O&M Plan for a School With In-Place Flooring
A 1970 elementary school has 18,000 sq ft of asbestos-containing floor tile and mastic in classrooms and hallways, all in good condition, plus intact pipe insulation in a custodial closet. The district adopts an O&M approach rather than abatement. The custodian currently strips and waxes floors twice a year using a high-speed floor machine and an aggressive stripper. There is no written O&M plan, no training records, and no work-order system for the flooring. A teacher has asked to hang artwork on the wall using adhesive hooks and to move a bookshelf across the room.
1. What elements must the O&M plan contain to be adequate for this building?
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The O&M plan should include: a description of the asbestos-containing materials and their locations; work practices for custodial and maintenance activities that could disturb them (floor care, drilling, moving furniture); a prohibition on dry stripping and on high-speed burnishing that abrades tile, with approved wet methods and low-abrasion products; procedures for minor disturbance and for handling debris; respiratory protection and training requirements for employees who may disturb material; a work-order/notification system so maintenance staff know where asbestos is before starting work; periodic surveillance and reassessment; and recordkeeping. It should also address the pipe insulation in the custodial closet, which is in an area where custodial work occurs.
2. Identify the specific deficiencies in current practice and the corrective actions.
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Deficiencies: (1) dry/aggressive stripping and high-speed machine use on asbestos tile - abrades the material and generates debris; (2) no written O&M plan; (3) no training records; (4) no work-order or notification system, so staff and contractors may disturb material unknowingly; (5) no surveillance. Corrective actions: switch to approved wet methods and low-abrasion floor care, prohibit dry stripping and aggressive burnishing, train custodial staff, implement a work-order/notification system with an asbestos location list, begin periodic surveillance, and document everything. The custodian's current method is the single biggest exposure driver and should be changed first.
3. How should the plan handle the teacher's requests (adhesive hooks, moving a bookshelf)?
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These are ordinary activities that can disturb material and should be covered by the O&M plan. Adhesive hooks: the teacher should not drill or abrade the wall; the plan should require maintenance staff to approve and perform any wall penetration, with precautions if the wall contains asbestos. Moving a bookshelf: dragging across tile can abrade it; the plan should require lifting/carrying or protective measures and should instruct staff not to slide heavy furniture. The plan should include a simple request/notification path so occupants know to ask before modifying surfaces, and staff know the material locations. This is a communication and work-practice issue, not a reason to abate.