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APS 12.1 – Managing Asbestos and Other Regulated Building Materials

Table of Contents

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(Approved by the Provost and Executive Vice President by authority of Executive Order No. 4 and by the Vice President for Finance and Facilities by Administrative Order No. 9) 

1.  Policy

This policy outlines the general responsibilities for University of Washington organizational units in managing asbestos and other regulated building materials.

The University is required to comply with local, state, and federal health and safety regulations including, but not limited to: Washington State Department of Labor and Industries asbestos regulation, Chapter 296-62 WAC, Part I-1; lead regulation, WAC 296-62-07521; and U.S. Environmental Protection Agency Polychlorinated Biphenyls (PCBs) regulation, 40 CFR 761.50. The University is required to ensure building material that may pose health risks be managed, abated, and disposed of appropriately.

This policy clarifies and guides departments in their roles and responsibilities to ensure compliance with regulated building material regulations. Failure to follow regulations could cause possible exposure and health issues or result in clean-up costs, regulatory fines, and increased risk of liability to the University.

2.  Scope

This policy applies at all locations including, but not limited to: the Seattle, Bothell, and Tacoma campuses; medical centers; jointly-owned facilities; all other University-owned, managed, or operated properties; University leased space as tenant or landlord; and research vessels that are owned or operated by the University.

UW Bothell has special considerations related to its co-location with Cascadia College and relationships with local jurisdictions and agencies that affect how this policy is implemented. Consult UW Bothell operating procedures and programs for implementation details.

UW Tacoma has special considerations related to local jurisdictions and agencies. Consult UW Tacoma operating procedures and programs for implementation.

3.  Definitions

Asbestos Containing Material (ACM)—Material containing more than one percent asbestos. Common examples of ACM include but are not limited to:  pipe and boiler insulation, sprayed on fireproofing, troweled on acoustical plaster, floor tile and mastic, floor linoleum, asbestos-cement board or shingles, roofing materials, wall and ceiling plaster or joint compound, ceiling tiles, gasket materials, and other asbestos containing materials.

Regulated Building Materials (RBM)—Materials regulated by law because of potential health and environmental risks. RBM includes ACM, lead and polychlorinated biphenyls (PCBs) that exist in building materials including, but not limited to, walls, floors, ceilings, insulation, caulk, glazing, mastic, paint, light fixtures, fireproofing, and equipment.

4.  University Compliance Responsibility

It is University policy that each vice president, vice provost, vice chancellor, dean, director, department chair, and supervisor is responsible for the health and safety performance in his or her respective units. This responsibility can neither be transferred nor delegated.

A. Environmental Health and Safety

The Environmental Health and Safety Department (EH&S) serves as the primary University liaison to regulatory agencies. EH&S develops and maintains the University Asbestos Management Plan which outlines institutional policy and program responsibility to ensure that asbestos is managed in accordance with applicable laws. EH&S also reviews program policies, provides consultation and assistance, conducts RBM training, performs compliance audits, performs exposure and health assessments, notifies campus of regulatory change, monitors and coordinates University response to proposed regulations, and provides a medical surveillance program for University employees who perform asbestos and other RBM work.

B. Facilities Departments—All Sites

Organizational units with independent facilities maintenance and operations responsibility must designate a qualified person, or agent, to manage RBM in University-owned and managed buildings/facilities. This includes, but is not limited to, developing safe work practices and controls, training employees, maintaining RBM records, responding to reports of damaged RBM, restricting access to hazardous spaces to prevent exposure, and maintaining labels and signs to warn of RBM.

C. Facilities Services, UW Seattle

Facilities Services (FS) has compliance responsibility for buildings it operates and maintains at the UW Seattle campus as outlined in Section 4.B above. FS also performs RBM work in support of alterations, maintenance, and capital projects by directing its term contractors for work at UW Seattle. FS may also provide this service to other campuses, sites, and research stations.

D. Capital Planning and Development (CPD)

CPD’s Major Projects and Special Projects groups manage capital construction and are responsible for ensuring that their programs and contracts require that ACM and RBMs are managed in accordance with applicable laws in all new construction, alteration, and renovation projects. CPD implements programs to eliminate or reduce the use of ACM and RBM in new construction or renovation of University owned or managed facilities. CPD uses its own Hazardous Materials Safety Manager as a resource on all projects it delivers.

E. UW Real Estate

UW Real Estate oversees property management companies who have been retained to manage and maintain the University’s property portfolio. In order to protect building occupants, UW Real Estate is responsible for ensuring that its contracts comply with the University Asbestos Management Plan and include provisions governing compliance with all applicable ACM and RBM regulations.

F. Other Organizational Units and Departments Conducting Construction, Alterations, and Installations

Each campus, organizational unit, and department that conducts, hires an outside service, or contracts for, construction, alteration, building maintenance, or certain custodial services of University buildings and facilities is responsible for adopting and implementing the University Asbestos Management Plan and following all compliance procedures, including those referenced in this policy.

Departments performing or contracting for minor installation or alteration, including purchase and installation services for office cubicles, flooring, fixed audio/visual equipment, fixed shelving, or other building fixtures must implement applicable procedures as outlined in the University Asbestos Management Plan and follow all compliance procedures, including those referenced in this policy.

G. Procurement Services

The University’s Procurement Services ensures solicitations/contracts comply with the University Asbestos Management Plan and include provisions governing compliance with all applicable ACM and RBM regulations.

5.  Compliance Procedures and Guidance

The University Asbestos Management Plan, other compliance procedures, guidelines, best practices, and occupational safety training information may be found on the EH&S Asbestos page.

6.  Relevant Regulations

Laws regulating asbestos, lead, and PCBs in building materials include, but are not limited to the following:

  • Washington State Department of Labor and Industries rules under WAC 296-62-077 et seq., Asbestos, Tremolite, Anthophyllite, and Actinolite, and Chapter 296-65 WAC, Asbestos Removal and Encapsulation.
  • Puget Sound Clean Air Agency Regulation III, Article 4, Asbestos Control Standards.
  • United States Environmental Protection Agency rules under 40 CFR Part 763, Asbestos, and 40 CFR Part 61, Subpart M, National Emission Standard for Asbestos; and applicable requirements of local jurisdictions and municipalities.
  • United States Environmental Protection Agency rules under 40 CFR Part 761, Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions.
  • Washington State Department of Labor and Industries rules under WAC 296-62-07521, Lead.

7.  Additional Information

For further information and specific guidelines and procedures regarding ACM and RBM, contact the Environmental Health and Safety Department.

March 14, 2016.