staff

9.  For Additional Assistance Contact: Angelo Dispensa, Env. Specialist (Connecticut PC) 203 574-6590 Robert Fox, Env. Specialist (Maine PC and NH) 603 427-6368 Jim Hennessey, Env. Specialist (Albany and WNY PCs) 603 427-6368 Ron Robbins, Env. Specialist (Vermont and MA PC 010-013) 860 285-7197 or 413 731-0235 Julie Theroux, Env. Specialist (SENE PC) 603 427-6368 Nick Varoutsos, Env. Specialist (MA PC 014-019 and Boston PC) 617 654-5488 Repairs and Alterations – Facilities Response Line (866) 298-8910

10. AGENDA I. Introduction II. Asbestos Asbestos Training Basics - Asbestos and the US. Postal Worker Video Health Effects Locations and Conditions Regulations Work Practices Work Authorization Form Summary The agenda confirms that the training was developed to satisfy OSHA Worker Right to Know requirements, OSHA Class IV asbestos work requirements, and the requirements established by the Management Instruction (MI).The agenda confirms that the training was developed to satisfy OSHA Worker Right to Know requirements, OSHA Class IV asbestos work requirements, and the requirements established by the Management Instruction (MI).

11. INTRODUCTION Pro-Active Program Facility Inspection Operations & Maintenance Training This is the final element in this 4-part process. Program Development centered around an Area-chartered inter-district task force of over 30 stakeholders. The outcome was a comprehensive management program tailored for the USPS NEA. Facility Inspections are being conducted area-wide by Volpe-ETC, a consulting consortium. Operations & Maintenance Procedures have been developed by Roy F. Weston, Inc. specifically for the NEA, and coordinated with MTSC, EMP, Safety & Health, and other USPS stakeholders in toxic building material management. Training, as established by OSHA, EPA, the MI and the MMOs is the topic of this presentation.This is the final element in this 4-part process. Program Development centered around an Area-chartered inter-district task force of over 30 stakeholders. The outcome was a comprehensive management program tailored for the USPS NEA. Facility Inspections are being conducted area-wide by Volpe-ETC, a consulting consortium. Operations & Maintenance Procedures have been developed by Roy F. Weston, Inc. specifically for the NEA, and coordinated with MTSC, EMP, Safety & Health, and other USPS stakeholders in toxic building material management. Training, as established by OSHA, EPA, the MI and the MMOs is the topic of this presentation.

12. ASBESTOS TRAININGPurpose USPS policy is to provide a safe work environment Protect health and safety of workers and public Occupational Safety & Health Administration (OSHA) requirement for Class IV maintenance workers No commentary is necessary.No commentary is necessary.

13. Asbestos and the U.S. Postal Worker Video BASICS Copies of the video can be obtained from your District Asbestos Program Coordinator. The video presents an overview of the USPS policy on asbestos and asbestos work practices in the Postal Service.Copies of the video can be obtained from your District Asbestos Program Coordinator. The video presents an overview of the USPS policy on asbestos and asbestos work practices in the Postal Service.

14. HEALTH EFFECTS Breathing Swallowing Caveat the discussion with the statement that the health effects training is required by OSHA, but is truly applicable only for dosages of asbestos in excess of the permissible exposure limit (PEL). Stress that asbestos exposure levels in the USPS (while conducting routine maintenance activities or OSHA Class IV asbestos work) are extremely low. Conducting the USPS approved Class IV asbestos work practices will result in no asbestos exposure. For the industrial hygienists in the audience, inhalation and ingestion are the technical terms for breathing and swallowing. Are we talking about snacking on the pipe insulation? … No this is ingestion of asbestos fibers on other things we put in our mouth like cigarettes, unwashed hands, or grilled cheese sandwiches toasted over an open boiler port. Caveat the discussion with the statement that the health effects training is required by OSHA, but is truly applicable only for dosages of asbestos in excess of the permissible exposure limit (PEL). Stress that asbestos exposure levels in the USPS (while conducting routine maintenance activities or OSHA Class IV asbestos work) are extremely low. Conducting the USPS approved Class IV asbestos work practices will result in no asbestos exposure. For the industrial hygienists in the audience, inhalation and ingestion are the technical terms for breathing and swallowing. Are we talking about snacking on the pipe insulation? … No this is ingestion of asbestos fibers on other things we put in our mouth like cigarettes, unwashed hands, or grilled cheese sandwiches toasted over an open boiler port.

15. HEALTH EFFECTS Occupational Environmental Interpersonal All types of asbestos disease involve exposure to asbestos dust by inhalation or ingestion. Merely being in a room with asbestos does not necessarily cause exposure. Exposure only occurs when asbestos is disturbed or when the dust is released by an activity that impacts asbestos. Sources of exposure include: Occupational-insulation worker Environmental -living in a region with active asbestos processing facilities Interpersonal - the wife and kids of the insulation worker. ALL SOURCES have documentation of asbestos related illness.All types of asbestos disease involve exposure to asbestos dust by inhalation or ingestion. Merely being in a room with asbestos does not necessarily cause exposure. Exposure only occurs when asbestos is disturbed or when the dust is released by an activity that impacts asbestos. Sources of exposure include: Occupational-insulation worker Environmental -living in a region with active asbestos processing facilities Interpersonal - the wife and kids of the insulation worker. ALL SOURCES have documentation of asbestos related illness.

