AHERA 

Operations and Maintenance Program

Elements of an O&M Program


The overall frame work for an asbestos O&M program is described in the EPA guidance document Managing Asbestos in Place (Green Book)”.  Operationally, asbestos O&M program consists of administrative procedures, which cause specific work, practices to be used for maintenance work on asbestos-containing materials (ACM).  This manual contains suggestions for work practices to be used in such an O&M program.  To insure that the work practices are applied as intended it is necessary to set up an administrative framework.  This framework need not be complex.  In fact, the more simple and straightforward the administration of the program, the more likely it is that it will perform reliably. There are several elements necessary for a successful asbestos O&M program.  


Definition of Scope Before the program can begin, the type, locations and condition of ACM to be controlled by the program must be determined.  This can be accomplished by an inspection, or by presuming that all materials suspected of containing asbestos are indeed asbestos containing.  Unless an inspection is performed and the materials are determined not to contain asbestos, OSHA requires that all thermal system insulation, sprayed or troweled on surfacing materials, and resilient flooring material installed no later than 1980 be presumed to contain asbestos.  In addition, OSHA requires that materials known to contain asbestos, or that should have been known by exercise of due diligence, also be identified.  The Asbestos School Hazard Abatement Reauthorization Act (ASHARA) requires that an EPA-accredited asbestos inspector perform all inspections of commercial and industrial buildings as well as schools.  (The accredited inspector requirement does not apply to visual or physical examinations of resilient floor covering material when conducted as part of the process of replacing an existing floor where the material has not been sanded, ground, mechanically chipped, drilled, abraded or cut.)  The first step in the initiation of an asbestos O&M programs is the preparation of an inventory of ACM or presumed asbestos-containing materials (PACM).  


Policy and Organization  To insure success, there needs to be a formal decision at the topmost level of management adopting the asbestos O&M program as a matter of policy.  This gives the program legitimacy within the organization and insures that the asbestos program manager (APM) will be given adequate authority to implement the program.  A specific administrative position must be given the responsibility for the asbestos O&M program.  It is best if this position already has the authority necessary to implement the program.  This position must have effective control over activities that could impact on the ACM in the facility.  At a minimum, this position needs to have control over internal maintenance and cleaning personnel, outside maintenance contractors and renovation projects.  In most organizations this person is the head of buildings and grounds or the facilities manager.  Otherwise well-conceived control programs have failed because the administrative position implementing them had inadequate authority.  This most typically occurs when the safety department is given the responsibility, but not given adequate authority.