The university is subject to regulations necessary to protect workers, the public, and the environment from hazardous building materials such as asbestos and lead when they are disturbed during maintenance and remodeling activities. The university utilizes a uniform purchasing order method for abatement services and the EHS Abatement Program maintains oversight to assure university abatement projects are conducted safely and meet regulatory notification, recording keeping, and certification requirements.
Contact
Chris Heidel
Hazardous Building Material
christopher.heidel@wisc.edu
Karl Stelzer
Occupational Safety
karl.stelzer@wisc.edu
How does this process work?
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Plan ahead!
Abatement is frequently the first work needed before other work can proceed. The further in advance abatement work can be requested and scheduled the better.
Material Identification Overview
An early step in project planning is material sampling and laboratory analysis. The sampling can be done by certified EHS staff without charge to most university departments. EHS Abatement Program staff must collect and document the sampling and cannot be provided with sample. EHS will have a certified laboratory analyze asbestos samples they collect, at no cost to most university departments. EHS also may provide sampling of coatings for lead (Pb) analysis by a direct reading instrument or bulk/chip sample analysis. Prior to testing, the requesting department needs to define the scope of work, so testing can be limited to what is needed. Asbestos testing and some lead samplings require collecting representative samples for lab analysis and may involve a destructive process which remove some of the material for lab analysis. Laboratory analysis of samples under normal processing may take up to 10 workdays and 5 workdays should be anticipated for of sample collection and shipping.
Abatement Project Overview
Prior to requesting an abatement project, the requesting department must provide an accurate scope for the abatement work being requested. Many projects involving asbestos abatement require the contractor to file regulatory notifications up to 10 working days in advance of beginning work, so up to four weeks advance notice may be needed for some projects in addition to the time need to have materials tested. Two weeks is the minimum necessary to process routine requests for an abatement and have the project scheduled with a contractor.. Advanced planning helps get a project on an abatement contractor’s schedule, especially during seasonal busy periods. Keeping in communication with your project manager and abatement team contacts to understand the time frame of your project is encouraged.
Emergency Work involving asbestos removal may be authorized to proceed by EHS if asbestos is being released or release is imminent due to unforeseen circumstances, work is needed to stabilize the site, to protect people, and to prevent further release of asbestos. Regulators do not accept poor planning or cost factors as acceptable reasons for filing emergency regulatory project notifications.
Requesting Abatement Services
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What process will be used to order abatement work under the University’s Purchasing Contract?
All project requests for university abatement services will be processed through the Facilities Planning and Management Division’s web-based work order tracking system called Asset Works. This system is managed through the Customer Service Department at the Physical Plant.
What information is needed to create an Asset Works abatement work order?
If a project is small, it may be cost effective to presume the material to be disturbed contains asbestos and request a work order for abatement. On larger projects the cost of abatement may be reduced by testing materials to demonstrate that they do not contain asbestos or lead and do not require removal as a hazardous building material. Staff in the EHS Hazardous Building Material Abatement Program may be consulted about the need to test materials and when presuming them to be asbestos can be cost effective. (Note: building materials must never be presumed to be free of asbestos and are considered to contain asbestos until valid testing proves they are asbestos free). All sampling and test result interpretations must be done by personnel having a current Department of Health certification and laboratory analysis must be done by an accredited laboratory.
To make a request for assessment or abatement, the description and scope of work must be defined in detail. Providing pictures of the materials to be assessed and/or abated and exact descriptions of the locations within rooms will help expedite processing of the requests. If pipe insulation or tank insulation needs to be tested or abated, mark the materials with red or blue spray paint (red for steam and blue for plumbing). This aids the abatement contractor in understanding what material needs to be removed when they arrive at the worksite.
Create the work order in Asset Works
When a work order is entered it should include an uploaded copy of the Hazardous Building Material (HBM) Assessment and Abatement Request Form. After the work request is made, customers are encouraged to call the EHS Abatement Program Coordinator to discuss how the project will progress. When EHS has assessment results they will be communicated to the contact indicated on the work order. Similarly, EHS will keep the work order contact advised when an abatement contractor has been scheduled to conduct the requested abatement work phase. When abatement work is conducted EHS will monitor the abatement at critical points to help assure the work is done safely, and document site survey visits including authorization to begin abatement and authorizing the contractor to remove environmental controls after final inspection is satisfactory. Once work is completed the department requesting the work should also have a representative review the project to ensure the work done has met what was requested. When the contractor invoices for the completed work the invoice will be reviewed by FPM Purchasing, and the abatement contractor’s submittals will be approved and retained by EHS. If the requesting department has any concerns about the project, they need to inform FPM Purchasing and EHS Abatement contacts as soon as possible after the abatement work has been completed.
Abatement Project Process Summary
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Project Assessment Phase
Determine the scope of work and what building materials will be disturbed.
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- Proceed directly to “abatement phase” if amount of work is small and no assessment is desired
- Request a detailed EHS “Assessment Phase” be added to a work order in Asset Works (Physical Plant Customer Service: 263-3333)
- Include an assessment request form with the work order
- Direct follow up communication with EHS is encouraged to assure vital information is conveyed and to assure assessment is progressing
- EHS will change the work order phase from “new” to “assigned” upon receipt
- EHS will review any prior records and provide the requesting department contact with material information if available
- If sampling and testing is conducted, once sampling is complete and laboratory analysis has been reported, the requesting department contact will be notified of the test results.
- If at any time during the project a material which has not been identified is discovered and may be disturbed, work needs to be stopped, EHS notified, and a hazard assessment conducted
Project Abatement Phase
Determine the scope of abatement needed based upon bulk sample results, EHS provided data, or Presumed Asbestos Containing Material (PACM)
- Request a detailed EHS “Abatement Phase” be added to a work order in Asset Works (Physical Plant Customer Service: 263-3333)
- Direct follow up communication with EHS is encouraged to assure vital information is conveyed and to assure assessment is progressing
- EHS will make arrangements with the abatement company keeping all stakeholders informed with a notice to proceed directed to the abatement contractor and providing oversight of the abatement work
- EHS will inform the requesting department contacts when the abatement work has been completed.
- The requesting department should review the worksite after notification that the abatement work has been completed.
- Physical Plant Purchasing will review the abatement contractor’s invoices and EHS Abatement will verify abatement was completed, and receipt of required submittals needed to authorize invoice payment.
- EHS will maintain abatement related records and update the abatement phase as shop done when abatement work is complete.