16. HEALTH EFFECTS Concentration Duration Genetic Pre-disposition The likelihood of asbestos disease is related to the magnitude of the exposure and/or concentration over time. There is no known safe level of asbestos exposure. However, there is a strong relationship between increased levels of exposures and the occurrence of asbestosis (one asbestos disease). While lung cancer and mesothelioma are diseases associated with asbestos exposure, there is no direct dose response relationship between the level of asbestos exposure and these diseases. Therefore, the only safe level of exposure is no exposure. Genetic pre-disposition is one of the phenomena that explains why some individuals manifest disease at much lower asbestos concentrations or after much shorter exposure durations.The likelihood of asbestos disease is related to the magnitude of the exposure and/or concentration over time. There is no known safe level of asbestos exposure. However, there is a strong relationship between increased levels of exposures and the occurrence of asbestosis (one asbestos disease). While lung cancer and mesothelioma are diseases associated with asbestos exposure, there is no direct dose response relationship between the level of asbestos exposure and these diseases. Therefore, the only safe level of exposure is no exposure. Genetic pre-disposition is one of the phenomena that explains why some individuals manifest disease at much lower asbestos concentrations or after much shorter exposure durations.

17. HEALTH EFFECTS Mesothelioma Asbestosis Lung Cancer Other Mesothelioma (Ma’ zo thee lee oma) is cancer of the lung lining. It is always caused by asbestos exposure. The only known cause of Mesothelioma is asbestos exposure. Asbestos is the scaring of the lung tissue, reducing the oxygen exchange efficiency of the lung tissue. Lung cancer can be caused by asbestos, a know carcinogen. Lung cancer can also be caused by many other agents. Studies have documented that there is a much higher risk of asbestos disease in people that smoke. Studies show that asbestos workers who smoke have a 50 fold increase in the risk of asbestos disease than those that do not smoke. Smoking paralyzes the cilia (or hair like structures) which help remove dust (including asbestos) from the lungs. The link between asbestos disease and smoking is so important that a slide about smoking cessation programs is presented next. Mesothelioma (Ma’ zo thee lee oma) is cancer of the lung lining. It is always caused by asbestos exposure. The only known cause of Mesothelioma is asbestos exposure. Asbestos is the scaring of the lung tissue, reducing the oxygen exchange efficiency of the lung tissue. Lung cancer can be caused by asbestos, a know carcinogen. Lung cancer can also be caused by many other agents. Studies have documented that there is a much higher risk of asbestos disease in people that smoke. Studies show that asbestos workers who smoke have a 50 fold increase in the risk of asbestos disease than those that do not smoke. Smoking paralyzes the cilia (or hair like structures) which help remove dust (including asbestos) from the lungs. The link between asbestos disease and smoking is so important that a slide about smoking cessation programs is presented next.

18. HEALTH EFFECTS The National Cancer Institute’s Cancer Information Service, 9000 Rockville Pike, Bethesda Maryland 20892, (800) 422-6237. www.cancer.gov Cancer Information Service Fact Sheet The American Cancer Society, 3340 Peachtree Road, NE, Atlanta, Georgia 30062, (404) 320-3333. http://www.cancer.org/docroot/home/index.asp American Heart Association, 7320 Greenville Avenue, Dallas, Texas 75231, (469) 865-1190. http://www.americanheart.org/ American Lung Association, 1740 Broadway, New York, New York 10019, (212) 315-8700. http://www.lungusa.org Office on Smoking and Health, US. Department of Health and Human Services, 5600 Fishers Lane, Park Building, Room 110, Rockville, Maryland 20857, http://www.surgeongeneral.gov/tobacco/ Smoking cessation programs are also offered by the Red Cross and other community groups. The district medical officer or occupational nurse can also provide assistance with workers desiring to quit smoking.Smoking cessation programs are also offered by the Red Cross and other community groups. The district medical officer or occupational nurse can also provide assistance with workers desiring to quit smoking.

19. HEALTH EFFECTS X-Rays Pulmonary Function Test Medical Questionnaire Medical Surveillance is required if a worker is exposed above the PEL in an occupational exposure. Q: Are any Postal Service employees enrolled in a medical surveillance program for exposure to asbestos? A: No. No USPS duty assignments result in exposures which require enrollment in a medical surveillance program.Medical Surveillance is required if a worker is exposed above the PEL in an occupational exposure. Q: Are any Postal Service employees enrolled in a medical surveillance program for exposure to asbestos? A: No. No USPS duty assignments result in exposures which require enrollment in a medical surveillance program.

