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Guidelines Part 6

Guidelines Part 6 Contents

Guidelines Part 6 - Asbestos

G6.1 Definition of asbestos-containing material

Issued March 25, 2005; Editorial revision May 17, 2006

Section 6.1 of the OHS Regulation defines asbestos-containing material (ACM) as follows:

means any manufactured article or other material which contains 1% or more asbestos by weight at the time of manufacture, or which contains 1% or more asbestos as determined in the National Institute for Occupational Safety and Health Manual of Analytical Methods, Method 9002, Issue 2 (microscopy, stereo and polarized light, with dispersion staining) or other method acceptable to the Board.

Purpose of this Guideline
This guideline provides information on an analytic method to WorkSafeBC, in addition to the means of determination referenced in section 6.1 of the OHS Regulation.

Other method acceptable to WorkSafeBC
The following analytic method is acceptable to WorkSafeBC for the purposes of bulk asbestos analyses of ACM:

EPA (Environmental Protection Agency) Test Method for the Determination of Asbestos in Bulk Building Materials (EPA/600/R-93/116 July 1993).

Both this method and the National Institute for Occupational Safety and Health Manual of Analytical Methods, Method 9002, Issue 2 contain provisions that require analytic consideration of layers of materials, where distinct layers are present. It is expected that the analysis and reporting of layered materials will involve consideration of those layers which are likely to contribute to the exposure of workers to asbestos.

Both methods contain mandatory provisions for intra-laboratory quality control (QC) systems, and recommendations for inter-laboratory QC procedures. Quality assurance is an important aspect of asbestos analysis.

G6.3 Exposure control plan for asbestos

Issued August 1, 1999

Section 6.3(1) of the OHS Regulation states "If a worker is or may be exposed to potentially harmful levels of asbestos, the employer must develop and implement an exposure control plan meeting the requirements of section 5.54."

Situations in which workers may potentially be exposed to asbestos include active or anticipated disturbance of friable asbestos or asbestos-containing materials or generation of dust from non-friable, asbestos-containing materials. For further information regarding the requirements of an exposure control plan, consult OHS Guideline G5.54-2.

Some workplaces may already have an asbestos management program in place. Components of an asbestos management program include:

coordination of subcontractors,
identification, hazard assessment, purchasing policy,
training,
written procedures,
transportation and waste disposal,
health monitoring, and
review of program.

Some or all of these components may correspond to elements of an exposure control plan and may be accepted as complying with the required elements of an exposure control plan. Under section 5.54(2) of the OHS Regulation, the required elements of an exposure control plan are as follows: statement of purpose and responsibilities; risk identification, assessment and control; education and training; written work procedures, when required; hygiene facilities and decontamination procedures, when required; health monitoring, when required; and documentation.

The complexity of the exposure control plan will depend on such factors as the results of the risk assessment, the options available for asbestos abatement and control, whether these options are utilized, and the likelihood of actively disturbing asbestos and asbestos-containing materials.

Under section 6.3(2), a "properly trained person" must administer the overall exposure control plan. To comply with this requirement, the "properly trained person" should

be familiar with the hazards and precautions required for handling and working around asbestos and asbestos-containing materials,
be well versed in the components of the exposure control plan,
be familiar with the factors used to assess risk associated with asbestos and asbestos-containing materials, such as friability, location, and damage to material,
have received instruction and training in the administration of the exposure control plan from a health and safety professional with experience in the practice of occupational hygiene as it relates to asbestos management. Alternatively, the person may have completed a course from a widely recognized training program, which would impart equivalent information, methods, practices and procedures to the recipient, such as NIOSH or other similar training program.

G6.5 Identification

Issued August 1, 1999

Section 6.5 of the OHS Regulation requires that the employer ensure that all asbestos-containing materials present in the workplace be identified by signs and labels. When the use of signs and labels is not practicable, "other effective means" may be used.

It may be impracticable to post signs and labels in situations where there are aesthetic concerns (e.g., building lobbies or public areas) or where they might create an unreasonable level of concern amongst the general public. In these circumstances, "other effective means" could include colour or letter encryption coding, floor plan mapping, or signage placed behind access ways (provided that workers are not placed at risk upon entering the restricted areas).

Whatever the means of identification, it must be coupled with effective training and education of all affected workers. Refer to section 6.11 ("instruction and training"). The guiding principle should be that the less information that is presented on signs or labels, the more education and training that will be required to communicate the hazards of and precautions for handling and working around asbestos.

