Asbestos Management

561 FW 8
FWM Number
561 FW 8, FWM 377, 09/29/01
Originating Office
Infrastructure Management Division

8.1 What is the purpose of this chapter? This chapter provides guidance for employees to properly manage Asbestos Containing Materials (ACM) at U.S. Fish and Wildlife Service (Service) facilities.

8.2 What are the authorities for this chapter?

A. Toxic Substances Control Act (TSCA), (15 U.S.C. 2601, et seq.).

B. Occupational Safety and Health Administration (OSHA), Toxic and Hazardous Substances, Asbestos (29 CFR 1910.1001).

C. OSHA, Safety and Health Regulations for Construction, Asbestos (29 CFR 1926.1101).

D. Environmental Protection Agency (EPA), National Emission Standards for Asbestos (40 CFR 61, Subpart M).

E. EPA, Asbestos Worker Protection (40 CFR 763, Subpart G).

F. Department of Transportation, Hazardous Materials Regulations (49 CFR 171 and 172).

G. 485 Departmental Manual, Safety and Occupational Health Program.

8.3 Who is responsible for administering this program? Table 8-1 describes the responsibilities of Service employees for the asbestos management program.

Table 8-1: Responsibilities for the asbestos management program

These employees...Are responsible for...
A. The DirectorApproving policy for our asbestos management program.
B. The Assistant Director – Business Management and OperationsEnsuring that the Service maintains an appropriate and effective asbestos management program.
C. The Chief, Division of Engineering

(1) Developing policy for the asbestos management program, and

(2) Providing technical assistance to the Regional Engineers and Regional Environmental Compliance Coordinators (RENs/RECCs) as they develop and monitor ACM management programs in the Regions.

D. Regional Directors

(1) Ensuring the implementation of an asbestos management program in their respective Regions, and

(2) Identifying funding requirements necessary for compliance.

E. Regional Engineers/Regional Environmental Compliance Coordinators (RENs/RECCs)

(1) Developing and monitoring the Regional asbestos management program;

(2) Providing assistance to Project Leaders/Facility Managers when they develop Operations and Maintenance (O&M) plans;

(3) Conducting or arranging for inspections of Service buildings for asbestos, as needed, using State-accredited Asbestos Hazard Emergency Response Act (AHERA) inspectors or State-certified asbestos inspectors and State-certified analytical laboratories;

(4) Advising managers about asbestos inspections, and, when required, overseeing remediation projects and ensuring compliance with applicable Federal, State, and local regulations; and

(5) Developing and maintaining a consolidated inventory of buildings in the Region that contain or may contain asbestos, including location, condition, and amount of the ACM or presumed ACM (PACM). The Project Leaders/Facility Managers provide this information.

F. Regional Safety ManagersGuiding and assisting the RECCs and Project Leaders/Facility Managers on actions that minimize risk to human health associated with asbestos.

G. Project Leaders/Facility Managers

(1) Ensuring that their facilities have been inspected;

(2) Where friable ACM is identified, implementing an asbestos O&M plan to prevent employee exposure;

(3) Developing and maintaining an inventory of the location, condition, and amount of the ACM in all buildings at the facility and providing a copy to the RENs/RECCs;

(4) Requesting sufficient funds for compliance with asbestos management program requirements;

(5) Ensuring that maintenance, custodial, and other employees who may be exposed to asbestos fibers receive annual asbestos awareness training (see section 8.7 and 29 CFR 1910.1001(j)(7)(iv));

(6) When required, maintaining records of employee exposure and medical surveillance (see 29 CFR 1926.1101(n)(2)-(3));

(7) Notifying contractors of the location and type of PACM/ACM in the O&M plan and having them sign FWS Form 3-2432, Contractor Notification Form for Asbestos; and

(8) Notifying tenants of location and type of PACM/ACM on Form D1-1881, Quarters Assignment Agreement, and having tenants sign the form.

H. Employees

(1) Informing managers when PACM or ACM is found and monitoring its condition, and

(2) Wearing appropriate personal protective equipment where ACM is present and likely to be disturbed when performing maintenance or other work (applies only to employees trained to be in the vicinity of asbestos).

I. Tenants

(1) Reviewing and signing DI-1881, Quarters Assignment Agreement, acknowledging the presence and types of PACM/ACM present, and

(2) Notifying Project Leader/Facility Manager if the condition of the PACM/ACM deteriorates.