20. LOCATIONS AND CONDITIONS Asbestos containing material (ACM) > 1% Asbestos TSI = thermal system insulation Surfacing (ACM) = sprayed or troweled on ACM Presumed Asbestos Containing Material (PACM) = TSI or Surfacing materials applied or installed before 1980. For us, this slide means that if you are looking at the survey report, and it says the drywall-joint compound contains trace levels of asbestos, but the drawing does not show the material, it is not an error. The material is just not “asbestos containing material (ACM)” as defined in the regulations. This means that the drywall joint compound contains less than 1 percent asbestos. Q: If a material (such as floor tile or pipe insulation) has not been tested in a building built before 1980 and it doesn’t look like asbestos, is it safe to assume that it is not asbestos? A: No. If you are not sure if the material contains asbestos, you must assume that it contains asbestos. The material is considered PACM (see above).For us, this slide means that if you are looking at the survey report, and it says the drywall-joint compound contains trace levels of asbestos, but the drawing does not show the material, it is not an error. The material is just not “asbestos containing material (ACM)” as defined in the regulations. This means that the drywall joint compound contains less than 1 percent asbestos. Q: If a material (such as floor tile or pipe insulation) has not been tested in a building built before 1980 and it doesn’t look like asbestos, is it safe to assume that it is not asbestos? A: No. If you are not sure if the material contains asbestos, you must assume that it contains asbestos. The material is considered PACM (see above).

21. LOCATIONS AND CONDITIONS By prioritizing the risk, the Postal Service can more effectively deal with the asbestos in our buildings. Non-friable asbestos (such as in some of our roofs and floor systems) poses little risk if properly maintained and managed. Our first focus is on dealing with damaged and spray-applied friable materials that have the highest potential for deteriorating. Friable (Fry’ eble) asbestos is material that can be easily crushed or reduced to a powder by hand pressure. Damaged asbestos materials that either have significant localized damage, or are damaged over a significantly large area may not be feasible to repair. If the damage is too extensive to effectively repair, asbestos abatement will be conducted. Examples of damaged asbestos include water damage from roof leaks, gouges, cuts and tears from physical intrusion, and the delamination of a material from substrate, often due to vibration or air erosion. By prioritizing the risk, the Postal Service can more effectively deal with the asbestos in our buildings. Non-friable asbestos (such as in some of our roofs and floor systems) poses little risk if properly maintained and managed. Our first focus is on dealing with damaged and spray-applied friable materials that have the highest potential for deteriorating. Friable (Fry’ eble) asbestos is material that can be easily crushed or reduced to a powder by hand pressure. Damaged asbestos materials that either have significant localized damage, or are damaged over a significantly large area may not be feasible to repair. If the damage is too extensive to effectively repair, asbestos abatement will be conducted. Examples of damaged asbestos include water damage from roof leaks, gouges, cuts and tears from physical intrusion, and the delamination of a material from substrate, often due to vibration or air erosion.

22. LOCATIONS AND CONDITIONS ACM/PACM Inspection Report Operations and Maintenance (O&M) Plan Turn to the site-specific survey documents for each facility. Table 2 of the inspection report should be reviewed at this point. For small groups (tabletop training) turn to the actual report. ACM identified in your facility has been labeled, and signs have been placed at the entrances to mechanical rooms containing ACM. The survey report will be periodically updated to keep the survey current with ACM that has been removed, and to assess the condition of the remaining ACM in your facility.Turn to the site-specific survey documents for each facility. Table 2 of the inspection report should be reviewed at this point. For small groups (tabletop training) turn to the actual report. ACM identified in your facility has been labeled, and signs have been placed at the entrances to mechanical rooms containing ACM. The survey report will be periodically updated to keep the survey current with ACM that has been removed, and to assess the condition of the remaining ACM in your facility.

23. LOCATIONS AND CONDITIONS PACM (TSI and Sprayed-on) Asphalt and vinyl flooring Brakes and clutches Exterior Building Components Brakes and Clutches in the LLVs are not asbestos. PACM is assumed to be asbestos only in buildings built before 1980. If you are in a building built before 1980, assume the fiberglass pipe insulation is asbestos. Similarly, since exterior building materials were not included in the surveys, all exterior building materials are considered PACM. Prior to a repair and alteration (R&A) project, an asbestos survey must be conducted on exterior materials that will be affected.Brakes and Clutches in the LLVs are not asbestos. PACM is assumed to be asbestos only in buildings built before 1980. If you are in a building built before 1980, assume the fiberglass pipe insulation is asbestos. Similarly, since exterior building materials were not included in the surveys, all exterior building materials are considered PACM. Prior to a repair and alteration (R&A) project, an asbestos survey must be conducted on exterior materials that will be affected.

24. LOCATIONS AND CONDITIONS Damage Flaking or crumbling Delaminating Water stains Gouging or scraping Debris Potential for Damage Accessibility Area activity Vibration Air erosion History of damage Exposed ACM Potential for new accessibility This information follows from the EPA guidance for asbestos hazard control, “the Purple Book” EPA 560/82-020a. Your students need to understand these terms when they notice a change in the material that needs to be addressed. Point out that they are not going to be “certified asbestos inspectors” from this awareness training. Q: If we notice a significant change in the condition of ACM, what should we do? A: Contact the Facility Asbestos Coordinator (FAC) or Facility Manager.This information follows from the EPA guidance for asbestos hazard control, “the Purple Book” EPA 560/82-020a. Your students need to understand these terms when they notice a change in the material that needs to be addressed. Point out that they are not going to be “certified asbestos inspectors” from this awareness training. Q: If we notice a significant change in the condition of ACM, what should we do? A: Contact the Facility Asbestos Coordinator (FAC) or Facility Manager.