G6.6-1 Risk assessment

Issued August 1, 1999

Section 6.6 of the OHS Regulation specifies the requirements for conducting a risk assessment and for classifying any work involving asbestos according to the risk involved.

Risk assessments are required under sections 6.6(1) and 6.6(2). Under section 6.6(1), a risk assessment must be conducted on asbestos-containing material identified in the inventory. As required by section 6.4 of the OHS Regulation, an inventory of all asbestos-containing materials must be prepared and kept current. Section 6.6(2) requires that a risk assessment be conducted "before any demolition, alteration, or repair of machinery, equipment, or structures where asbestos may be disturbed."

Assessment of the risk to workers from asbestos materials either used or present in the workplace relies on a two-stage process. The goal of this process is to prioritize materials for abatement control and to assist in selecting appropriate control options.

The first stage involves evaluating parameters that are indicative of the likelihood of worker exposure. The parameters most commonly looked at include

Accessibility

How easily will the asbestos fibres become airborne because of architectural design, location and occupant activities? Are the fibres

totally enclosed (e.g., behind a fixed ceiling)? If so, there is minimal risk of exposure.
inaccessible (i.e., beyond the reach of the public)? If so, there is low risk of exposure.
accessible in a low activity area? If so, there is a moderate risk of exposure.
Accessible in a high activity area (e.g., hallways, stairways, etc.)? If so, there is a high risk of exposure.

Condition

Based on a visual examination, what is the existing state of the sprayed on material?
Is the material in good condition (i.e., no damage at all)? If so, there is a minimal risk of exposure.
Does the material have mild damage? If so, there is a low risk of exposure.
Does the material have moderate damage? If so, there is a moderate risk of exposure.
Does the material have severe damage (i.e., areas are missing, hanging loose, or are water damaged)? If so, there is a high risk of exposure.

Friability

To what extent can the material be broken apart if a person or object makes contact with it?
Is the material is firmly bound? If so, it is not friable and there is minimal risk of exposure.
Is the material slightly friable? If so, there is a low risk of exposure.
Is the material moderately friable? If so, there is a moderate risk of exposure.
Does the material break apart easily? If so, it is very friable and there is a high risk of exposure.

Presence in return air plenum

Is the asbestos containing material present in the air moving system? Options are "present" or "not present".

Percentage of asbestos

What is the percentage of asbestos contained in the sprayed on material? It is generally not necessary to know the exact percentage of asbestos. Rather, it can be estimated using broad ranges. For example:

"Less than 20%" or "greater than 20%".
"Less than 1%"; "1 to 10%"; "11 to 25%"; "26 to 50%"; or "greater than 50%".

Other parameters that may be examined include the extent of water damage, the exposed surface area of friable material, activity and movement (e.g., air movement, building vibration from machinery or other sources, and activity levels of workers).

Each parameter is assigned a "score" to indicate the potential for exposure. These "scores" are then combined to derive an overall risk factor that is used to prioritize the control and abatement options to be implemented. Different approaches are used to "score" the parameters and to combine the assigned scores into one overall risk factor. Some examples are briefly described below.

A numerical rating scale is used in a system developed by the US Environmental Protection Agency (e.g., "0" or "1" is assigned to parameters for which there is a low potential of exposure, "4" is assigned to those for which the potential of exposure is high). These scores are then combined using a mathematical formula. The range into which the overall score falls will determine what remedial action is recommended (e.g., overall score is in the range of 5-9, then the recommended action is to review in 2 to 3 years).
An alternative system, described in an Alberta Occupational Health and Safety publication, categorizes the parameters on the basis of high, medium or low potential for exposure. "Asbestos Control -- Sprayed on Applications", published in 1990. The need for control is determined by consulting a decision table. For example, in situations where there is no asbestos in the return air plenum and the material contains less than 20% asbestos, there is no need for immediate control, unless 2 parameters have been assigned a high potential of exposure or 3 parameters have been assigned a medium potential of exposure.

G6.6-2 Classification of risk

Issued August 1, 1999

Before any work involving asbestos takes place, section 6.6(3) requires that the work activity be assessed and classified according to risk by a qualified person. The intent of this requirement is to assess the likelihood of asbestos fibres being released during handling activities and to select appropriate work precautions, according to the level of the risk to workers.

