Asbestos Management

Policy Statement

It is the policy of the City of Toronto to:

eliminate, or minimize to the extent possible, the potential for worker and tenant exposure to airborne asbestos fibres, thereby protecting their health, and
maintain compliance with legislative requirements by appropriately managing asbestos in buildings on an ongoing basis as well as during any construction and renovation work that may potentially disturb any asbestos-containing material.

Application

This policy applies at all City-owned or leased facilities at which asbestos-containing materials are, or may be, present.

Specifically, it outlines owner responsibilities for implementing and maintaining asbestos management programs in every building with material which may contain asbestos. During construction projects, it outlines responsibilities of the constructor, every employer and workers engaged in or on the project, as well as responsibilities of the owner of the project. During repair, alteration, maintenance or demolition of a building, it outlines responsibilities of all workers and employers involved, as well as, responsibilities of the owner.

Definitions

Asbestos

Any of the following fibrous silicates: actinolite, amosite, anthophyllite, chrysotile, crocidolite or tremolite. Asbestos is most commonly found in sprayed-on insulation or fireproofing, fibrous or corrugated paper pipe insulation, cement pipe, drywall and drywall joint compound, floor and ceiling tiles.

Asbestos-containing material

Material that contains 0.5% or more asbestos by dry weight.

Building

Means any structure, vault, chamber or tunnel including, without limitation, the electrical, plumbing, heating and air handling equipment (including rigid duct work) of the structure, vault, chamber or tunnel.

Building asbestos record

A document that details the current location (by room, hallway, stairwell, etc.), type, condition and whether material is friable or non-friable of asbestos-containing material(s) in a facility, as well as associated inspection and repair records.

Building asbestos assessment and report

A document (showing material likely to be handled, disturbed or removed during demolition, alteration or repair work, whether or not material is asbestos-containing material, its condition, whether friable or non-friable and drawings, plans and specifications showing location of material in question) that is prepared in addition to the building asbestos record and provided to prospective contractors prior to asking for tenders.

Friable material

Material that when dry can be crumbled, pulverized, or powdered by hand pressure and any material which is crumbled, pulverized or powdered. It is important to recognize that damage or deterioration may cause non-friable material to become friable.

Competent person

An individual meeting the definition of “competent person” under the Occupational Health and Safety Act. It means a worker who,

is qualified because of knowledge, training and experience to perform the work,
is familiar with the Act and with the provisions of the regulations that apply to the work, and
has knowledge of all potential or actual danger to heath or safety in the work.

HEPA filter

A high efficiency particulate aerosol filter that is at least 99.97% efficient in collecting a 0.3 aerosol.

Homogenous material

Material that is uniform in colour and texture.

Owner

Includes a trustee, receiver, mortgagee in possession, tenant, lessee, or occupier of any lands or premises used or to be used as a workplace, and a person who acts for or on behalf of an owner as an agent or delegate.

Type 1 operations

Installing or removing ceiling tiles that are asbestos-containing if the tiles cover an area less than 7.5 square metres and are installed or removed without being broken, cut, drilled, abraded, ground, sanded or vibrated.

Installing or removing non-friable asbestos-containing material, other than ceiling tiles, if the material is installed or removed without being broken, cut, drilled, abraded, ground, sanded or vibrated.

Breaking, cutting, drilling, abrading, grinding, sanding or vibrating non-friable asbestos-containing material if the material is wetted to control the spread of dust or fibres and the work is done only by means of non-powered hand-held tools.

Removing less than one square metre of drywall in which joint filling compounds that are asbestos-containing material have been used.

Type 2 operations

Removing all or part of a false ceiling to obtain access to a work area, if asbestos-containing material is likely to be lying on the surface of the false ceiling.

Removal or disturbance of one square metre or less of friable asbestos-containing material during the repair, alteration, maintenance or demolition of all or part of machinery or equipment or a building, aircraft, locomotive, railway car, vehicle or ship.

Enclosing friable asbestos-containing material.

Applying tape or a sealant or other covering to pipe or boiler insulation that is asbestos-containing material.

Installing or removing ceiling tiles that are asbestos-containing material, if the tiles cover an area of 7.5 square metres or more and are installed or removed without being broken, cut, drilled, abraded, ground, sanded or vibrated.

Breaking, cutting, drilling, abrading, grinding, sanding or vibrating non-friable asbestos-containing material, if the material is not wetted to control the spread of dust or fibres and the work is done only by means of non-powered hand-held tools.