25. LOCATIONS AND CONDITIONS Prevent Damage Avoid Disturbance Monitor Safe Procedures Since the EPA and the rest of the experts agree that the BEST way to reduce the total exposure from asbestos in good condition is through an effective management program, we have developed state-of-the-art procedures for dealing with this material. One of the cornerstones of this management program is the development and use of effective work practices to maintain ACM using an Operations and Maintenance (O&M) Plan. This process will be explained in the next few slides.Since the EPA and the rest of the experts agree that the BEST way to reduce the total exposure from asbestos in good condition is through an effective management program, we have developed state-of-the-art procedures for dealing with this material. One of the cornerstones of this management program is the development and use of effective work practices to maintain ACM using an Operations and Maintenance (O&M) Plan. This process will be explained in the next few slides.

26. LOCATIONS AND CONDITIONS Repair Encapsulation Enclosure Removal If the Facility Manager hands out white suits and says “You have completed the training, lets remove this asbestos”. Your reply should be that removal requires a contractor, 38 more hours of training, and specialty equipment. The Postal Service MI prohibits USPS employees from removing asbestos.If the Facility Manager hands out white suits and says “You have completed the training, lets remove this asbestos”. Your reply should be that removal requires a contractor, 38 more hours of training, and specialty equipment. The Postal Service MI prohibits USPS employees from removing asbestos.

27. REGULATIONS Classification Class I Class II Class III Class IV Activities Removal of high-risk ACM & PACM (TSI or surfacing) Removal of ACM & ACBM which is not high risk Maintenance & repair operations where ACM, including TSI and surfacing ACM, or PACM are likely to be disturbed Maintenance & custodial activities during which employees may contact but not disturb ACM or PACM Go through each of the classes to differentiate the levels of training. The asterisk on Class III is because we currently have one approved Class III activity, namely drilling holes with the dustless drilling system developed by Nilfisk and WESTON. We expect additional Class III work practices will be added in the future for some maintenance-capable facilities. Only O&M work that is not intended to disturb asbestos is allowed by Class IV training. Q: What about contract cleaners? A: Contract cleaners are required to have Class IV training and may attend a USPS sponsored training session. As an alternative, contract cleaners may provide evidence that they have reviewed the training materials and USPS survey reports and have become familiar with USPS asbestos policy. This evidence must be provided for each facility a contract cleaner works at. The USPS will not reimburse contract cleaners for attending outside training seminars. However, contract cleaners can receive their training at Postal Service expense if the training is received at a USPS sponsored training event within their regular contract work hours.Go through each of the classes to differentiate the levels of training. The asterisk on Class III is because we currently have one approved Class III activity, namely drilling holes with the dustless drilling system developed by Nilfisk and WESTON. We expect additional Class III work practices will be added in the future for some maintenance-capable facilities. Only O&M work that is not intended to disturb asbestos is allowed by Class IV training. Q: What about contract cleaners? A: Contract cleaners are required to have Class IV training and may attend a USPS sponsored training session. As an alternative, contract cleaners may provide evidence that they have reviewed the training materials and USPS survey reports and have become familiar with USPS asbestos policy. This evidence must be provided for each facility a contract cleaner works at. The USPS will not reimburse contract cleaners for attending outside training seminars. However, contract cleaners can receive their training at Postal Service expense if the training is received at a USPS sponsored training event within their regular contract work hours.

28. REGULATIONS Awareness training Notification Prohibited activities This is why we have the training, to raise awareness, to reinforce the notification of where the material is located, and to establish work procedures for asbestos materials. Q: What about exterior building materials? A: Exterior building materials are not included in the survey reports. Exterior building materials should be treated as PACM.This is why we have the training, to raise awareness, to reinforce the notification of where the material is located, and to establish work procedures for asbestos materials. Q: What about exterior building materials? A: Exterior building materials are not included in the survey reports. Exterior building materials should be treated as PACM.

29. REGULATIONS Written notification or personal communication to affected employees Sign at entrances to affected mechanical areas Label near installed ACM or PACM The USPS notification program is well developed. This training is part of the notification program.The USPS notification program is well developed. This training is part of the notification program.

30. Work Practices Show Class IV Video

31. WORK PRACTICES Suspect ACM = PACM “Asbestos until proven innocent.” Only proof is survey report If no survey assume positive Sampling only by certified asbestos professionals The only way to identify asbestos is to analyze it with a mineralogical microscope (polarizing light microscope) or an electron microscope. Beyond a couple of important examples, such as transite panels, even trained and experienced asbestos professionals cannot visually identify asbestos without the aid of a microscope. Collection of samples is regulated by EPA and all of the states in the NEA. One must possess a current license to collect asbestos samples.The only way to identify asbestos is to analyze it with a mineralogical microscope (polarizing light microscope) or an electron microscope. Beyond a couple of important examples, such as transite panels, even trained and experienced asbestos professionals cannot visually identify asbestos without the aid of a microscope. Collection of samples is regulated by EPA and all of the states in the NEA. One must possess a current license to collect asbestos samples.