G6.6-3 Qualifications

Issued August 1, 1999; Editorial Revision October 2004; Revised June 18, 2008

Regulatory excerpt
Section 6.6 of the OHS Regulation ("Regulation") states

(1) The employer must ensure that a risk assessment is conducted by a qualified person on asbestos-containing material identified in the inventory, with due regard for the condition of the material, its friability, accessibility and likelihood of damage, and the potential for fibre release and exposure of workers.

(2) The employer must ensure that a risk assessment has been conducted before any demolition, alteration, or repair of machinery, equipment, or structures where asbestos may be disturbed.

(3) Before work involving asbestos takes place the employer must ensure that a qualified person assesses the work activity and classifies it as a low, moderate, or high risk activity.

(4) The qualified person referenced in subsections (1) and (3) must be an occupational health and safety professional with experience in the practice of occupational hygiene as it relates to asbestos management.

Purpose of guideline
This guideline provides information to describe the competencies necessary in a qualified person, and provides contact information to assist an employer to locate a qualified person.

Competencies of a qualified person
For the purposes of sections 6.6(1) and 6.6(3) ,appropriate qualifications for persons performing risk assessments and work activity classifications include

Certified industrial hygienist (CIH), registered occupational hygienist (ROH), certified safety professional (CSP), Canadian registered safety professional (CRSP) or professional engineer (P. Eng.), provided that the holders of these qualifications have experience in the recognition, evaluation, and control of asbestos hazards
Other acceptable combination of education, training and experience. This should include completion of recognized training courses in asbestos inspection and extensive occupational health and safety experience within the asbestos abatement industry, e.g.
- Experience applying the principles of occupational hygiene
- Experience with specific elements or tasks related to asbestos abatement, such as
  - Asbestos hazard identification and risk assessment
  - Preparation of asbestos work procedures
  - Collection of samples of materials suspected of containing asbestos
  - Collection of air samples during asbestos abatement projects
  - Preparation of inspection reports
  - Conduction of workplace inspections
Recognized education and training courses in the field of asbestos consultation and abatement include
- "Building Inspection and Management Planning for Asbestos" course offered by the Continuing Education section of the University of California (Berkeley) Center for Occupational & Environmental Health, and conducting workplace inspections
- AHERA Building Inspector course offered under the EPA Asbestos Hazard Emergency Response Act (AHERA)

Employer due diligence
Employers are responsible for selecting qualified persons, as defined in section 6.6 of the Regulation, to undertake asbestos risk assessments and work classification. The employer must exercise due diligence in the selection of the qualified person. This is especially necessary if the person being engaged does not hold one of the certifications or the licence credentials specified herein. While each case must be considered on its merits, reliance by an employer on a person holding a certification or licence specified herein would normally be considered reasonable; however, due diligence in all cases includes a review of the person's experience as well as their accredited credentials.

A deficient asbestos risk assessment or work classification may be an indication that the person selected was not qualified. In all such situations, whether the person selected purports to be a qualified person, WorkSafeBC prevention officers will enquire what steps the employer took to assess the person's qualifications. It should be noted that when evaluating the qualifications of a person who has prepared an asbestos risk assessment or work classification, the prevention officer's primary focus will be the quality and accuracy of the assessments and work classifications rather than the person's credentials.

Contact with Accrediting agencies
An accrediting agency will often maintain a web site with contact information on accredited members. For example, the Canadian Registration Board of Occupational Hygienists maintains contact information on persons with an ROH designation and can be accessed at www.crboh.ca. A list of persons with a CIH designation can be found on the American Board of Industrial Hygiene web site at www.abih.org. Lists of persons with CRSPs, which are issued by the Board of Canadian Registered Safety Professionals, are available at www.bcrsp.ca.

G6.7 Control of friable asbestos

Issued August 1, 1999

Section 6.7(1) of the OHS Regulation states "The employer must ensure that a friable asbestos-containing material in the workplace is controlled by removal, enclosure or encapsulation so as to prevent the release of airborne asbestos fibre."

Abatement and control options should eliminate or reduce all moderate and high risk factors identified in the risk assessment required under section 6.6. Drop ceilings are not an appropriate or effective system of permanently enclosing asbestos materials as it does not eliminate access to the treated area and services are not likely to be removed to the outside of the ceiling system.

