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Letter of agreement: Cement asbestos water pipe repair

Background

cross section view of a concrete water pipeHistorical monitoring of asbestos exposure during various repair operations on cement-asbestos water pipes shows that, when specific work practices are followed, workers do not experience measurable levels of airborne asbestos. This letter of agreement is based on these specific work practices and historical monitoring data, along with training, to exempt water district employers from the need to conduct air monitoring while repairing cement-asbestos water pipes. However, other Class III asbestos regulations must still be followed.

If you have questions about Oregon OSHA requirements, please contact our technical section at 503-378-3272, tech.web@dcbs.oregon.gov, or Online contact form.

Documents

Letter of Agreement Template

Today's Date

Gretchen Hall-Wunderlich, Standards and Technical Manager
Oregon OSHA
PO Box 14480
Salem, OR 97309-0405

RE: Letter of Agreement

ENTITY NAME agrees to participate in this Letter of Agreement with Oregon OSHA regarding repair of non-friable asbestos-containing water-pipe under the requirements of OAR 437-003-1926.1101, “Asbestos."

We understand that asbestos-containing (AC) water-pipe repair is classified as Class III asbestos work under the Oregon OSHA Asbestos standard. One of the requirements of Class III asbestos work is initial air monitoring to determine the appropriate level of protection. However, past air monitoring in a variety of situations has shown that airborne levels of asbestos do not approach nor exceed the airborne permissible exposure limits when appropriate work practices are followed. The Portland Water Bureau submitted supportive documents and air monitoring results to Oregon. (Note: this document should be reviewed by the participant.) The document is available on Oregon OSHA's Website or from Portland Water Bureau and is listed as Appendix A.

We agree to comply with and use only the work practices outlined in the ENTITY NAME “Standard Operating Procedures for Working with AC Pipe" included herein as Appendix B.

We agree to establish a program that identifies who the Competent Person is, training responsibilities, work procedures to be used, safety equipment, respiratory protection when employees request them, all other necessary personal protective equipment (PPE), procedures to establish a regulated area or “controlled zone" when asbestos-cement pipe is removed, and procedures for disposal and decontamination. Our designated Competent Person is responsible for this program and ensures that we comply with all components of this program. The Competent Person is defined as: one who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure, who has the authority to take prompt corrective measures to eliminate them, as specified in 1926.32(f).

All employees working with AC pipe will be trained at least in accordance with Class III asbestos type work and allows for the Competent Person to design a training program that meets 1926.1101(k)(9)(viii). However, certain parts of 1926.1101(k)(9)(viii) are not applicable to working with non-friable water pipe. Below is the modified training that will be provided to all employees performing this work:

  1. Methods of recognizing asbestos;
  2. The health effects associated with asbestos exposure;
  3. The relationship between smoking and asbestos in producing lung cancer;
  4. The nature of operations that could result in exposure to asbestos, the importance of necessary protective controls to minimize exposure including, as applicable, engineering controls, work practices, respirators, housekeeping procedures, hygiene facilities, protective clothing, decontamination procedures, emergency procedures, and waste disposal procedures, and any necessary instruction in the use of these controls and procedures;
  5. The purpose, proper use, fitting instructions, and limitations of respirators as required by OAR 437-002-1910.134; (testing results indicate that Respiratory Protection is not necessary, but is available for voluntary use)
  6. The appropriate work practices for performing the asbestos job;
  7. Medical surveillance program requirements;
  8. The content of OAR 437-003-1926.1101, including appendices;
  9. The names, addresses and phone numbers of public health organizations which provide information, materials and/or conduct programs concerning smoking cessation. The employer may distribute the list of such organizations contained in Appendix J to this section, to comply with this requirement; and
  10. The requirements for posting signs and affixing labels and the meaning of the required legends for such signs and labels.

All training will include hands-on training for the work practices used. Because working with AC pipe is rare and cannot be anticipated, work conditions may be simulated

AC pipe work will require a pre job planning checklist and post job debriefing to ensure procedures and practices were followed and any deviation discussed and resolved.

AC pipe jobs will be periodically visited by the supervisor and/or Safety Manager to ensure that work practices are followed, and a mechanism will be in place for employees to report problems to the Competent Person, their supervisor, and/or Safety Office.

We agree to follow all other requirements of OAR 437-003-1926.1101 for work operations that occur outside the scope of this letter of agreement.

I have read, understand and agree to abide by the provisions of this Letter of Agreement.