32. WORK PRACTICES Do not use compressed air to clean surfaces Dust or debris in area with TSI, surfacing, or deteriorated ACM or PACM shall be treated as ACM (Contact Facility Asbestos Coordinator) All of the work practices were designed to allow you to safely conduct typical maintenance activities without disturbing asbestos. All of the work practices share the common goal of minimizing dust generation while working around asbestos. Work practice ASB06 addresses cleaning procedures in rooms with friable ACM. Q: What should I do if I need to conduct a maintenance activity that is not covered by the work practices? A: Do not modify any work practice to fit your needs. Contact the FAC or Facility Manager if you need to conduct a work activity which is not listed as an approved Class IV work practice.All of the work practices were designed to allow you to safely conduct typical maintenance activities without disturbing asbestos. All of the work practices share the common goal of minimizing dust generation while working around asbestos. Work practice ASB06 addresses cleaning procedures in rooms with friable ACM. Q: What should I do if I need to conduct a maintenance activity that is not covered by the work practices? A: Do not modify any work practice to fit your needs. Contact the FAC or Facility Manager if you need to conduct a work activity which is not listed as an approved Class IV work practice.

33. WORK PRACTICES Sanding is prohibited Strip finishes with low abrasion pads at speed slower than 300 rpm and using wet methods Only burnish or dry-buff floors with sufficient finish to prevent contact with ACM This is the most important aspect of the program. The USPS is responsible for over 150 million square feet of asbestos floors. We own over 95% of the plank floor produced in the world. The manufacturer of the plank floor up to 1989 was the Johns-Manville Corporation, a former Fortune 100 company bankrupted due to asbestos litigation. “All” plank floor installed before 1988 contains asbestos.This is the most important aspect of the program. The USPS is responsible for over 150 million square feet of asbestos floors. We own over 95% of the plank floor produced in the world. The manufacturer of the plank floor up to 1989 was the Johns-Manville Corporation, a former Fortune 100 company bankrupted due to asbestos litigation. “All” plank floor installed before 1988 contains asbestos.

34. WORK PRACTICES ASB01 Installing new floor covering over ACM flooring ASB02 Remove carpet over ACM flooring ASB03 Clean potentially ACM contaminated carpeting ASB04 Remove non-ACM ceiling panel below ACM pipe insulation ASB05 Clean up small amounts of ACM debris If the condition is expected in the facility, review the work practice. ASB04 and ASB09 make good hands-on exercises. If you are going to conduct them as a hands-on demonstration later, point it out now. Q: What should I do with asbestos wastes generated during the work practice? A: Asbestos is a regulated substance and must be disposed of properly. Please contact the District Environmental Compliance Coordinator for guidance on proper labeling and disposal. Q: What about polyethylene sheeting, duct tape, and rags used during a Class IV work practice? A: These materials are also considered asbestos wastes and must be disposed of accordingly.If the condition is expected in the facility, review the work practice. ASB04 and ASB09 make good hands-on exercises. If you are going to conduct them as a hands-on demonstration later, point it out now. Q: What should I do with asbestos wastes generated during the work practice? A: Asbestos is a regulated substance and must be disposed of properly. Please contact the District Environmental Compliance Coordinator for guidance on proper labeling and disposal. Q: What about polyethylene sheeting, duct tape, and rags used during a Class IV work practice? A: These materials are also considered asbestos wastes and must be disposed of accordingly.

35. WORK PRACTICES ASB06 Clean room that has asbestos-containing dust or PACM dust ASB07 Replace a light bulb in a light fixture attached to or in surface finished with ACM ASB08 Clean a mechanical room with friable ACM present in good condition ASB09 Pulling cable above a suspended ceiling Review the General Asbestos O&M Procedures checklist before conducting any work practice. If the facility contains friable surfacing material and inset light fixtures, ASB07 should be closely reviewed and demonstrated during the training session. Note however, that ACM sprayed on surfaces or finishes are to be removed immediately under USPS policy.Review the General Asbestos O&M Procedures checklist before conducting any work practice. If the facility contains friable surfacing material and inset light fixtures, ASB07 should be closely reviewed and demonstrated during the training session. Note however, that ACM sprayed on surfaces or finishes are to be removed immediately under USPS policy.

36. WORK PRACTICES ASB10 Plumbing work on un-insulated pipes attached to a piping system that contains ACM pipe insulation ASB11 Wet strip floor wax from ACM flooring ASB12 Low speed ACM floor buffing ASB13 Clean or scrub ACM flooring ASB14 Dry or spray buff ACM flooring ASB15 Changing or replacing a HEPA vacuum bag and/or filter ASB16 Repair ACM Flooring Work practices ASB11 through ASB14, and ASB16 are almost universally required in the facilities. Demonstrate one or all of these work practices in the hands-on phase. Stress that wet methods are used in most work practices to keep dust down. Tell trainees that each work practice must be followed carefully and that all steps listed in the work practice are required to safely complete the work. Reminder for ASB15: The HEPA vacuum can be operated by USPS employees. However, removal of the waste bag or any of the filters requires a contractor as specified in ASB15.Work practices ASB11 through ASB14, and ASB16 are almost universally required in the facilities. Demonstrate one or all of these work practices in the hands-on phase. Stress that wet methods are used in most work practices to keep dust down. Tell trainees that each work practice must be followed carefully and that all steps listed in the work practice are required to safely complete the work. Reminder for ASB15: The HEPA vacuum can be operated by USPS employees. However, removal of the waste bag or any of the filters requires a contractor as specified in ASB15.