G6.8 Procedures for abatement of asbestos-containing material during house and building demolition/renovation

Issued July 5, 2002; Revised November 23, 2005

Regulatory excerpt
Section 6.8 (Procedures) of the OHS Regulation states:

(1) The employer must ensure that procedures for handling or using asbestos-containing material prevent or minimize the release of airborne asbestos fibres.

(2) The employer must ensure that the procedures for control, handling or use of asbestos are in accordance with procedures acceptable to the Board.

(3) The procedures must address

(a) containment of asbestos operations where applicable,

(b) control of the release of asbestos fibre,

(c) provision, use and maintenance of appropriate personal protective equipment and clothing,

(d) means for the decontamination of workers, and

(e) removal of asbestos waste and cleanup of asbestos waste material.

(4) The procedures must provide a worker with task-specific work direction that addresses both hazards and necessary controls.

Purpose of guideline
In the past, a wide variety of building materials contained asbestos. During renovation or demolition of buildings and other structures constructed of such materials, workers and other persons may be at risk of harmful exposure to airborne asbestos if safe work procedures are not followed.

This guideline provides information to assist with the development of task-specific work procedures required by section 6.8 of the OHS Regulation during the renovation or demolition of a house, building, or similar structure involving asbestos material. It also provides information on some of the requirements in the OHS Regulation for asbestos control, particularly in Part 6 (Substance Specific Requirements - Asbestos) and Part 20 (Construction, Excavation and Demolition).

The requirements for asbestos in Part 6 apply to any workplace where a worker is or may be exposed to potentially hazardous levels of asbestos fibre including, but not limited to: a workplace where asbestos-containing material (ACM) is present or is used, an operation involving the abatement of ACM, and an operation in which exposure to asbestos fibre in excess of 50% of the exposure limit may occur. The provisions of Part 6 are in addition to those in Part 5 (Chemical and Biological Substances), which, among other things, establishes the exposure limit for asbestos and general measures for control.

Part 20 applies to any construction project as defined in Part 20, including demolition, alteration and repair. Provisions in Part 20 on notice of project (NOP) and hazardous materials are particularly applicable to asbestos control.

This guideline should be used with the WorkSafeBC (WSBC) manual, Safe Work Practices for Handling Asbestos, and other applicable safety information on asbestos in construction. These are available at www2.worksafebc.com/Portals/Construction/HazardousMaterials.asp?ReportID=34092.

Pre-planning and notice of project
Renovation and demolition work involving materials containing asbestos requires proper planning. A risk assessment for asbestos must be done before demolition or other work begins, as required by sections 6.6 and 20.112 of the OHS Regulation.

In addition, an NOP must be submitted, as required by s. 20.2(1)(c), before beginning any work that involves either

The removal, encapsulation or enclosure of friable asbestos
The demolition, dismantling or repair of any building or structure, or parts of them in which insulating materials containing asbestos have been used, or in which asbestos products have been manufactured.

The owner or prime contractor must ensure the NOP is received at the WSBC at least 24 hours before starting the project; not just the day before the project, but less than 24 hours before work is due to begin. Sending NOPs either by fax, or electronically to the WorkSafeBC web site is acceptable.

Note: In some emergency circumstances such as flooded or fire-damaged buildings that contain or are suspected of containing asbestos, immediate work may be necessary to prevent injury to workers or damage to property. In such cases section 20.2(4) of the OHS Regulation permits work to begin as long as the nearest Board office is provided with an NOP at the earliest possible time. Section 20.2(4) does not relieve the employer of the obligation to comply with any other requirement of the OHS Regulation, including the obligation to conduct a pre-demolition risk assessment for asbestos. Work must be done safely.

Renovation and demolition scenarios
Ten common renovation and demolition scenarios are outlined in the Table "Guide for handling and removal of asbestos materials during demolition and renovation." The scenarios range from removal of spray-on friable asbestos insulation within a structure, to demolishing a structure using mechanical demolition equipment.

For each scenario, the Table provides information on five aspects of hazard control

The type of containment, from restricted access to partial or full containment
Work area controls to minimize the generation of dust and to otherwise control it if present
Personal protective equipment, particularly respiratory and body protection
Personnel decontamination, ranging from simple wash-up to full shower provisions
Site decontamination

The control measures outlined in the Table vary according to risk factors, and are intended to be consistent with the risk-based principles in the manual Safe Work Practices for Handling Asbestos.

One of the risk factors in the Table deals with whether or not the structure will be re-occupied. "Re-occupancy" refers to a circumstance where one or more workers or other building occupants without appropriate personal protective equipment will be returning into the abatement area following the abatement work. Re-occupancy involves a higher level of risk and typically a more stringent standard of work area control and decontamination.

