BRANDEIS UNIVERSITY
ASBESTOS MANAGEMENT PLAN
REVISION UPDATE
Revision: 2/14/12
Issue Date: 2/28/12
Replaces: 9/16/09
Reason: See italics.
Document1
Originated by: Andrew J. Finn, Mgr. EH&S
Date:___2/28/12_________
Page 1
2/10/2016
BRANDEIS UNIVERSITY ASBESTOS MANAGEMENT PLAN
In institutional buildings, “friable” (easily crumbled or pulverized by hand pressure)
asbestos was used for many purposes including: 1) Thermal insulation on pipes and
boilers, 2) fireproofing material, 3) acoustical material on floors, ceilings and walls, 4)
mastics and floor tiles, and many other uses. Any building built since the 1920’s may
have asbestos containing materials in pipes and boilers, while fireproofing materials
and acoustical material appeared more in the 1950’s. The spraying of asbestos as
fireproofing was banned in 1973, its application as pipe and boiler insulation was
discontinued in 1975, and spraying for acoustical purposes was banned in 1975.
Since the 1970s, less friable forms of asbestos have been in use up to the present. Most
of these are in the form of flooring, roof coatings, mastics and joint compound. While
less dangerous than the original banned forms, these products can be harmful to
humans or the environment if disturbed, demolished or disposed of improperly.
Brandeis University has implemented this Plan to identify, inspect, control, maintain
and improve our handling of asbestos related issues across the campus. Brandeis,
under the direction of the Environmental Health & Safety Department, has put
together evaluation, abatement, maintenance and training programs that will not only
better protect the environment, but the faculty, staff, students and visitors of the
college. Risks associated with asbestos, including alteration, construction, demolition
and repair activities will be addressed in the most expeditious manner possible in an
effort to reduce negative environment impact or adverse health effects to the Brandeis
University community.
1.0
RECOGNITION , NOTIFICATION AND EVALUATION
The following program applies to all University staff, facilities, and contractors, and is
designed to recognize potential asbestos containing material (PACM), establish evaluation
for asbestos content, and outline notification protocols so that appropriate controls can be
implemented to minimize any possible exposure to staff, students, and visitors.

Recognition
Definite identification is possible only by laboratory evaluation, however, most
asbestos pipe insulation has a white or grey, chalky appearance and may be covered
with cloth wrapping. Fiberglass insulation is usually pink or yellow and has long
woven fibers. Asbestos fireproofing material or ceiling material ranges from soft
Document1
Page 2
2/10/2016
“pebbly” appearance to a hard plaster material. The Environmental Health & Safety
Department shall maintain files of Brandeis buildings and areas that have been tested
for PACM. All staff likely to come into contact with PACM shall be trained by their
supervisors (Information supplied by the Environmental Health & Safety Department)
in how to recognize PACM and report potential issues with material.
Asbestos may be found in the following types of materials:













Caulking
Ceiling Tiles
Cement
Cooling Tower Baffles
Door Interiors
Electrical Cloth.
Elevator Brakes
Floor Linoleum and most 9" x 9" Tiles
Insulation
Laboratory Furniture and Hoods
Insulation (wide variety)
Joint Compound
Plaster, both Decorative and Non-Decorative

Notification
When asbestos containing material is suspected, it should be immediately reported to
the appropriate supervisor. Trades personnel should not disturb any questionable
material until it has been reviewed and analyzed if necessary. The supervisor is
responsible for reporting PACM issues to the Manager of EH&S at 64262
(afinn@brandeis.edu).
Project managers shall manage asbestos identification and abatement within the scope
of the Project Planning and Design Process. The Department of EH&S should be
notified of all abatement projects to ensure abatement compliance.
The Asbestos Program Checklist should be used by Facilities staff as well as Project
Managers to ensure that proper evaluation and preventive actions have been
completed.

