ERP 1 - Asbestos Competent Person Rev 0

7/28/2019 ERP 1 - Asbestos Competent Person Rev 0

1/11

ERP-1

Asbestos Competent Person Emergency Action Guidelines Rev. 0

Printed on 05/23/2009

Void after 7 days

[Insert Facility Name Here]

Emergency Procedure

ERP-1

Asbestos Competent Person Emergency Action Guidelines

Effective Date:

Reason for Change: New Procedure

Approved By: Date:

[Enter Name Here]

[Enter Title Here]

Responsible Department: [Enter Department Here]

This entire document shall be in the field during procedureperformance.

The following portions of this procedure shall be in the field

during procedure performance.

Checklist from this procedure shall be in the field during

procedure performance.

No part of this procedure is required to be in the field during

procedure performance.


2/11

ERP-1


Printed on 05/23/2009

Void after 7 days

Table of Contents

Section Page Number

1.0 Purpose .............................................................................................................. 12.0 Scope .................................................................................................................. 13.0 Responsibilities................................................................................................ 14.0 Instructions ...................................................................................................... 15.0 Definitions.........................................................................................................96.0 Records .............................................................................................................. 97.0 References......................................................................................................... 9


3/11

ERP-1


Page 1 of 9

1.0 Purpose1.1 To provide the competent person guidelines in order that emergency

response operations concerning asbestos release are found effective in

minimizing responders and employees exposure to asbestos fibers.

2.0 Scope2.1 Establishes guidelines for the following:

2.1.1 Identifying and evaluating health hazards associated with asbestosexposure.

2.1.2 Providing technical assistance to the Incident Commander to assistwith the placement of barricades to establish a regulated area

(control zone), selection of personal protective equipment, and

procedures to follow when entering / leaving the regulated area,including decontamination.

2.1.3 Setting up a decontamination station and a clean room forentering/leaving the regulated area.

2.1.4 Performing personnel and area air monitoring including calibration,surveillance, and record keeping.

3.0 Responsibilities3.1

Responsibilities common to all events are covered in C-EPP-P001.

4.0 Instructions4.1 Ensure the "Competent Person(s)" provide supervision of the asbestos clean-

up activities and assist the Incident Commander until the emergency is

stabilized. This includes but is not limited to the following:

4.1.1 Identify the asbestos hazards associated with the response activities.4.1.2 Recommend the initial location of the barricade (control zone) and

adjust the location as air-monitoring data becomes available.

4.1.3 Determine the requirements for personal protective equipment afterthe emergency has been stabilized.

4.1.4 Determine which (if any) employees were exposed to airborneasbestos fibers and to what extent decontamination is necessary.


4/11

ERP-1


Page 2 of 9

4.1.5 Set up decontamination station. Provide instructions/procedures tobe used to decontaminate affected employees and assure that all

employees leaving the regulated area follow established procedures.

4.1.6 Set up "clean room" and assure that all employees who enter theregulated area are properly equipped and trained.

4.1.7 Conduct air-monitoring: The competent person has the overallresponsibility for calibrating equipment, recording information and

supervising any and all personnel air-monitoring required under

OSHA regulation 29 CFR 1926.1101.

4.2 Identify and Evaluate Health Hazards.4.2.1 Determine the extent and level of asbestos contamination. Obtain

directly or indirectly information concerning the damage to the

asbestos material and evidence of potential exposure conditions.Below is a partial list of considerations:

4.2.1.1 Physical damage: Verify that the material in question isasbestos. Any suspect material should be assumed to be

asbestos and treated accordingly unless there is evidence

that it is non-asbestos material.

A. Quantity of material that was damaged and disturbed.The more material missing/broken/exposed/etc., the

greater the health-hazard.

B. Extent of visible emissions: Dust in the air, onsurfaces, and small pieces of material indicate

airborne emissions. The greater the area, the greater

the health-hazard.

4.2.1.2 Friable vs. non-friable: Insulation systems that arehighly friable will create a more hazardous condition than

non-friable material.

4.2.1.3 Asbestos content of material: Generally, the higher theconcentration of asbestos the more hazardous theresulting condition. Asbestos content of the damaged

material can be determined by bulk sampling or

reviewing previous sampling results of similar insulation

systems.


5/11

ERP-1


Page 3 of 9

4.2.2 Determine the affected areas: The areas affected can be limited byprompt action in the first moments of response. Shutting HVAC

systems down, closing doors, etc. will greatly reduce the areas that

are affected. Below is a list of considerations for determining which

areas may be considered to be a health hazard:

4.2.2.1 Common air space, without walls, floors and ceilings, acontinuous area should be considered contaminated.

4.2.2.2 Common HVAC system: Any area that is supplied withcontaminated air should be considered as a potential

health hazard. The longer the contamination is allowed

to enter the area, the greater the health risks.