37. WORK PRACTICES 1. Conduct the work preparation activities outlined in the Asbestos O&M General Procedures Checklist. 2. Additional tools needed: Floor buffing machine, buffing pads (least abrasive), spray buffing compound, floor scraper, and caution wet floor signs. 3. Place the tools, equipment, and materials needed in the work area. Position “Caution - Wet Floor” signs. 4. Mix spray buffing compound according to the manufacturers recommendations. 5. Pick up any large, loose, general debris and place into disposable bags. In addition to the detailed review of these two slides, this work practice should always be demonstrated through hands-on exercise if applicable to the facility. First inspect the buffer and determine speed Review pad color-code white (least abrasive) pink, red, black (most abrasive). Go through the checklists and work practices aviation style Foster the safety aspects by setting up floor signs, inspecting power cords, etc. Describe but refrain from demonstrating work practice flaws, such as scalloping and edge cutting.In addition to the detailed review of these two slides, this work practice should always be demonstrated through hands-on exercise if applicable to the facility. First inspect the buffer and determine speed Review pad color-code white (least abrasive) pink, red, black (most abrasive). Go through the checklists and work practices aviation style Foster the safety aspects by setting up floor signs, inspecting power cords, etc. Describe but refrain from demonstrating work practice flaws, such as scalloping and edge cutting.

38. WORK PRACTICES 6. Remove all foreign matter from the finished surface (gum, tar, etc.) by wetting the floor using a sprayer with amended water and a floor scraper. 7. If necessary, clean the floor using work practices outlined in ASB13 - Cleaning ACM flooring. 8. Spray a small area with spray-buff solution. 9. Buff the floor using the least abrasive pads and a low speed setting (175-190 RPM maximum). 10. Perform the clean-up and tear down steps outlined in the Asbestos O&M General Procedures Checklist. In small group sessions (<5), this should take 15-20 minutes. Encourage the team to conduct the work practice with the trainer serving as the mentor, not the operator. Initially, the buffer may be difficult to control and can pull the operator unexpectedly. Make sure that other trainees stand a few feet away from the hands-on practice area. Encourage the trainees to practice starts and stops several times.In small group sessions (<5), this should take 15-20 minutes. Encourage the team to conduct the work practice with the trainer serving as the mentor, not the operator. Initially, the buffer may be difficult to control and can pull the operator unexpectedly. Make sure that other trainees stand a few feet away from the hands-on practice area. Encourage the trainees to practice starts and stops several times.

39. WORK PRACTICES Disturbing ACM surfaces Placing objects where they can impact ACM Cleaning asbestos debris Entering regulated areas Disturbing ACM - drilling the floors is not allowed at the Class IV training level. Do not place objects where they can disturb ACM. However, this does not mean that you can’t place objects on the plank floor. Small amounts of ACM debris can be cleaned up using ASB05 and ASB06. However, cleaning up a collapsed ACM ceiling tile is way beyond the intent of ASB05 and ASB06. Q: What is a regulated area? A: A regulated area is defined as an area that is demarcated to warn the general public of asbestos abatement activity, where access is restricted to authorized personnel, where respiratory protection is required, and where certain activities such as eating, drinking and smoking are prohibited.Disturbing ACM - drilling the floors is not allowed at the Class IV training level. Do not place objects where they can disturb ACM. However, this does not mean that you can’t place objects on the plank floor. Small amounts of ACM debris can be cleaned up using ASB05 and ASB06. However, cleaning up a collapsed ACM ceiling tile is way beyond the intent of ASB05 and ASB06. Q: What is a regulated area? A: A regulated area is defined as an area that is demarcated to warn the general public of asbestos abatement activity, where access is restricted to authorized personnel, where respiratory protection is required, and where certain activities such as eating, drinking and smoking are prohibited.

40. How to Respond Don’t Disturb Vacate Immediate Area and Restrict Access Whom to Contact Facility Asbestos Coordinator (FAC) WORK PRACTICES Great information as far as it goes, but use your head. We are NOT talking about vacating a workroom floor because of a broken floor tile. We are talking about stabilizing the issue, and starting the appropriate response actions. Give examples appropriate for the facility of when we should call for a vacate and mobilize emergency response contractor. For instance, you get a call that a contractor installing telephone cables hung the cable tray from the steam pipe. So it would be good and secure, he cut off the chalky pipe wrap. When questioned, he said he would be sure to sweep it up that evening before they finished.Great information as far as it goes, but use your head. We are NOT talking about vacating a workroom floor because of a broken floor tile. We are talking about stabilizing the issue, and starting the appropriate response actions. Give examples appropriate for the facility of when we should call for a vacate and mobilize emergency response contractor. For instance, you get a call that a contractor installing telephone cables hung the cable tray from the steam pipe. So it would be good and secure, he cut off the chalky pipe wrap. When questioned, he said he would be sure to sweep it up that evening before they finished.