Evaluation
Once the Environmental Health & Safety Department has been notified (6-4262) of
PACM, a Department representative shall assess the situation, potential damage,
exposure and conditions. Samples shall be taken by a licensed Asbestos Inspector
Document1
Page 3
2/10/2016
working for an independent industrial hygiene firm and evaluated for asbestos
content. Samples shall be analyzed and results of positive or negative presence of
asbestos will be reported in a timely fashion depending upon project needs. Material in
question should not be handled by Brandeis or contract employees until test results
have been received and reviewed. Quick turn-around times are available. Generally, at
a minimum 24 hours is required. EH&S shall maintain all test results in building files.
Currently authorized contractors include:
o Environmental Health, Inc. (Sampling and Testing)
Dover, Ma
508-785-2258
Phil Terrell, ScD
617-201-7730 (cell)
o Envirotest Laboratory Inc. (Sampling and Testing)
Westwood, MA
781-278-0080
Primary contact: Mark Gorham
781-258-1001 (cell)
o Dectam Corp (Abatement)
50 Concord Street
N. Reading, Ma 01864
978-470-2860
Primary contact: Bruce Sullivan
978-375-0383
o A-Best Abatement Inc. (Abatement)
Salem, NH
1-800-331-7699 (Main #)
Primary contact: Sam Homsey
603-231-0663
2.0
ASSESSING AND RANKING HAZARD AREAS
With many Campus buildings and facilities potentially containing asbestos
materials, the University must conduct an appropriate exposure-risk assessment in
order to prioritize hazard areas. This is necessary to maximize the University’s
resources in scheduling asbestos abatement or encapsulation projects. Assessments
shall be carried out when PACM or known ACM has been disturbed by some
activity or when repair, renovation or demolition activities on campus may disturb
these materials.
Document1
Page 4
2/10/2016
An exposure-risk assessment involves determining the nature of the harm likely to
occur, potential for exposure, how often exposure may occur, type of location
(mechanical room, dorm, administrative building etc.). This assessment is a
requirement of the EPA NESHAP standard. This standard requires a
preconstruction survey prior to demolition or renovation activity.
The University shall evaluate the input from contractors whose professional
expertise lies in this field (i.e. Envirotest or other), this shall be utilized along with
the potential for exposure in determining the appropriate control techniques for
each situation.
Immediate removal or encapsulation shall be followed when there is a high
possibility of release and/or exposure to University personnel.
Areas of little damage (no exposure to friable material) may require no immediate
action where material is well protected and fiber release is extremely unlikely.
3.0
REPAIR AND REMOVAL NOTIFICATION
The following procedure applies to all University facilities that have been identified
as containing PACM. In all situations (emergency or otherwise), the Supervisor
shall contact the EH&S Department (64262) before work is initiated on material
suspected of containing asbestos. If the Manager of EH&S is not available, another
Authorized Personnel (Section 9.0) should be contacted. At no time shall University
personnel be knowingly exposed to PACM.

Notification
o Facilities Department shall notify EH&S of any PACM issues for evaluation,
encapsulation or removal needs. This shall include any
renovation/demolition projects during the planning phase to determine of
asbestos may be impacted.
o Project Managers shall notify the EH&S Department prior to any abatement
project. This shall include any renovation/demolition projects during the
planning phase to determine of asbestos may be impacted.
o The EH&S Department or Authorized Personnel (Section 9.0) shall notify
contractors of all asbestos evaluation, encapsulation and removal projects.
Document1
Page 5
2/10/2016