4.2.2.3 Traffic through area: If response personnel and/orcontaminated employees used an area as an evacuation

route, the area should be evaluated and considered apotential health hazard.

4.3 Selection of Personnel Protective Equipment4.3.1 Initial response - Level II and Level III: The emergency response

team will perform initial actions in full bunker gear and SCBAs.

Until air-monitoring data is available, all employees entering an area

with an "unknown" level of exposure should be equipped with SCBAs.

Note 1.0Incidental or incipient response (Level I) will be performed in accordance withnormal asbestos exposure control procedures.

4.3.2 Known exposure levels: Air-monitoring should begin immediatelyand should be processed as soon as possible to determine

concentration levels.

4.3.3 Respiratory selection should be based upon these results. Thefollowing table indicates the proper respirator to use based upon

concentration and time required to be in the regulated area:


6/11

ERP-1


Page 4 of 9

Maximum

Concentration

8 hr shift

Maximum

Concentration

16 hr shift

Minimum

Respiratory

Requirements

1 f/cc 0.05 f/cc Negative pressure

respirator.

10 f/cc 5 f/cc Any PAPR

Type "C" Operated in

Continuous Flow Mode

100 f/cc 50 f/cc Supplied air respirator

operated in pressure

demand mode

Unknown

or greater than 100 f/cc

Unknown

or greater

than 50 f/cc

Self Contained

Breathing Apparatus

SCBA

4.3.4 Protective Clothing: The emergency response team will be in fullbunker gear. This clothing will need to be de-contaminated but is

considered satisfactory for initial response. Once the emergency has

been stabilized, any employee entering the regulated area should don

a complete asbestos suit (tyvek full body, hood, booties and gloves).

See Asbestos Clean-up Procedure in the Asbestos Management Plan

for post emergency response and additional information.

4.4 Decontamination4.4.1 Decontamination of Evacuated Personnel

4.4.1.1 Determine if employees had an exposure to friable,airborne asbestos fibers. If so, it will be necessary to

decontaminate the employees. The competent person will

have to determine the best method for decontamination

based on the employee's exposure, available facilities and

equipment and the feasibility of each possible method.

Several methods of decontamination are feasible.

A. Set up a portable shower and change room in a cleanarea contiguous to the contaminated area.


7/11

ERP-1


Page 5 of 9

Note 2.0A good faith effort should be made to capture or filter contaminated water.

However, in the initial phase of the emergency response, it may be necessary to

utilize makeshift facilities without filtration. The use of a 1-micron filter sock in

the drain should be considered.

B. Have employees don a tyvek suit over theircontaminated clothing and report to a remote

shower/decontamination station.

Note 3.0If possible, utilize an asbestos portable shower equipped with filtration. If normal

facilities are used, arrange to have the shower room decontaminated after use. It

may be advantageous to use a smaller shower area on site (i.e., women's locker

room, supervisor shower room, etc.)

C. HEPA vacuum outer clothing and hair. Instructemployee to shower at home immediately upon arrival

and launder or bag and dispose of clothing.

Note 4.0The following option should only be considered in the event that HEPA vacuums,

and/or showers are not available/feasible.

D. Have employees remove and bag clothing. Wet-wipeface, hands and exposed areas. Don a tyvek suit to

wear to another facility or home. Wet hair, apply hair

spray or don a hood. Instruct employee to remove

tyvek suit in a running shower, shampoo hair and bag

tyvek suit for proper disposal.

4.4.2 Decontamination of Response Team Personnel: The EmergencyResponse Team will decontaminate in accordance with the

instructions given by the Emergency Response Team Leader.

4.4.3 Decontamination of Clean-Up Crews: Once all employees have beenevacuated and the emergency has been stabilized, the competent

person should set up a clean room and decontamination station foruse by personnel required to enter the area for evaluation and clean-

up activities. This is considered post-emergency response. The

decontamination facility should conform to all applicable EPA and

OSHA regulations. If necessary, acquire equipment or hire a

contractor to provide a portable "Decon" unit.


8/11

ERP-1


Page 6 of 9

4.5 Air Monitoring For Asbestos Emergency Activities4.5.1 All emergency response operations should be monitored unless self-

contained breathing apparatuses are used for respiratory protection.

4.5.2

Air monitoring results will be used to accurately place the controlzones at a distance that will assure employees are not exposed to

concentrations of asbestos above the action level.

