Asbestos & Lead

Asbestos is a known human carcinogen that was used in a multitude of building applications prior to about 1980. Many of the buildings constructed prior to 1980 at UC Santa Barbara have Asbestos Containing Materials (ACM) in publicly accessible areas in materials such as floor tiles and mastic, sheet vinyl, roofing felt, drywall joint compound, and pipe insulation. Most of these materials are considered "non-friable" (not easily reduced to dust or powder) and as long as they are not crushed or abraded, do not pose a public health risk.

The purpose of this plan is to describe a program for controlling exposure to asbestos in University owned buildings. The principal element of this program is the delegation of a central authority to act as a component person for the campus as defined in CCR Title 8 Subchapter 5 Article 4 Section 1529. The management of asbestos at UC Santa Barbara is the responsibility of the Asbestos Program Manager: Gene Horstin (Email gene.horstin@ucsb.edu). These responsibilities include the identification of existing asbestos hazards, selecting the appropriate control strategy for asbestos exposure, and taking prompt corrective measures to eliminate identified asbestos hazards.

It is UC Santa Barbara practice to manage asbestos in place. Asbestos is rarely used alone, and it is generally safe when combined with other materials with strong bonding agents. As long as the material remains bonded so that fibers are not released, it poses no health risk. If material becomes damaged or is impacted during a renovation the material will either be repaired or removed. Please contact Asbestos Program Manager: Gene Horstin – Email gene.horstin@ucsb.edu with any comments, questions, abatement, and/or repair request.

1. Asbestos Manager - Act as project manager for asbestos abatement contracts
2. Asbestos Manager - Maintaining asbestos records including asbestos surveys, laboratory reports, abatement specifications, etc.
3. Asbestos Manger - Provide technical assistance to the campus with regards to asbestos
4. Asbestos Manger - Perform bulk asbestos sampling and interpretation of results
5. Asbestos Manager - Review of renovation and demolition projects for potential asbestos hazards
6. Asbestos Manager - Santa Barbara Air Pollution Control District notification for applicable renovation and demolition projects
7. UCSB Environmental Health & Safety (EH&S) in conjunction with the Asbestos and Lead Manager is responsible for asbestos training for staff.
   1. Employees having job descriptions requiring the occasion to perform duties with or around asbestos, must receive annual training in asbestos awareness. This training includes:
      1. Information regarding asbestos, its various uses and forms.
      2. Health effects
      3. Locations in the buildings
      4. Recognition of damage, deterioration, and delamination of asbestos
      5. Name and phone number of the person designated to carry out responsibilities regarding asbestos

For projects that require abatement the Asbestos Manger will act as project manager for the asbestos abatement portion of the project. This includes the scoping of the work for contractors and consultants, the preparation of bid documents, pre-abatement surveys and waste characterization. All asbestos abatement or asbestos work on campus and in campus owned buildings is contracted out to registered asbestos abatement Contractors.

Documents of bulk sampling, air sampling, and abatement projects are kept in a database maintained by the North Hall data center and the Asbestos Manager. Records are available upon request.

Incidents of asbestos exposure or potential exposure should be reported to your supervisor and Gene Horstin
Asbestos Manager at – Email gene.horstin@ucsb.edu. After hours call Public Safety Dispatch (805) 893-3446 or EH&S Technical Assistance (805) 893-3194.

CCR Title 8 Subchapter 5 Article 4 Section 1529
CCR Title 22 Division 4.5 Environmental Health Standards for the Management of Hazardous Waste
40 CFR 61 National Emission Standard Hazardous Air Pollutants (NESHAPS)

To establish the University of California, Santa Barbara’s Lead Work MOP and the process for compliance with CCR Title 8 section 1532.1, Lead, and to provide for the safety of building occupants from lead exposure. The University shall not self-perform any lead abatement as defined by CCR Title 17, Division 1, Chapter 8.

The University is dedicated to providing lead safe facilities for building occupants, and with complying with state and federal laws regarding lead work. All University employees share a responsibility to minimize their exposure to lead. The Lead Work MOP shall be reviewed and evaluated for its effectiveness periodically and updated as necessary.

Facilities Management and Housing, Dining & Auxiliary Enterprises shall identify and train employees for tasks described below. In addition, the University shall identify, train, and medically monitor employees assigned to perform lead work in compliance with CCR Title 8 section 1532.1. All lead-work areas shall be clearly posted at approaches to the lead work site in accordance with 29 CFR Part 1926.62, 8 CCR Part 1532.1 and 27 CCR Part 25601. Respirators shall at a minimum be equipped with P-100 filters.

