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Asbestos Floor Tile Policy

OBJECTIVE

The objective of this policy is to clarify the requirements for addressing the removal of vinyl asbestos floor tile and other asbestos containing floor coverings during renovation and remodeling projects.

POLICY

The goal of this policy is to eliminate asbestos containing materials from the University of Florida main campus and from off campus facilities as they are encountered during renovation/refurbishment projects. It has been determined that covering over asbestos flooring (e.g., vinyl asbestos tile and sheet goods) and adhesive leads to greater costs and additional time to do future projects. This has also led to confusion as to which areas never had asbestos flooring, which have asbestos flooring under another covering and which were removed prior to new covering being applied.

AUTHORITY

By authority delegated from the University President, the Vice-President for Business Affairs is responsible for the safety of all University facilities. Under this authority, policies are developed to provide a safe teaching, research, service, housing and recreational environment.

Reference
OSHA 1926.1101 (Asbestos Standard for Construction); 40 CFR Part 763 (EPA Worker Protection Rule); FAC 469 (Asbestos Practices Act)

RESPONSIBILITIES

Environmental Health and Safety
Environmental Health and Safety is responsible for administering the University’s asbestos management program and for monitoring compliance with applicable State and Federal asbestos regulations.
Departments
Project managers and supervisors are responsible for determining whether or not asbestos floor covering will be impacted by a project and, if so, arranging for its safe removal and disposal.

PROCEDURES

The presence of asbestos flooring and/or adhesives that contain asbestos must be determined at the beginning of affected projects so additional funding and time can be incorporated into the project.

Floors with existing exposed asbestos tile that are well maintained and firmly attached to the substrate may remain in service, provided that the tiles are free of broken or crumbling material. If the area is remodeled or a new floor covering is to be installed all flooring related asbestos in the affected area is to be properly removed.

If existing materials covering asbestos flooring are replaced, all materials including the asbestos flooring and adhesive, must be removed prior to installation of new material. These materials include, but are not limited to existing vinyl composition tile, glued-down carpet, or stretched carpet with pad. The costs involved in asbestos removal shall be borne by the entity that is funding the remodeling or new floor covering project.

All asbestos removal activities shall be done by appropriately licensed companies using only trained workers or by appropriately trained and certified in house staff, in concert with the Division Project Manager and Specialists from Environmental Health and Safety. All necessary safeguards required to protect the workers, University staff, students, visitors and property from asbestos exposure will be utilized during removal projects. Every effort will be made to maintain good indoor air quality conditions in the affected space when solvent based adhesive removal is conducted.

Specific Removal Requirements
The removal of asbestos containing floor tile will typically be completed by following the OSHA requirements for removing a Class 2 material. When traditional abatement methods are used, air monitoring and final clearance sampling are required. The removal of asbestos floor tile using the heat method can be used without the need for air monitoring but only if the tile is removed intact, which means as close to in one piece as practical, and as long as the work practices published by the Resilient Floor Covering Institute (RFCI) are followed to the letter.

The use of the RFCI method to remove asbestos flooring is subject to EH&S approval on a case by case basis. Adequate time should be allowed prior to the start of a project to allow for EH&S review. The submittal of an APNF is still required.

The removal of carpet to provide access to asbestos floor tile can be done with no restrictions as long as it can be removed without pulling up or breaking floor tile. A couple of tiles coming up is typical and is acceptable but if large sections of tile come up, work must stop and the area must be placed under a negative pressure containment before removal can continue. Air monitoring will be required.

In situations where asbestos floor tile has been removed previously and carpet has been glued down over the original black asbestos containing mastic, the removal of that carpet from the floor must be done by an abatement contractor within a negative pressure enclosure. Removal of the mastic in these instances must also be conducted within a negative pressure enclosure and air monitoring must be provided.

Whenever practical, exhaust ventilation shall be provided during the course of asbestos floor tile and mastic removal activities, regardless of the methods used. If the location of an abatement project prevents the discharge of work area exhaust directly to the exterior of a building, EH&S must review and approve the work plan prior to the start of the project and air monitoring by an asbestos consultant will be required during asbestos removal activities.