For most scenarios a "Comments" section is included to outline the differences in control measures where no re-occupancy is expected or to provide further technical information.

There are several precautions when using the Table.

The Table does not include all possible scenarios. Sections 6.5 and 20.112 of the OHS Regulation establish the employer's obligation to identify asbestos at the work site. Section 6.6 requires that a risk assessment be done of any identified ACM and before any demolition, alteration or repair of machinery, equipment or structures where asbestos may be disturbed. It also requires that the level of risk be established, which will typically be high or moderate risk for renovation and demolition work. The assessment of ACM must be done by a qualified person. See section 6.6(4) of the OHS Regulation and OHS Guideline G6.6-3 for information on qualifications.

Measures to identify and assess asbestos may reveal additional scenarios and types of ACM. For any scenario, section 6.8 requires that proper procedures be in place.
The measures in the scenarios are considered only to be a guide to the expected standard of protection. There may be circumstances at a site where the assessment demonstrates a need to include additional or more stringent measures. In all cases, it is necessary to ensure that the control measures properly protect from exposure to asbestos. Measures must be in compliance with the OHS Regulation.
The Table does not cover all aspects of asbestos controls required by the OHS Regulation. Several examples are provided below.
- Air monitoring: Air monitoring must be done if a worker may be exposed to asbestos levels above 50% of the exposure limit of 0.1 fibre/ml, and in certain high risk circumstances specified in the Regulation.
- Some procedures are prohibited: Examples include pressure spraying to remove asbestos, and dry sweeping or using compressed air for clean-up. Procedures such as sanding of asbestos-contaminated flooring and similar surfaces should be avoided where possible, given the requirement in section 6.8 to prevent or minimize the release of airborne asbestos. Any sanding is considered to be high risk and requires a corresponding high level of control.
- Before starting work, all workers and supervisors must be properly trained: Training is required on matters including the hazards of asbestos, the means of identifying asbestos-containing materials at the worksite, the correct use and maintenance of personal protective equipment, the operation of required engineering controls, and the site-specific work procedures to be followed. Workers must be properly supervised.

Table: Guide for handling and removal of asbestos materials during demolition and renovation projects

Note: Explanations of the terms used in this Table are provided at the end of the Guideline.

Work area desig- nation and contain- ment	Work area controls	Personal protective equipment (See Note 1 at the end of the table)	Personnel decontam- ination (See Note 2 at the end of the table)	Site decontam- ination comments and explanation (See Note 3 at the end of the table)
Scenario 1: Spray-on friable asbestos insulation or fire-proofing materials, with re-occupancy
Full contain- ment	Material saturation procedures designed to eliminate or reduce the release of dust before and during disturbance and handling of materials; and HEPA-equipped ventilation cabinet	Air supplied respirator; Protective clothing; and Laceless rubber boots or other appropriate footwear designed to be easily decontam- inated	Full shower decontam- ination facility	Impervious waste containers; HEPA-equipped vacuum to ensure removal of all visible ACM (Wet wash-down also recommended); and Fibre sealant on exposed surfaces after cleaning
Comment: If there will be no re-occupancy, the above measures apply except that partial containment is acceptable as a means of work area containment. Also, the recommendation for wet-wash down would not apply as part of site decontamination as long as decontamination methods ensure removal of all visible ACM.
Scenario 2: Asbestos-containing textured ceiling or wall removal, with re-occupancy
Full contain- ment	Material saturation procedures designed to eliminate or reduce the release of dust before and during disturbance and handling of materials; and HEPA-equipped ventilation cabinet	Powered air-purifying respirator with NIOSH 100 Series filters; Protective clothing; and Laceless rubber boots or other appropriate footwear designed to be easily decontam- inated	Full shower decontam- ination facility	Impervious waste containers; HEPA-equipped vacuum to ensure removal of all visible ACM (Wet wash-down also recommended; and Fibre sealant on exposed surfaces after cleaning
Comment: If there will be no re-occupancy, the above measures apply except that partial containment is acceptable as a means of work area containment. Also, the recommendation for wet-wash down would not apply as part of site decontamination as long as decontamination methods ensure removal of all visible ACM.
Scenario 3: Asbestos cement products, with re-occupancy
Designated work area	Material saturation procedures designed to eliminate or reduce the release of dust before and during disturbance and handling of materials; and Controlled manual procedures	Half-facepiece dual cartridge air purifying respirator with NIOSH 100 Series filters; Protective clothing; and Laceless rubber boots or other appropriate footwear designed to be easily decontam- inated	Wash-up decontam- ination facilities	Impervious waste containers, or polyethylene-lined disposal bin; and HEPA-equipped vacuum to ensure removal of all visible ACM (Wet wash-down also recommended)
Comment: In some cases it may not be practicable to apply material saturation techniques. In such cases an alternative is to wet exposed surfaces of the ACM and mist the air during removal. If there will be no re-occupancy then the above measures apply except that the recommendation for wet wash-down would not apply as part of site decontamination procedures, as long as decontamination methods ensure removal of all visible ACM.
Scenario 4: Asbestos-containing joint tape or paper on ductwork, with or without re-occupancy
Designated work area	Glove bag and/or Material saturation procedures designed to eliminate or reduce the release of dust before and during disturbance and handling of materials; and HEPA-equipped vacuum	Half-facepiece dual cartridge air purifying respirator with NIOSH 100 Series filters; Protective clothing; and Laceless rubber boots or other appropriate footwear designed to be easily decontam- inated	Wash-up decontam- ination facilities	Impervious waste containers; and HEPA-equipped vacuum to ensure removal of all visible ACM