8.4 What terms do you need to know to understand this chapter?

A.  Asbestos. Includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophylite asbestos, actinolite asbestos, and any of these minerals that have been chemically treated or altered.

B.  Asbestos Containing Material (ACM). Any material or product that contains more than 1% asbestos.

C. Category I Non-friable ACM. Material such as packing, gaskets, resilient floor covering, and asphalt roofing products containing more than 1% asbestos.

D. Category II Non-friable ACM. Any material containing more than 1% asbestos that is not category I non-friable ACM, and that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. Category II ACM includes, but is not limited to:

(1) Asbestos cement siding and shingles,

(2) Transite panel boards, and

(3) Asbestos cement pipe (asbestos cement pipe may not be limited to buildings).

E. Friable ACM. Any material containing more than 1% asbestos that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure.

F. High-Efficiency Particulate Air (HEPA) Filter. A filter capable of trapping and retaining at least 99.97% of monodispersed particles of 0.3 micrometers or larger in diameter.

G. Presumed Asbestos Containing Material (PACM). Thermal System Insulation (TSI)and surfacing material found in buildings constructed before 1981 and floor tile installed in buildings through 1981 may contain asbestos. Though it is unlikely, some flooring installed after 1981 may contain asbestos. Until sampling demonstrates that the material has 1% or less asbestos, we consider these materials PACM.

H. Regulated Asbestos-Containing Material (RACM). RACM includes:

(1) Friable asbestos material;

(2) Category I non-friable ACM that has become friable, or has been subjected to sanding, grinding, cutting, or abrading; and

(3) Category II non-friable ACM that has a high probability of becoming crumbled, pulverized, or reduced to powder during the course of demolition or renovation operations.

I. Vinyl Asbestos Floor Tile. When vinyl floor tile, and in some cases its mastic, contains more than 1% asbestos, it must be handled as ACM.

8.5 What are the overall program requirements for facilities?

A. Regions must demonstrate that PACM does not contain asbestos by:

(1) Implementing a program to inspect buildings to determine the location and condition of materials likely to contain asbestos. The RECC initiates inspection procedures according to applicable Federal, State, and local regulations.

(2) Performing tests of PACM to confirm the presence or absence of asbestos in the material. All sampling must be conducted by an accredited Federal or State inspector and analyzed by a State-certified analytical laboratory.

B. Project Leaders/Facility Managers must develop and maintain an inventory of the location, condition, and amount of ACM in all buildings for which they are responsible (see Exhibit 1 for an inventory template).

C. To ensure they are aware of any changing conditions, Project Leaders/Facility Managers must ensure that ACM is visually inspected semiannually using FWS Form 3-2430, Asbestos Inspection Form.

D. REN/RECCs must maintain a consolidated inventory of buildings in the Region that contain asbestos, including location, condition, and amount of the ACM.

8.6 When does a Project Leader/Facility Manager have to prepare an O&M plan, and what is in one?

A. If an asbestos inspection reveals the presence of friable ACM in a building, the Project Leader/Facility Manager must prepare an O&M plan. (See Exhibit 2 for a template.) The material’s characteristics, condition, quantity, and location within the building, as well as building use, affect how the Project Leader/Facility Manager should deal with the ACM. If the friable ACM is in good condition, O&M procedures may be appropriate and sufficient. If the friable ACM is significantly damaged, the procedures in the O&M plan alone are not sufficient. In these instances, some form of full-scale abatement (repair, encapsulation, enclosure, encasement, or removal) is required.

B. An O&M plan is a critical component for properly managing asbestos in place and assuring compliance with construction and exposure regulations. The elements of an O&M plan should include:

(1) Training. Describe training requirements (see section 8.7).

(2) Notification. Describe how the Project Leader/Facility Manager informs employees, tenants, and other building occupants about the presence of friable ACM by distributing written notices or posting signs or labels about ACM where employees can see them. Also describe how the Project Leader/Facility Manager makes the O&M plan available to anyone who might work on or disturb the ACM.

(3)  Monitoring ACM. Describe how employees semiannually inspect ACM visually to ensure that any ACM damage or deterioration is detected and corrective action taken. Employees should use FWS Form 3-2430 for this inspection.