CONTACT NAME AND TITLE ________________________________ Date __________

Oregon OSHA Signature ________________________________ Date __________

The above-signed affirm that they have authority to enter into this Letter of Agreement on behalf of the ENTITY NAME and Oregon OSHA.

 

Please send signed agreement on letterhead. You will receive a signed paper copy for your files. If you have questions, please contact Gretchen Hall-Wunderlich, Standards and Technical Manager, at 503-507-5529.



Standard Operating Procedures for Working with Asbestos Cement Pipe

ENTITY NAME

"Standard Operating Procedures for Working with Asbestos Cement Pipe"

A. PURPOSE:

ENTITY NAME places the highest value on employee safety. Being consistent in providing a safe and healthy workplace for all employees and to help make fieldwork as safe as possible, the following safe work procedures have been developed for repairing Asbestos-Cement pipe.

These procedures will assist ENTITY NAME to establish itself as a leader in our community and the water industry by providing our employees with training and equipment to protect themselves from hazards and injuries. Once hazards are identified and evaluated, every effort will be made to eliminate or control them through engineering or administrative measures. Good design and engineering practices will be used to eliminate or reduce hazards in the design of facilities and projects. But when hazards cannot be eliminated, Personal Protective Equipment (PPE) will be required.

This policy defines the use of appropriate work practices and PPE necessary to protect employees from hazards associated with working with Asbestos-Cement (AC ) pipe.

All employees – managers, supervisors and staff – are responsible for the success of this policy and will be held accountable for deviations. Both Labor and Management are dedicated to promoting safe work and safe job sites. Any violation of the policy will be subject to progressive disciplinary action, up to and including termination of employment.

B. SCOPE:

Repair work involving disturbing and/or removal, of AC Pipe must follow the outlined safety procedures. This procedure applies to Water Utilities crews and contractors. No methods can be used that intentionally cause AC pipe to shatter, crumble, be pulverized, or release asbestos fibers. This means that we are not permitted to sand, power saw, grind, chip or use power tools on AC pipe.  By following these methods, DEQ asbestos abatement contractor and worker certification are not required.

C. RESPONSIBILITIES

  1. ENTITY NAME will provide support and commitment to furnish affected employees with the appropriate training and equipment to protect themselves from known hazards working with and around AC pipe. Whenever possible, ENTITY NAME will attempt to eliminate hazards of AC pipe by means of engineering controls and design.
  2. The Safety Staff will provide and document all training and education for employees; and provide Supervisors with assistance and support in the administration and maintenance of the program.
  3. The Managers and Supervisors will ensure that these procedures are implemented and ensure compliance within their respective departments and crews. They will also ensure that all equipment necessary for AC pipe work is available and in use whenever working with AC pipe.
  4. The Employee is responsible for following the procedures, including utilizing training and equipment provided. Employees who violate this policy will be subject to disciplinary action.
  5. Competent Person is capable of identifying existing and predictable hazards in the surroundings or work conditions which are unsanitary, hazardous, or dangerous to employees and has the authority to take prompt corrective measures to eliminate them.

NOTE: It is important to note that the work practices and conditions describe in the policy must exist and be maintained at all times. If there are any deviations in conditions, practices or procedures outside the scope of the policy, a Competent Person must have a higher level of skills and training as outlined in OSHA's 1926.1101 Asbestos Standards and the EPAs 40 CFR 763.92

D. TRAINING

  1. All employees involved in AC pipe work must be Asbestos Awareness Trained (See attached power point presentation) that meets Oregon OSHA Asbestos Standard 1926.110(k)(9(viii).  The training will include this safe work procedure.
  2. Training will be refreshed at least annually or as needed.
  3. All training and refresher sessions will be documented. Documentation will be filed with ENTITY NAME Safety File system.
  4. For the purpose of these Safe Work Practices, the training module attached will be deemed adequate.

E. SAFETY PROCEDURES:

  1. Wet methods will be used to prevent release of airborne asbestos fibers. This requires use of a garden type sprayer with water to be used prior and during all work in AC pipe.  The pipe exterior will be sprayed down prior to and during removal or repair work.

