Training of custodial and maintenance workers is one of the keys to a successful operations and maintenance (O&M) program. If building owners do not emphasize the importance of well-trained custodial and maintenance personnel, asbestos O&M tasks may not be performed properly. This could result in higher levels of asbestos fibers in the building air and an increased risk to building workers and occupants.
Training Required by Law
The Occupational Safety and Health Administration (OSHA) requires employers to institute and ensure participation in a worker training program for employees exposed to fiber levels (either measured or anticipated) at or above the permissible exposure limit (0.1 fibers per cubic centimeter (f/cc) as an 8-hour, time-weighted average (TWA) and/or the excursion limit (1.0 f/cc as a 30-minute TWA). This training program consists of an initial training period, the duration of which is determined by the type of work the employee performs, and annual refresher training. For additional information about these training requirements, see the OSHA regulations at 29 CFR § 1910.1001(j)(7) (PDF) (53 pp, 408K, about PDF).
According to the EPA regulations governing schools, all school staff custodial and maintenance workers who conduct any activities that may result in the disturbance of asbestos-containing building material (ACBM) must receive 16 hours of O&M training (comprised of 2 hours of Awareness Training and 14 hours of Special O&M Training).
Some states and municipalities may also have specific training requirements for workers who could be exposed to asbestos, or who work in a building with ACM present.
Types of Training
As an illustration of the different types of maintenance worker training, below are three types of training under the EPA regulations governing schools:
Type 1: Awareness Training
This training is for maintenance and custodial staff involved in cleaning and minor maintenance tasks where ACM may be accidentally disturbed.
Two-hour Asbestos Awareness Training may include such topics as:
- Background information on asbestos
- Health effects of asbestos
- Worker protection programs
- Locations of ACM in the building
- Recognition of ACM damage and deterioration
- The O&M program for that building.
Type 2: Special O&M Training
This training is for maintenance and custodial workers involved in general maintenance and asbestos-containing material repair tasks.
For example, the job may involve repair or removal of a small section of damaged thermal system insulation, or the installation of electrical conduit in an air plenum containing ACM or ACM debris. This training generally lasts at least 14 hours. Special O&M training usually involves more detailed discussions of the topics included in Type 1 training as well as:
- Federal, state, and local asbestos regulations
- Proper asbestos-related work practices
- Descriptions of the proper methods of handling ACM, including waste handling and disposal
- Respirator use, care, and fit-testing
- Protective clothing donning, use, and handling
- Hands-on exercises for techniques such as glovebag work and HEPA vacuum use and maintenance
- Appropriate and proper worker decontamination procedures.
Type 3: Abatement Worker Training
This training is for workers who may conduct activity related asbestos abatement activities.
This work involes direct, intentional contact with ACM. The Asbestos Model Accreditation Plan (MAP)(PDF) (96 pp, 588K, about PDF) training courses approved by the EPA or a state with an EPA-approved MAP requires the use of trained and accredited asbestos professionals when conducting asbestos inspection and corrective-action activities at schools and public and commercial buildings. It provides guidance to the states on the training requirements for asbestos control professionals. These training courses range in duration from 32 to 40 hours.
This type of training is much more extensive than Types 1 and 2, although it should include many of the same elements. Abatement worker training typically addresses a variety of specialized topics, such as:
- Pre-asbestos abatement work activities
- Work area preparation
- Establishing decontamination units
- Personal protection, including respirator selection, use, fit-testing, and protective clothing
- Worker decontamination procedures
- Safety considerations in the abatement work area
- A series of practical hands-on exercises
- Proper handling and disposal of ACM wastes.
Who Should Conduct Training
The asbestos program manager (APM) could consider conducting the training program for Types 1 and 2 if he or she has sufficient specific asbestos knowledge and training. If the APM does not conduct the training, the building owner should hire an outside consultant or send workers to an appropriate O&M training course. A trained industrial hygienist or trained and accredited asbestos professional should conduct the training on respirator use and fit-testing. A health professional should conduct the training on health effects. Type 3 training must be conducted by an entity that had its training course(s) approved by the EPA or a state with an EPA approved MAP.
Where to Find Training
State and local agencies and professional associations, may be able to suggest courses or direct you to listings of training providers for each of the three types.
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