(4) Recordkeeping. Describe how staff keep all facility asbestos management documents in permanent files. These documents include, but are not limited to:

     (a) Copies of AHERA inspection and assessment reports;

     (b) Written O&M plan;

     (c) Semiannual ACM/PACM visual inspection records (see FWS Form 3-2430);

     (d) Awareness training records (see FWS Form 3-2431); and

     (e) Changes to location, condition, or quantity of the ACM/PACM.

(5) Job Site Controls for Work Involving ACM. Describe practices employees must use to control activities that might disturb ACM.

(6) Safe Work Practices. Describe practices employees must use to avoid or minimize fiber release during activities affecting ACM.

(7) Worker Protection. Describe medical and respiratory protection programs. Service employees may not participate in asbestos abatement activities unless they are in full compliance with State AHERA certification and licensing standards and follow OSHA and EPA requirements and the policy in this chapter. In most instances, worker protection will be described in the employee Job Hazard Analysis (see 240 FW 1).

8.7 What are the requirements for awareness training for employees who may come into contact with ACM?

A. All maintenance, custodial, and other employees who may disturb asbestos during their normal job duties must complete a minimum of 2 hours of asbestos awareness training annually. Project Leaders/Facility Managers:

(1) Provide this training before assigning their employees to duties where contact is possible, and

(2) Record the initial training date and subsequent annual refresher dates on FWS Form 3-2431 or a similar form.

B. The training must include information on:

(1) Health effects of asbestos,

(2) Locations of ACM and PACM in the building/facility,

(3) Recognition of ACM and PACM damage and deterioration,

(4) OSHA requirements relating to housekeeping found in 29 CFR 1910.1001(j)(7)(iv), and

(5) Proper response to fiber release episodes.

8.8 What procedures are necessary before demolition, renovation, or remodeling activities take place at Service facilities?

A. For demolition, renovation, and remodeling projects at facilities that have not had an asbestos inspection, before beginning the project, the Project Leader/Facility Manager must ensure that a State-accredited, AHERA asbestos inspector performs an inspection to determine the presence or absence of friable and non-friable asbestos.

B. If RACM is found during the inspection, the Project Leader/Facility Manager:

(1) Consults with the RECC to develop a contract to hire a State-certified and licensed asbestos abatement contractor to remove it from the building(s) before beginning any such project, and

(2) Ensures that the contractor reads and signs FWS Form 3-2432, Contractor Notification Form for Asbestos, and maintains a copy in station or contract files.

C. The contractor is responsible for:

(1) Notifying either EPA or the State agency responsible for Clean Air Act enforcement before beginning work;

(2) Managing, transporting, and disposing of ACM at an appropriate landfill; and

(3) Completing and submitting all forms, in accordance with State requirements, about notification of demolition and renovation resulting in the removal of asbestos.


(1) Reviews contractor work plans and provides technical advice to the Contracting Officer and Project Leader/Facility Manager;

(2) May assist with managing abatement projects; and

(3) Ensures compliance with State and Federal regulations.

E. When ACM remains at a facility, any contractors hired for demolition, renovation, or remodeling must also read and sign FWS Form 3-2432, Contractor Notification Form for Asbestos.

8.9 What prohibitions does the Service have related to asbestos management?

A. Service employees may not participate in asbestos abatement activities unless they are in full compliance with State AHERA certification and licensing standards and follow OSHA and EPA requirements and the policy in this chapter.

B. Employees must be physically separated from abatement areas unless they are involved in the actual abatement project. Only abatement personnel may occupy a building in which an asbestos abatement project is being performed unless there is a containment area separating the abatement work.

C. Employees may only perform vehicle-related work involving asbestos, such as brake and clutch repair, by using a negative pressure enclosure/HEPA vacuum system method or low pressure/wet cleaning method that meets the detailed requirements in 29 CFR 1910.1001(f)(3) and Appendix F.

D. Employees may not use compressed air to remove asbestos or materials containing asbestos unless they use it in conjunction with a ventilation system that can effectively capture the dust cloud the compressed air creates.

8.10 How does the Service inform employees about asbestos issues? The Project Leader/Facility Manager:

A. Notifies employees in writing about inspection and abatement programs, including air sampling results and abatement schedules occurring at their specific facility, and

B. Tells employees about training programs and requirements related to asbestos management.

Attachments (Exhibits, Amendments, etc)

Amended by Decision Memorandum, “Approval of Revisions to ~350 Directives to Remove Gender-Specific Pronouns,” 6/22/2022