4.5.3 Emergency Response in an asbestos environment is a uniqueprocedure and will be listed as "other" in the work description for air

monitoring data.

4.5.4 Select one employee involved in each major activity for personal airmonitoring. Results may be used to determine the respiratory

requirements.

Note 5.0Air monitoring results may not be available until after the emergency has been

stabilized. It is possible to rush the laboratory analysis and obtain results within

hours or call an off-site non-company laboratory for emergency monitoring

assistance (Sitex Environmental).

Air monitoring data will be valuable during clean up activities and for the final

critique of the response.

4.5.5 When the emergency has been stabilized and clean-up activitiesbegin, continue to conduct personal air monitoring in accordance with

routine procedures found in the Asbestos Management Plan.

4.6 Area Sampling For Background Exposure Levels4.6.1 Area samples will be taken to provide data on the background

exposure level and to accurately place the barricade to protect

employees who are not involved in the response or clean-up effort.

Sampling will be conducted to determine exposure level for post

response operations.

4.6.2 The sample duration should be four to eight hours with a low volume(portable) pump set at 2.0 liters/minute (500 liters or more).

4.6.3 Sample pumps should be placed at breathing zone height and in thepath of any natural or forced ventilation, if possible. The location

should be documented and repeatable.


9/11

ERP-1


Page 7 of 9

4.7 Calibration4.7.1 Air Pump Calibration shall be per the manufactures instructions.4.7.2 Sampling Procedure

4.7.2.1 The unique number on Form AMDF 100 is used toidentify each sample.

4.7.2.2 Consecutively label each sample cassette with the AMDF100 number.

4.7.2.3 Each sample cassette must be sealed with tape andmarked with the unique number.

4.7.2.4 Fill out AMDF 100 Form for each person monitored.4.7.2.5 Attach pump and cassette in breathing zone of employee

(within 6 to 12 inches of nose) and remove upper cap.

4.7.2.6 Turn on pump and record start time.4.7.2.7 After completion of sampling, remove cassette and record

finish time.

Note 6.0Many air-sampling pumps are equipped with built in timers. This should be used to

compare recorded time (verifies that the pump was running continuously) and in

the event that the pump shuts off due to low battery charge.

4.7.2.8 Decontaminate all equipment by wet wiping. Dispose ofwet wipes with other asbestos waste.

4.7.2.9 Place samples in shipping box; include two (2) blanksfrom same lot as sample cassettes in each box and mark

as "blanks". Do NOT include blank on the AMDF 100

form.

4.7.2.10 Seal box; complete "Request for Asbestos Counting" form,and send the form with the samples to:

A. Sitex Environmental, Inc.B. Send original AMDF 100 and copy of the "Request for

Asbestos Counting" to Safety and Health Department.


10/11

ERP-1


Page 8 of 9

4.7.2.11 Safety and Health Department will calculate the eight (8)hour time weighted average (TWA) and prepare employee

notification form.

4.7.2.12 If the Permissible Exposure Limit (PEL) is exceeded,Safety and Health will also generate an exceedence reportto initiate an investigation of the exposure.

4.7.3 Pre-calibration shall be conducted per manufacturesrecommendation.

4.7.3.1 Post Calibration shall be conducted per manufacturesrecommendation.

4.8 Air Monitoring Results And Record Keeping4.8.1 Posting:

4.8.1.1 Personal monitoring results will be posted for a period of30 days.

4.8.1.2 The safety bulletin board designated for compliancemonitoring will be used for asbestos air monitoring

posting.

Note 7.0Area monitoring need not be posted.

4.8.2 Notification:4.8.2.1 If air-monitoring results indicate that the employee

exposure was above the PEL times (the respiratory

protection factor), the Competent Person will personally

notify the employee of the results and complete an

exceedence report including information provided by the

employee.

4.8.3 File Retention:4.8.3.1 The Safety and Health department will maintain the

original air monitoring data forms for a minimum of 30

years beyond the employees termination of employment.

4.8.3.2 Copies of all asbestos air monitoring data will be filed onsite for an indefinite period of time.

4.8.3.3 Calibration records will be maintained for one year.


11/11

ERP-1


Page 9 of 9

5.0 Definitions5.1 Definitions are provided in ERP-0, Emergency Action Plan.6.0 Records6.1 None7.0 References7.1 Ameren Management Instruction Environmental - Safety & Health: Ameren

Employee Asbestos Exposure Controls Work Practices and Reporting

Requirements, No. REG 203 Revised 2-16-96

7.2 Safety & Health Department's Air Sampling Procedures

ERP 1 - Asbestos Competent Person Rev 0

Documents

Transcript of ERP 1 - Asbestos Competent Person Rev 0