Removing one square metre or more of drywall in which joint filling compounds that are asbestos-containing material have been used.

Breaking, cutting, drilling, abrading, grinding, sanding or vibrating non-friable asbestos-containing material if the work is done by means of power tools that are attached to dust-collecting devices equipped with HEPA filters.

Removing insulation that is asbestos-containing material from a pipe, duct or similar structure using a glove bag.

Cleaning or removing filters used in air handling equipment in a building that has sprayed fireproofing that is asbestos-containing material.

An operation that is not mentioned previously and may expose a worker to asbestos and is not classified as a Type 1 or Type 3 operation.

Type 3 operations

The removal or disturbance of more than one square metre of friable asbestos-containing material during the repair, alteration, maintenance or demolition of all or part of a building, aircraft, ship, locomotive, railway car or vehicle or any machinery or equipment.

The spray application of a sealant to friable asbestos-containing material.

Cleaning or removing air handling equipment, including rigid ducting but not including filters, in a building that has sprayed fireproofing that is asbestos-containing material.

Repairing, altering or demolishing all or part of a kiln, metallurgical furnace or similar structure that is made in part of refractory materials that are asbestos-containing materials.

Breaking, cutting, drilling, abrading, grinding, sanding or vibrating non-friable asbestos-containing material, if the work is done by means of power tools that are not attached to dust-collecting devices equipped with HEPA filters.

Repairing, altering or demolishing all or part of any building in which asbestos is or was used in the manufacturer of products, unless the asbestos was cleaned up and removed before March 16, 1998.

Conditions

Because of its fire-resistant properties, asbestos was extensively used in buildings as insulation around pipes and boilers, in sprayed-on fireproofing, in thermal/acoustic insulating boards, in ceiling and floor tiles, and in cement pipes.

The Regulation respecting Asbestos on Construction Projects and in Buildings and Repair Operations (Ontario Regulation 278/05), made under the Occupational Health and Safety Act, outlines requirements for the management of asbestos (friable and non-friable) in buildings and safe work measures and procedures during construction and renovation. The requirement to incorporate non-friable asbestos-containing materials in building management programs came into effect on November 1, 2007.

Where the City of Toronto is the facility owner, all requirements of the regulation apply and must be complied with. Any City of Toronto division responsible for acquiring and maintaining City facilities [e.g. divisions who maintain their own facilities (e.g. Toronto Water, Parks, Forestry and Recreation); Facilities and Real Estate who acquire and maintain a number of City-owned facilities] in which asbestos-containing material is present must assume asbestos-related “owner” obligations under the Occupational Health and Safety Act and the Regulation respecting Asbestos on Construction Projects and Repair Operations.

When a City division is the tenant only, divisional management continues to assume the employer responsibility for protecting the health of employees. However, responsibilities are more limited as building management (whether external or another City division) assumes owner responsibilities.

On projects that are carried out on City-owned facilities, even where the City has not been deemed to be the constructor, the City maintains owner responsibilities and employer responsibilities for protecting the health of any employees located on-site.

Responsibilities

Division heads responsible for maintaining City-owned facilities will ensure that:

responsibilities for asbestos management are clearly established and communicated for all plants/facilities/complexes/buildings, including multi-tenanted locations.

Management of divisions which acquire and maintain City-owned facilities will establish a system to ensure the following steps are taken:

A list of buildings, indicating whether asbestos is present, is prepared and maintained.
Funds are budgeted for preparing a building record (where previously none was required) or for updating an existing building record (to ensure compliance with current legislative requirements).
Funds are budgeted for updating asbestos records at least annually.
Funds are budgeted for asbestos remediation projects, as deemed necessary during asbestos inspections. If maintaining a facility where abatement is required for another City division, that division’s senior manager is advised of the need to budget for abatement.

In addition to the above, management of divisions which acquire and maintain City-owned facilities will also ensure the following actions are taken:

Building Acquisition or Lease

When purchasing, leasing or otherwise acquiring facilities, every reasonable effort is made to ensure that acquired buildings are asbestos-free. In circumstances where this is not feasible or achievable, building asbestos records are obtained, wherever possible. At a minimum, if building asbestos records are not obtained during the acquisition process, asbestos inspections are performed by competent persons and building asbestos records are prepared prior to building occupancy.

