"We've had a very aggressive asbestos abatement program in place for three years," said Frank Lisella, director of the Environmental Health and Safety Office. "The revised OSHA regulations actually will have a minimal impact on us, because we have been moving ahead so rapidly in the area of asbestos abatement." Asbestos is most often found in floor tiles and pipe insulation in buildings constructed before 1980.
Although the revised regulations, which took effect Oct. 1, require Emory to post notices at building entrances regarding the condition and location of asbestos within the building, Lisella said that for several years Emory has made a practice of posting such notices at buildings affected by asbestos. "On every asbestos abatement project, we've pretty much plastered notices throughout the area," Lisella said. "We've found that we actually have fewer calls as a result of that advance notification than we did before we began posting the notices."
OSHA's revised asbestos regulations set forth three workplace standards concerning exposure to asbestos. Two of those standards, the General Industry Standard and the Construction Standard, apply to Emory.
*General Industry Standard: This applies to Emory facilities in which asbestos containing materials (ACM) are present, but are not undergoing renovation or construction. Under this standard, in Emory facilities that contain ACM that has been damaged to the extent that airborne asbestos levels are exceeding OSHA limits, the University must establish a compliance program to bring the airborne asbestos levels within OSHA limits, and establish enclosed regulated areas in which respirators and other protective measures are required until acceptable limits are reached.
Emory is required to: inform employees who perform housekeeping activities in areas that contain ACM and PACM (presumed asbestos containing material) of the presence and location of ACM and PACM in their area; post warning signs in regulated areas and ensure that employees understand such signs; and place warning labels on all raw materials, mixtures, scrap, waste debris and products containing asbestos fibers. The University is also required to place a label on any ACM or PACM that reads: "Danger, contains asbestos fibers, avoid creating dust, cancer and lung disease hazard." The label must be placed on the product or its container, or as close to it as reasonably possible.
*Construction Standard: This applies to all construction work including the demolition or salvage of structures where asbestos is present; removal or encapsulation of ACM; construction, alternation, repair, maintenance or renovation of structures that contain asbestos; installation of products containing asbestos; asbestos spill/emergency cleanup; and transportation, disposal, storage containment of and housekeeping activities involving asbestos, or products containing asbestos on the construction/ renovation site.
The Construction and General Industry Standards both call for signs to be posted at the entrances to mechanical rooms that employees may reasonably enter and that contain ACM or PACM. The signs must list the presence and location of the ACM/PACM and the procedures that must be followed to avoid disturbing it. Signs must also be posted at and around regulated areas. Products containing asbestos also must be labeled as such.
Mike Gladle, Asbestos Program manager in the Environmental Health and Safety Office, said that Emory's new asbestos testing laboratory in the Woodruff Memorial Building West Wing Addition has made the process of identifying asbestos in campus buildings faster and easier, although a substantial amount of testing continues to be performed by accredited labs off campus. Emory's asbestos lab is part of a larger storage and processing facility for radioactive and hazardous waste that began operating nearly a year ago. These facilities are generally regarded as being among the best of their kind in the country.
"The long-term intent of our program," Gladle said, "is to have an asbestos-free campus."
--Dan Treadaway