41. Required for Renovation and Alteration, Construction, Demolition, Maintenance Work in Facilities With Asbestos Containing Building Materials WORK AUTHORIZATION FORM Hand out the form at this time. Point out where the master form is located. Q: Do I have to obtain a signed Work Authorization Form for work in a facility with ACM, but in a room of that facility which doesn’t have any ACM? A: Yes. A signed Work Authorization Form is required for work in facilities where asbestos is present whether or not asbestos is present in that room. If the work is a routine activity that does not affect asbestos, a twelve month blanket approval may be issued. Q: For routine activities such as floor cleaning, do I have to obtain an authorization for each day I conduct the activity? A: No. For routine activities, the Facility Asbestos Coordinator (FAC) may sign a twelve month authorization for that work activity. After twelve months, the FAC will review the activity to ensure that the nature and intent of the work activity has not changed and sign another twelve month authorization. A competent person is available to assist in this determination. Q: If no survey is available, what do I do? A: You must assume that the material is asbestos and use the required Work Authorization Form.Hand out the form at this time. Point out where the master form is located. Q: Do I have to obtain a signed Work Authorization Form for work in a facility with ACM, but in a room of that facility which doesn’t have any ACM? A: Yes. A signed Work Authorization Form is required for work in facilities where asbestos is present whether or not asbestos is present in that room. If the work is a routine activity that does not affect asbestos, a twelve month blanket approval may be issued. Q: For routine activities such as floor cleaning, do I have to obtain an authorization for each day I conduct the activity? A: No. For routine activities, the Facility Asbestos Coordinator (FAC) may sign a twelve month authorization for that work activity. After twelve months, the FAC will review the activity to ensure that the nature and intent of the work activity has not changed and sign another twelve month authorization. A competent person is available to assist in this determination. Q: If no survey is available, what do I do? A: You must assume that the material is asbestos and use the required Work Authorization Form.

42. WORK AUTHORIZATION twelve month blanket work authorization may be issued for routine maintenance activities covered by USPS approved work practices. Stress that the Work Authorization Form only needs to be filled out and approved by the FAC once every twelve months for routine activities. The approved Work Authorization should be kept in the O&M plan which is maintained at the affected facility. Stress that the Work Authorization Form only needs to be filled out and approved by the FAC once every twelve months for routine activities. The approved Work Authorization should be kept in the O&M plan which is maintained at the affected facility.

43. WORK AUTHORIZATION Examples of Blanket Approval Pulling cable above a suspended ceiling Low speed ACM floor buffing Cleaning ACM floors Stress that this blanket approval will become routine only if the work practices are being followed properly as determined by the Facility Asbestos Coordinator (FAC). Q: What is an example of a Work Authorization that does not get a blanket approval? A: ASB04 - Removing a non-ACM ceiling panel below ACM pipe insulation. This work practice requires visual inspection by a competent person each time the work activity is conducted. Contact the FAC to arrange for the competent person to inspect the work area.Stress that this blanket approval will become routine only if the work practices are being followed properly as determined by the Facility Asbestos Coordinator (FAC). Q: What is an example of a Work Authorization that does not get a blanket approval? A: ASB04 - Removing a non-ACM ceiling panel below ACM pipe insulation. This work practice requires visual inspection by a competent person each time the work activity is conducted. Contact the FAC to arrange for the competent person to inspect the work area.

44. WORK AUTHORIZATION Blanket Twelve Month Authorization Issuance Facility Asbestos Coordinator (FAC) Competent Person Please note when in doubt please contact your District Asbestos Coordinator or competent person for guidance. Q: Is it difficult to get the twelve month authorization (blanket approval)? A: No. It only takes a few minutes of your time every twelve months. The twelve month Work Authorization must be signed by the FAC. A competent person is available to review the applicability of the work practice if there is a question regarding the suitability of any work practice to any given activity. You must know who the competent person for your district is to fill out the Work Authorization form.Q: Is it difficult to get the twelve month authorization (blanket approval)? A: No. It only takes a few minutes of your time every twelve months. The twelve month Work Authorization must be signed by the FAC. A competent person is available to review the applicability of the work practice if there is a question regarding the suitability of any work practice to any given activity. You must know who the competent person for your district is to fill out the Work Authorization form.

45. WORK AUTHORIZATION Competent Person The name of the competent person is obtained from the project manager, the FAC or the contracting officer. A competent person is defined as a person that has had 16-hour Class III asbestos training; will supervise Class III and IV asbestos work (however, this person does not have to be present on-site for most work practices); has a high level of knowledge of worksite safety and health issues; and be able to identify existing and predictable hazards that are hazardous to employees. The competent person has the authorization to take prompt corrective measures to eliminate recognized hazards to USPS personnel. The USPS must designate at least one individual as a competent person for each district. Contact the FAC or Facility Manager if you do not know who the competent person is for your facility. Q: What work practice requires a competent person to be on-site? A: ASB04 - Removing a non-ACM ceiling panel below ACM pipe insulation. The competent person must visually inspect the work area each time the work is conducted. Contact the FAC to arrange for the competent person to inspect the work area.A competent person is defined as a person that has had 16-hour Class III asbestos training; will supervise Class III and IV asbestos work (however, this person does not have to be present on-site for most work practices); has a high level of knowledge of worksite safety and health issues; and be able to identify existing and predictable hazards that are hazardous to employees. The competent person has the authorization to take prompt corrective measures to eliminate recognized hazards to USPS personnel. The USPS must designate at least one individual as a competent person for each district. Contact the FAC or Facility Manager if you do not know who the competent person is for your facility. Q: What work practice requires a competent person to be on-site? A: ASB04 - Removing a non-ACM ceiling panel below ACM pipe insulation. The competent person must visually inspect the work area each time the work is conducted. Contact the FAC to arrange for the competent person to inspect the work area.