Asbestos Record

Evaluate the need for a building record according to legislative requirements (whether friable or non-friable material containing 0.5% asbestos or greater is present).
Review existing building record and revise as required to include non-friable in addition to friable asbestos-containing material.
Review existing building records to ensure minimum number of bulk samples as defined by legislation have been collected by a competent person from an area of homogenous material and analyzed using specified method.
Retain the master copy of each building asbestos record.
Provide a copy of each building asbestos record to the corporate Occupational Health, Safety and Workers’ Compensation Unit.
Provide a copy of each building asbestos record to the senior manager(s) responsible for the work location and updates, as necessary. These senior managers are to ensure that a copy of the building asbestos record is available and maintained on site and that health and safety staff are advised of the location of these records.

Asbestos Management Program

Periodic routine inspections of asbestos-containing materials are performed by competent persons in facilities in which asbestos is present to determine its condition and results of these inspections are incorporated into building asbestos records. Reports are made accessible to the joint health and safety committee/health and safety representative for that location.
Asbestos records are updated at least annually and if new information is available.
Any incidents of accidental disturbance of asbestos-containing material are promptly abated.
Repair orders, generated as a response to recommendations of joint health and safety committees/health and safety representatives, building users, health and safety staff and/or those employees who conduct periodic routine inspections, are promptly addressed.
Employees, who work in the vicinity of asbestos-containing material, including employees of contractors, are advised of its presence.
If friable material has fallen and is being disturbed such that exposure is likely, no further work is done until it is determined whether it is asbestos-containing material. The fallen material is cleaned up, removed and appropriately disposed of. If it is likely that the material will continue to fall, then it is repaired, sealed, removed or permanently enclosed.

Before Requesting Tenders or Arranging Work

A detailed building asbestos assessment and report is provided to prospective contractors prior to asking for tenders, this is in addition to the building asbestos record.
If the work of service providers may result in disturbance of asbestos-containing materials, they are advised of the existence of such materials, as well as required work protocols and procedures.
Employees who perform work, which may disturb asbestos-containing material, are advised of the need to consult building asbestos records for work locations prior to beginning work.
Arrangements for removal of asbestos-containing material as part of major renovations are made, whenever possible. At a minimum, all damaged or deteriorating material is removed during renovations.
In the case of demolition work, remove to the extent practicable any asbestos-containing material that may be disturbed during the work.

Asbestos Work

Written notification is provided to senior on-site managers prior to initiation of scheduled asbestos-abatement work. When work is of an emergency nature, E-mail or fax notification is provided.
Asbestos remediation work is classified as Type 1, 2 or 3 as specified in Regulation 278/05 and appropriate work procedures are developed and implemented.
The Ministry of Labour (MOL) is notified in advance by telephone and in writing of all Type 3 work and all glove bag work exceeding 1 square meter.
Outside contractors retained for asbestos abatement work and their staff are competent and possess all necessary registrations and permits before undertaking any work. All workers and supervisors involved in Type 3 work must have successfully completed an Asbestos Abatement Worker training program and Asbestos Abatement Supervisor training program, respectively, approved by the Ministry of Training, Colleges and Universities.
Project managers who oversee the work of asbestos abatement contractors are appropriately trained and competent.
Project managers are to review and revise, as appropriate, contract language to ensure that contractors hired by the City to conduct asbestos abatement are competent. Project managers are to seek confirmation (e.g. written documentation), as appropriate, that contractors hired by the City to conduct asbestos abatement are in compliance with legislative requirements (e.g. staff have successfully completed approved asbestos training programs staff wear appropriate respiratory protection and have been successfully fit-tested, specified work procedures are followed, required clearance air monitoring is conducted etc.). Project managers are to take immediate corrective action, either directly or indirectly, depending on constructor status, if any violations of safe working procedures are noted.
Asbestos waste is transported and disposed of in accordance with regulatory requirements.
If, in the course of work, material is discovered which was not identified in the asbestos assessment and report but which may be asbestos-containing material, work is stopped and the material is analyzed for asbestos content. The MOL and joint health and safety committee or health and safety representative are immediately advised by telephone and in writing.
Written notice is provided in advance to the joint health and safety committee or health and safety representative if varying a measure or procedure from legislation. Varied measures or procedures must afford at least equal protection to workers.