  2. No power tools will be used on AC pipe. Only various approved hand tools will be used.
  3. Approved tools:
    1. Snap cutters (“squeeze-and pop" equipment) operate by means of cutting wheels mounted in a chair wrapper around the pipe barrel. Hydraulic pressure, applied by means of a remote, pneumatically, or manually operated pump, squeezes the cutting wheel into the pipe wall unit the cut is made. This type of cutting with water sprayed minimizes the release of asbestos fibers.
    2. Roll cutters that cut the pipe as the cutting edge of the rollers are tightened down as pressure is applied manually to the cutters as they circle the pipe. This type of cutting with water sprayed on the pipe minimizes the release of any asbestos fibers. Cutting wheels are wiped before use to remove any lubricant that might bond with any fibers and wiped cleaned after use.
    3. Wet Tapping AC Pressure Pipe for service connects is performed in the trench while the pipe is under pressure. The equipment is affixed to the pipe by means of a chain yoke.  A combination boring-and-inserting bar drills and taps the pipe wall and inserts a corporation stop or pipe plug. The pressure chamber, which protects against water leakage, also catches the asbestos-cement chips, so this is essentially a dust-free operation. To minimize fouling of valves, regulators, meters, and other equipment with chips or unnecessary addition of asbestos to drinking water a positive purge or blow-off features should be used on the equipment. (NOTE: There will be no dry AC pipe tapping as only non-A.C pipe is used for new installation or repair). Bolts for all fittings and sleeves should be placed so the nuts are on the non-asbestos side of the pipe, which prevents the AC pipe from being, rubbed by the wrenching and tightening of the bolts.
    4. Bristle Brush to smooth cutting surface may be used only with copious water spray to suppress any dust.
    5. Use of Cold Chisel and Hammer to remove coupling from AC pipe: When possible, the intact section would be removed not requiring a coupler to be removed but this is not always possible. AC coupling removal must be done by gradually splitting the coupling lengthwise using a chisel and hammer. After the coupler has been split a crowbar or similar tool is used as a lever to split the bottom of the coupling.  The pieces must be bagged in asbestos disposal bag(s).
      There are varieties of other fittings that are used to insert the ductile iron pipe, including various pressure collars, which do not result in damage to the AC pipe.
    6. Safety Equipment: The AC pipe safety equipment will be available from the NAME STORAGE PLACE before heading to the AC pipe work site. The equipment must include a laminated copy of this SOP, gloves, safety glasses, ear plugs, appropriate polypropylene suits,  towels, hand cleaner, yellow disposal bags, clear disposal bags, duct tape, flash light, warning signs and barrier tape.
  4. Required Personal Protective Equipment:
    1. Employee personal protective clothing: To further safeguard our employees' the following PPE is required:
      • Polypropylene or disposable coveralls appropriate for the hazard
      • Rubber boots
      • Gloves with plastic cover hands and canvas back will be worn when working with AC pipe
      • Safety Glasses
      • While testing has shown that proper procedures do not result in any detectable fiber exposure employees have the option of wearing the N-100 disposable dust masks. Since exposure to asbestos occurs primarily through inhalation, the use of respiratory protection is strongly recommended.
      2. NOTE: The use of disposable dust masks (N-100) is NOT an acceptable practice under the OR-OSHA Asbestos Standard (1926.1101). Air-purifying respirators equipped with N-100 cartridges are acceptable.  While these procedures recognize airborne exposure to asbestos fibers from non-friable asbestos cement pipe would not pose a hazard, a best practice is to avoid using disposable dust masks (filtering facepieces) and to use air-purifying respiratory protection, even for voluntary use.
    2. The rubber gloves will have the tops rolled out 1 – 1 ½" to form a cuff that can catch drips, etc. that might normally land on a body part.
    3. The coveralls will be secured and sealed to the ankles and wrists by applying duct tape at the cuffs if necessary.
  5. Establish a "Controlled Zone"
    1. A “Controlled Zone" will be established for all work involving AC pipe. The following are guidelines for establishing and maintaining a “Controlled Zone".
      1. Establish a perimeter 5 – 10 feet back from the leading edge of any excavation, hole or trench.
      2. Set cones or barricades strategically around the perimeter.
      3. Thread "Danger Tape" around the perimeter and attached to the cones or barricades.
      4. Set the "Authorized Personnel Only" signs around the outside of the "Controlled Zone".
      5. Only authorized and properly outfitted personnel may enter the “Controlled Zone".
      6. Any person and any equipment leaving the "Controlled Zone" must be subjected to decontamination as defined further in this document.
  6. Disposal and Decontamination procedures
    1. The Snap or Roll Cutter tool should be cleaned prior to use to reduce asbestos cement debris which could build-up on the blades during cutting
    2. All removed AC pipe and debris will be wetted down, collected, and placed in asbestos disposal bags. They will be taken to the asbestos disposal area at the main shop.
    3. All tools that have been used to remove AC pipe must be wiped clean of debris with disposable cloths while still inside the "Controlled Zone". The cloths will be placed in Asbestos disposal bags and the bags will be sealed as defined above.
    4. The disposable coveralls and rubber gloves will be placed into the asbestos disposal bag while the workers are still inside the "Controlled Zone".
    5. Rubber boots must be washed off removing dirt and debris while in the excavation with the garden sprayer.
    6. Proper bagging will consist of placing the AC pipe and debris in a yellow hazardous waste bag and duct taping the top of the bag to seal it. The yellow bag will then be placed inside a clear disposal bag to ensure double-bagging can be verified. The 2nd bag must also have the top sealed with duct tape to ensure a seal.
    7. Waterless hand cleaners and water will be available for employee's hand and face cleaning after removing the Personal Protective Equipment.
    8. Once wiped clean, clean Snap or Roll Cutter and all other tools used at the shop and restocked on the crew vehicles.
  7. Periodic Air Re-monitoring
    • If there are needed changes to work procedures or the condition of AC pipe is friable and unstable, work must cease immediately and all provisions of 1926.1101 apply. A Competent Person as defined by the Asbestos Standard must re-evaluate the situation to determine what actions are necessary, including air monitoring, respiratory protection, training, or any other required actions.Re-monitoring will be done when the Competent Person has reason to believe that there has been a change in the operation, which could affect airborne exposure.
  8. Safe Work Procedure Checklist
  • The Supervisor and crew mechanic will use, follow and document safe work procedures on a checklist (attached). Notification to the Safety Office so that Key Performance Indicators can be verified.
    1. Identifying potential AC pipe work needs prior to job site work.  This allows crew to ensure they have right equipment and procedures for working on AC pipe.
    2. Ensuring that crew has been asbestos awareness trained
    3. Assembling basic protective equipment and tools, which is in good repair and clean:
      • Disposable coveralls
      • Rubber boots
      • Rubber gloves
      • Safety glasses
      • Proper working order and clean tools including Snap or Roll cutters wiped before and after use to reduce and remove any fibers that may be on the cutters.
      • Ensure all clean tools are available
    4. Assembling Control Equipment
      • Garden sprayer with adequate supply of water
      • Large wipes for cleaning tools and equipment
      • Asbestos Disposable Bags and duct tape
      • Waterless hand cleaners
      • Warning signs
      • Barrier tape