46. WORK AUTHORIZATION Assessment of Work Refer to O&M Plan for location of ACBM Review work practices USPS personnel use approved USPS work practices Contractors use work practices found in approved Scope of Work Explain that the person completing the Work Authorization form needs to: Determine whether or not ACM is in the vicinity of the work area. Whether ACM will be disturbed by the proposed work. Determine if a postal employee can perform the work. If a USPS employee will do the work, determine if there is an approved work practice. If a contractor* performs the work, state if there is a Scope of Work (SOW) for the project. Go through an example of filling out the form with a work practice that is used at a specific facility. *Contractors can certainly use USPS work practices as a reference. However, they do have their own OSHA requirements, which are not met exclusively by following USPS work practices.Explain that the person completing the Work Authorization form needs to: Determine whether or not ACM is in the vicinity of the work area. Whether ACM will be disturbed by the proposed work. Determine if a postal employee can perform the work. If a USPS employee will do the work, determine if there is an approved work practice. If a contractor* performs the work, state if there is a Scope of Work (SOW) for the project. Go through an example of filling out the form with a work practice that is used at a specific facility. *Contractors can certainly use USPS work practices as a reference. However, they do have their own OSHA requirements, which are not met exclusively by following USPS work practices.

47. WORK AUTHORIZATION General Instructions If no asbestos, the form is not required Sections 1 & 2 - completed by responsible person Sections 3, 4, 5, & 6 - completed by the Facility Asbestos Coordinator (FAC) Walk them through the completion of the form. The information required for the Work Authorization Form is needed to maintain the integrity of the O&M program. Without updates, the whole asbestos survey will gradually become outdated. The Work Authorization Form keeps the program up to date with the quantity and condition of asbestos in the building.Walk them through the completion of the form. The information required for the Work Authorization Form is needed to maintain the integrity of the O&M program. Without updates, the whole asbestos survey will gradually become outdated. The Work Authorization Form keeps the program up to date with the quantity and condition of asbestos in the building.

48. WORK AUTHORIZATION General Information Contractor Information should be completed by: Contractor Contracting Officer’s Representative Project manager FAC/IH Q: What about contract cleaners? A: For contract cleaners, the contracting officer’s representative (COR) can get the paperwork completed and approved in advance so that the work will not be delayed. Q: Can another person handle the paperwork? A: Yes. It is your choice on who will coordinate the paperwork required for contract cleaners and how to make the program work.Q: What about contract cleaners? A: For contract cleaners, the contracting officer’s representative (COR) can get the paperwork completed and approved in advance so that the work will not be delayed. Q: Can another person handle the paperwork? A: Yes. It is your choice on who will coordinate the paperwork required for contract cleaners and how to make the program work.

49. WORK AUTHORIZATION Work Description Information on location of work consistent with O&M plan A narrative description of work USPS work practices to be noted if work is performed by USPS personnel Make sure that you provide a detailed description of the work and the location(s) in the facility where the work will take place. Please indicate on the form when the USPS approved Class IV work practices will be used.Make sure that you provide a detailed description of the work and the location(s) in the facility where the work will take place. Please indicate on the form when the USPS approved Class IV work practices will be used.

50. WORK AUTHORIZATION Work Denial Work is denied as follows Proposed disturbance of asbestos without an approved work practice an approved contractor authorization from a contracting officer Failure to provide information on location and work to be performed Explain that the form cannot be signed by the FAC without all of the proper information.Explain that the form cannot be signed by the FAC without all of the proper information.

51. WORK AUTHORIZATION Work Authorization Procedure For contracted work the CO signs and sends to FAC/IH for approval The FAC/IH signs form if information is provided in sections 1, 2, 3, & 4 This procedure is put in place so that the FAC will sign the form after it has been completed and can be filed at the facility in the O&M plan.This procedure is put in place so that the FAC will sign the form after it has been completed and can be filed at the facility in the O&M plan.

52. WORK AUTHORIZATION Distribution Original work authorization is kept by FAC/IH in O&M plan Copy 1 is provided to District Asbestos Program Coordinator Copy 2 is assigned by District Make sure that the original form is kept in the O&M plan.Make sure that the original form is kept in the O&M plan.

53. SUMMARY Remain informed Notify in the event of disturbance Use work practices consistent with the O&M Plan Q: Who will we notify in the event of an emergency or disturbance? A: The facility asbestos coordinator, which is the postmaster in most postal facilities. Q: “I would like to modify the work practices, I’ve got a better way to do this job.” A: The work practices are OSHA-approved best management practices. We can make changes, but only after careful review and coordination with OSHA. If you think you know a better way to conduct the work practice, please contact your district asbestos coordinator to discuss its merits. Pause at this point. Address any questions before proceeding to management issues. Q: Who will we notify in the event of an emergency or disturbance? A: The facility asbestos coordinator, which is the postmaster in most postal facilities. Q: “I would like to modify the work practices, I’ve got a better way to do this job.” A: The work practices are OSHA-approved best management practices. We can make changes, but only after careful review and coordination with OSHA. If you think you know a better way to conduct the work practice, please contact your district asbestos coordinator to discuss its merits. Pause at this point. Address any questions before proceeding to management issues.