Additional Requirements if Asbestos Work Conducted by City Staff

All employees likely to be engaged in asbestos-related work are trained in (i) asbestos hazards, (ii) personal hygiene and appropriate work practices and (iii) use, care and disposal of respirators and protective equipment, including limitations, inspection and maintenance, proper fitting, respirator cleaning and disinfection. Training records are maintained. Retraining is completed on a routine and as-needed basis.
Advise joint health and safety committee/health and safety representative of time and place that the above worker training is to be carried out.
All workers and supervisors engaged in Type 3 work must have completed training programs approved by the Ministry of Training, Colleges and Universities.
Asbestos work reports are completed for any workers engaged in Type 2 or Type 3 operations at least once every 12 months and immediately on termination of employment, or, for any employees who experience accidental exposure to asbestos. Reports are submitted to Employee Health staff with responsibility for the asbestos biomedical surveillance program.
All workers engaged in cleaning and/or removing filters used in air handling equipment in a building with asbestos-containing sprayed fireproofing must have been trained in and follow Type 2 procedures.
Ensure workers follow legislatively required procedures.
Ensure workers are provided with appropriate personal protective equipment. For respiratory protective equipment, ensure these are provided within the context of a written respiratory protection program (which includes respirator fit testing).
For type 3 work, ensure that a copy of clearance air test results are posted in the workplace and in a common area (if the building contains other workplaces) and a copy is provided to the joint health and safety committee/health and safety representative within 24 hours after the test results are received. The owner shall keep a copy of the clearance air test results for at least one year.

Management of all divisions that occupy buildings where asbestos is present will:

Obtain and maintain the building asbestos record in an accessible location on-site.
Supply a copy of the building asbestos record to the joint health and safety committee/health and safety representative responsible for the location and notify workers potentially exposed.
Develop, in consultation with health and safety staff, job-specific safe working procedures for asbestos-related work.
Schedule with health and safety staff asbestos training of (i) workers who may work in close proximity to asbestos-containing material and who may disturb this material and (ii) joint health and safety committee members/health and safety representatives who visually inspect accessible asbestos materials of which they are aware.
Notify building management when they suspect damaged asbestos-containing material, requesting investigative and/or corrective action.
Report and seek immediate corrective action if any violations of safe working procedures are noted.
Advise employees and tenants of any scheduled or emergency asbestos-related work.

The Occupational Health, Safety and Workers’ Compensation Unit’s occupational hygiene staff will:

Lead in the development of procedures, guidelines and training programs to facilitate compliance with this policy.
Retain copies of building asbestos records, as provided by divisions, and maintain database of locations.
Provide, or assist in provision of, asbestos training for those employees potentially exposed to asbestos.
Assist in addressing employee asbestos-related concerns.
Assist divisions in asbestos-related communications with the Ministry of Labour.

Health and Safety Consultants will:

Monitor frequency of management’s inspections.
Based on joint health and safety committee/health and safety representative inspection reports and/or occupational health and safety staff inspections, recommend appropriate remedial actions or seek an occupational hygiene assessment.
Assist in the provision of training and development of safe work procedures.

Employee health staff in Human Resources’ Employee Health, Rehabilitation and Employee Assistance Unit will:

Develop and assist City divisions in implementing an asbestos biomedical surveillance program.
Co-ordinate asbestos-related health assessments with appropriate health care practitioners, in response to needs identified by departments.
Review and communicate results of these assessments to employees and, to the extent legislatively required, with departments.
Submit asbestos work report forms to the Ministry of Labour at the frequency required by legislation.

Joint health and safety committees/health and safety representatives representing employees at locations with identified asbestos-containing materials will:

Inspect readily visible asbestos-containing material as part of their routine workplace inspections
Bring deficiencies, if any, to the attention of area supervisors and occupational health and safety staff.

Workers will:

Follow asbestos safe work procedures applicable to the work they perform.
Advise their supervisors of any asbestos-related occupational health and safety issues or concerns.
For workers engaged in Type 2 or 3 work, voluntarily participate in biomedical surveillance program.

The Occupational Health and Safety Co-ordinating Committee will:

Monitor the implementation and effectiveness of this policy

Tool Kit

Asbestos Management Checklist

Asbestos Fact Sheet

Authority

The Regulation Respecting Asbestos on Construction Projects and in Buildings and Repair Operations (O. Reg. 278/05)

Hazardous Waste Regulation (O. Reg. 347 as amended)

Corporate Asbestos Management Program

Endorsed by

Occupational Health & Safety Co-ordinating Committee, (OHSCC), June 6, 2007

OHSCC Reviewed: February 25, 2009 and April 26, 2016

Approved by

City Manager, July 23, 2007

Date Approved

July 23, 2007

Reviewed by OHSCC

April 26, 2016