Notification Guidelines
Conditions
Actions
Accidental asbestos disturbance or
other emergency requiring immediate
action to abate other emergency (i.e.
broken pipe, leaking valve, damaged
tiles)
Routine work needing evaluation and
potential abatement.
[Note: Failure to plan appropriately
does not constitute an
“emergency”.]
Emergency Waiver Route
Isolate affected area to prevent any exposure,
lock doors if necessary, isolate HVAC systems,
post warning signs, post Public Safety if
necessary. Contact EH&S. EH&S shall contact
contractor (apply for emergency waiver)
Contact: Joe Paparella 978-694-3264 (DEP)
10-Day Notification**
Notify EH&S. EH&S will contact contractor
(apply for notification)
Asbestos Notification Form ANF-001
http://www.mass.gov/dep/air/approvals/anf001.pdf
**Plan the 10-day notification into your project schedule.
Excerpt from 310 CMR 7.00:
“EMERGENCY DEMOLITION/RENOVATION OPERATION means any operation that was
not planned but results from a sudden unexpected event which requires the
demolition/renovation of a structurally sound or unsound facility or facility component. This
term includes operations necessitated by non-routine failures of equipment.”
4.0
TRAINING AND PPE

Training
The Facilities Department is responsible for ensuring that employees who may be
exposed to PACM receive appropriate training. The EH&S Department may assist
in providing training (Outside sources may be used, ex: IEE in Woburn). Training
topics shall include:
o Types and uses of asbestos
o Health effects associated with asbestos exposure
o Notification requirements
o Work restrictions
Document1
Page 6
2/10/2016
o Personal protective equipment
o Administrative controls, engineering controls and work practices.
Contractors are responsible for ensuring their training responsibilities are met prior
to working on campus.

Personal Protective Equipment
University personnel shall not undertake work that will expose them to PACM
requiring special PPE. PACM shall be abated or encapsulated prior to University
personnel working in the immediate area or on equipment/surfaces that may
contain PACM.
Contractors shall ensure that appropriate control techniques are utilized (area
isolation, decontamination and control, glove bags), to eliminate exposure to
University personnel during testing, abatement and control projects. All project
areas shall be prominently and suitably labeled in accordance with the most current
and strictest regulatory requirements.
5.0
FACILITIES ACTIVITIES ON OR AROUND PACM
Facilities Services personnel shall not disturb any PACM prior to evaluation and
abatement. Work which may be affected include tasks such as:
o Fire door repair
o Plumbing work which requires pipe insulation removal
o Electrical work which requires handling or removal of asbestos insulated
wiring
o Boiler work affected PACM components (insulation etc.)
o Tile and/or grout removal which may contain asbestos
o Wall penetrations into wallboard which may be PACM
o Roof repair or penetration where roofing material may be PACM
o Steam line or valve operation where access may impact insulation
Facilities shall contact the EH&S Department for evaluation and abatement if
necessary prior to commencing any work. Facilities personnel shall assume that
material is PACM where it is suspect until proven otherwise by a qualified
individual or documentation.
Facilities staff should notify EH&S of any dangerous conditions immediately. A
dangerous condition would be one in which PACM is visibly damaged and may
become airborne. Asbestos material should not be disturbed, swept up or otherwise
damaged.
Document1
Page 7
2/10/2016
General practices
Custodial practices on ACM tile floors should include:
o Using wet methods on floors
o Utilizing low buffer speeds and non-aggressive pads
Restricted practices include:
o Dry buffing floors in buildings built prior to 1980, unless floors have
been replaced.
o Scraping floors in buildings built prior to 1980, unless floors have
been replaced.
o Sweeping or dry brushing floors in mechanical rooms in which
asbestos containing material is possible.
o Removing ceiling tiles in buildings built prior to 1980 if there is a
possibility that pipes with asbestos insulation are above and may be
damaged. (Evaluation should be done by an asbestos contractor to
prevent employee exposure.)
o Cutting or drilling walls in buildings constructed prior to 1980 unless
the material has been tested and either shown to be negative for asbestos
content or remediated.
o Dry scraping or sanding of plaster walls in buildings constructed
prior to 1980 unless the material has been tested and either shown to be
negative for asbestos content or remediated.
6.0
CONTRACTOR REQUIREMENTS
Contractors shall comply with all applicable regulations.
The contractor shall utilize all means possible to prevent asbestos fibers from
migrating out of the work area(s).
Contractors are required to make appropriate notifications prior to any abatement
work. (Asbestos Notification Form ANF-001)
Contractors involved in demolition and construction are required to assess the need
for and shall file a “Notification prior to Demolition and Construction” form, BWP
AQ 06.
Any areas where abatement activities are occurring shall be restricted to authorized
personnel. Authorized personnel shall include only Massachusetts certified
asbestos workers, supervisors, project monitors, and emergency response
personnel.
Document1
Page 8
2/10/2016
To protect the building components and its occupants from exposure to potentially
harmful volatile organic compounds (VOC), only low-VOC and low-odor products
shall be utilized for floor tile and mastic abatement. The Contractor shall provide to
the Project Manager and project monitor on site Material Safety Data Sheets
(MSDSs) for all chemicals used including mastic removers.
7.0
RECORDKEEPING
The EH&S Department shall maintain files of all assessment and abatement
projects.
EH&S shall contact the waste transporter if return manifest paperwork has not been
received within 35 days of initial shipment date.
Training documentation shall be maintained and be accessible.
EH&S shall maintain all test results in building files.
Documentation that must be sent to EH&S for project files:
 Project notifications
 Purchase orders
 Abatement proposals
 Invoices
 Air clearance sampling
 Bulk sampling results
 Waste Shipment Record (“manifest”)
 Asbestos surveys
 Asbestos Program Checklist(s)
8.0
GENERAL RESPONSIBILITIES