DOCUMENTATION:

  • All training, refresher sessions, checklists and annual reviews or audits will be documented. Documentation will be filed with the ENTITY NAME Safety File system.

G. KEY PERFORMANCE INDICATORS:

  1. Documentation of training, checklists and audits or reviews.
  2. Field audits during actual operations.

H. AUDITS AND REVIEWS

  1. Field audits by the safety office or the supervisor will be conducted as opportunities present themselves using the utilizing the established jobsite inspection program.
  2. Conduct SOP reviews whenever there is reason to believe or field audits indicate that there is a need to review and/or revise this SOP because of observed deviations and violations of this SOP.
  3. Supervisors and safety staff are readily available to address employee concerns, questions, and/or assist with work activities

I. ATTACHMENTS

Safe Work Procedure Checklist

SAFE WORK PROCEDURE CHECKLIST

The crew mechanic or the district supervisor will ensure this checklist is reviewed and completed before any work involving AC pipe commences. This checklist must be fully completed, signed and dated. The completed checklist will be forwarded to the ENTITY NAME Risk Specialist.

Training

  • All crew members have been trained to the SOP for AC pipe work. __Yes __No

Equipment

__ Roll cutters or similar tool

__ Waterless hand cleaners

__ Garden sprayer with adequate supply of water

__ Large wipes for cleaning tools and and equipment

__ Asbestos Disposal Bags and duct tape(yellow and clear bags)

__ Asbestos warning signs

__ Asbestos barrier tape

__ Hooded Tyvek disposable coveralls

__ Rubber boots

__ Laminated SOP

__ Rubber gloves

__ Safety glasses

__ N100 filtering face pieces

__ Pipe, collars, specific tools etc. required for the repair

By my signature, I verify that all the items above are on site or have been reviewed or verified.

Crew mechanic or supervisor print name __________________________________________

Address or site of work: _______________________________________________________

Date work conducted: _______________