1. Supervisors/Managers shall:
   1. Be responsible for the employees under their supervision;
   2. Evaluate work tasks for compliance with this MOP;
   3. Monitor the work practices of their employees;
   4. Ensure the safety of the University population;
   5. Submit any paperwork including but not limited to daily logs, work tasks, disposal procedures, and incidents, and shall maintain records of employee training, exposure monitoring and work logs pertaining to lead;
   6. Devise and review a lead-work plan prior to work starting to stay in compliance with this MOP.
   7. Ensure documented Job Hazard Assessments are conducted for all tasks involving hazardous chemicals or requiring the use of personal protective equipment per Title 8 of the California Code of Regulations, General Safety Order 3380;
   8. Ensure hazards identified are eliminated or adequately controlled;
   9. Ensure direct reports who use and/or are exposed to hazardous chemicals including lead, have received documented Chemical Hazard Communication Training and understand their rights and the requirements of the UCSB Chemical Hazard Communication Program and the Cal/OSHA Hazard Communication Standard;
   10. Ensure direct reports who use and/or are exposed to hazardous chemicals including lead, can interpret labels and Safety Data Sheet information, recognize the signs and symptoms of exposure, and know how to take appropriate safety precautions to protect themselves from the hazardous chemicals they are exposed to;
   11. Ensure direct reports are provided all necessary personal protective equipment, and are trained on proper use;
   12. Enforce the use of personal protective equipment and safe work practices where required;
   13. Ensure direct reports comply with all other UCSB Chemical Hazard Communication Program requirements;
2. Employees shall:
   1. Be responsible for compliance with this MOP;
   2. Ensure safe work practices including but not limited to PPE and the establishment and maintenance of a regulated area;
   3. Proper cleanup;
   4. Proper equipment;
   5. Maintenance of equipment;
   6. Maintenance of training certificates and medical surveillance;
   7. Establishment of a wash/decontamination station;
   8. Report lead or potential lead hazards to their supervisor;
   9. Devise a lead-related work plan prior to work starting for review by the project supervisor and/or campus Lead and Asbestos Manager.
3. Lead and Asbestos Manager shall:
   1. Be responsible for testing surfaces for lead coatings prior to work. Paint to be tested by sampling paint chips;
   2. Perform exposure sampling of employees;
   3. Assist in the implementation of this MOP.
4. EH&S Industrial Hygiene Program shall:
   Administer the UCSB Respiratory Protection Program and ensure that it meets California Code of Regulations, Title 8, Section 5144 requirements. All use of respiratory protection equipment by UCSB personnel, including the use of filtering facepiece respirators (dust masks), must be reviewed and approved by the EH&S Industrial Hygiene Program. Compliance: The University shall comply with all state and federal laws pertaining to lead work. The University shall train employees in compliance with CCR Title 8 § 1532.1 and 40 CFR 745. Training shall be done prior to lead work and shall be maintained as stated in CCR Title 8 §1532.1, 40 CFR 745, and 17 CCR Division 1, Chapter 8. Medical and biological monitoring shall be implemented to lead trained employees in compliance with CCR Title 8 §1532.1. Respirator protection shall be in compliance with CCR Title 8 § 5144.

Each lead task encountered on the University Campus and University owned buildings will have variables. Each task may need to be evaluated by the Employee, Supervisor, and/or Lead and Asbestos Program Manager to determine if the task is safe to the Employees performing the task and the campus community and if the University will be in compliance with State and Federal Laws regarding lead. The following is a general guideline for common tasks involving lead work on campus and University owned buildings to be performed by University employees:

• Paint prep of lead-containing or lead-based paint: Paint prep shall include only the scraping of loose and flaking paint. Coated surface shall not be over 3000ppm and over 50sqft. Sanding lead coatings of any concentration is prohibited. Power tools (i.e. grinders) are prohibited.
• Demolition of lead-coated materials: Demolition of building walls, ceilings, and floors with lead-coatings shall not be over 3000ppm and over 50sqft. Demolition of building walls, ceilings, floors, or trims higher than 3000ppm shall not be over 10sqft. Demolition of building components intact (e.g. fan units, HVAC ducting, windows) shall not be over 75sqft. Lead-related demolition shall be performed in a manner that reduces the amount of lead particulate generated.
• Paint stripping: Chemical paint stripping shall be done in compliance with the stripping manufacturer’s recommendations. Lead paints requiring chemical striping shall not be over 5000ppm and 50sqft. Stripping using mechanical means is prohibited.
• Heating, welding, and torch cutting of lead coated materials is prohibited. Coatings shall be removed in compliance with CCR Title 8 § 1537.
• All lead work areas to be cleaned with HEPA vacuums and/or wet wiping.

Waste generated by any of the tasks above shall be disposed of via Environmental Health & Safety (EH&S). Employee and or Supervisor shall provide the Campus Hazardous Waste Program a recharge number for disposal costs. Waste shall be packaged by the Employee performing the task. Packing for shipment and disposal shall be done by EH&S. Waste over 1000ppm shall be disposed of as hazardous waste. Waste below 1000ppm shall be disposed of as non-hazardous waste. Waste of unknown concentrations shall be characterized using the project’s work order number by the Lead & Asbestos Program Manager.

Below is a list of applicable regulations regarding lead work.

• CCR Title 8 section 1532.1
• CCR Title 8 section 1537
• CCR Title 8 section 5144
• CCR Title 8 section 5194
• CCR Title 17 div 1 chap 8
• CCR Title 22 div 4 chap 30
• 40 CFR part 745
• 40 CFR part 262