VP Administration
o Ensure overall implementation of the Program
Director of Facilities
o Ensure Facilities personnel are complying with appropriate sections of this
program
Document1
Page 9
2/10/2016


9.0
o Ensure that copies of paperwork filed through Facilities related to and
required to be maintained by this Plan are sent to the EH&S Department
o Ensure that Facilities Supervisors are aware of the Plan and have notified
their personnel of its application to their job(s)
Facilities Trades personnel
o Ensure compliance with notification procedures of this plan when PACM is
encountered
o Comply with General and Restricted practices
o Forward project paperwork to EH&S
Environmental Health & Safety Staff
o Carry out evaluation and notification duties as outlined
o Maintain records as required
o Coordinate remediation actions
AUTHORIZED PERSONNEL
The following personnel are authorized under this plan and by the University to
carry out the evaluation and notification requirements under Section 1.0 in the
absence of the EH&S Department representatives.
 Peter Baker
 Joe Delisle
 Ryan Donahue
 Bob Elias (EH&S)
 Andrew Finn (EH&S)
 Peter Shields
Document1
Page 10
2/10/2016
ASBESTOS PROGRAM CHECKLIST
This checklist should be completed for each proposed demolition, renovation, asbestos
abatement, or other building related project that includes disturbance of asbestos
containing material or potential asbestos containing material. A copy of this checklist must
be sent to the EH&S Department with corresponding paperwork prior to commencement
of work.
Asbestos Evaluation and Control Procedures
Check when
complete.
Has the area to be demolished, renovated or otherwise
impacted been surveyed for asbestos-containing material?
Was the survey completed by a Licensed Inspector?
If asbestos containing material was found, has a licensed
abatement contractor been retained to abate the asbestos prior
to disturbance?
Have the appropriate DEP notifications been made and copies
provided to the Brandeis EH&S Department?
Has a licensed asbestos Industrial Hygienist been contracted to
oversee abatement and air clearance?
Have building occupants been notified in advance of asbestos
abatement work that will take place?
Is asbestos abatement an emergency situation requiring an
exemption notification?
Is asbestos abatement complete?
Has asbestos waste manifest paperwork been provided to the
Brandeis EH&S Department?
Document1
Page 11
2/10/2016
PACM awareness by Facilities staff,
contractor or other party
Notify EH&S
6-4262
afinn@brandeis.edu
elias@brandeis.edu
EH&S Evaluation of PACM
Testing
necessary- NO
Testing
necessary YES
EH&S shall ensure sampling and analysis is
completed. Results will be communicated
when complete.
Positive Test
– EH&S to
contract
remediation
Negative
Test
Tasks in area can commence.
Remediation
Document1
Page 12
2/10/2016