Scenario 5: Asbestos-containing filling compound on gypsum board, with re-occupancy
Partial contain- ment; or Full contain- ment	Material saturation procedures designed to eliminate or reduce the release of dust before and during disturbance and handling of materials; and HEPA-equipped ventilation cabinet	Half-facepiece dual cartridge air purifying respirator with NIOSH 100 Series filters; Protective clothing; and Laceless rubber boots or other appropriate footwear designed to be easily decontam- inated	Wash-up decontam- ination facilities; and HEPA-equipped vacuum	Impervious waste containers; and HEPA-equipped vacuum to ensure removal of all visible ACM (Wet wash-down also recommended)
Comment: In some cases it may not be practicable to effectively apply material saturation techniques to joint filling material, for example, if water resistant paints or coatings had previously been applied to the material. In such cases an alternative is to wet exposed surfaces of ACM and mist the air during removal. For gypsum board ceilings with ACM filling compounds it is appropriate to use full shower decontamination facilities. If there will be no re-occupancy then the above measures apply except that the recommendation for wet wash-down would not apply as part of site decontamination as long as decontamination methods ensure removal of all visible ACM.
Scenario 6: Vinyl asbestos floor tile or vinyl asbestos sheet flooring - with asbestos in the matrix of the flooring or adhesive, with re-occupancy
Partial contain- ment	Material saturation procedures designed to eliminate or reduce the release of dust before and during disturbance and handling of materials; and Controlled manual procedures, or HEPA-filtered local exhaust ventilation	Half-facepiece dual cartridge air purifying respirator with NIOSH 100 Series filters; Protective clothing; and Laceless rubber boots or other appropriate footwear designed to be easily decontam- inated	Wash-up decontam- ination facilities	Impervious waste containers or Polyethylene-lined disposal bin; and EPA-equipped vacuum to remove all visible ACM
Comment: During renovation work avoid sanding asbestos-contaminated surfaces wherever possible. In some cases it may not be practicable to effectively apply material saturation techniques. In such cases an alternative is to wet the exposed surfaces and mist the air during removal. If there will be no re-occupancy then the above measures apply except that the use of a HEPA-equipped vacuum in site decontamination is not necessary as long as decontamination methods ensure removal of all visible ACM.
Scenario 7: Vinyl sheet flooring - with asbestos in backing or underlay, with re-occupancy
Partial contain- ment; or Full contain- ment	Material saturation procedures designed to eliminate or reduce the release of dust before and during disturbance and handling of materials; HEPA-filtered local exhaust ventilation; and HEPA-equipped vacuum	Powered air purifying respirator with NIOSH 100 Series filters; Protective clothing; and Laceless rubber boots or other appropriate footwear designed to be easily decontam- inated	Full shower decontam- ination facility	Impervious waste containers; HEPA-equipped vacuum to ensure removal of all visible ACM (Wet wash-down also recommended); and Fibre sealant on exposed surfaces after cleaning
Comment: Where feasible, remove vinyl flooring and sub-floor as a unit, without de-lamination. If this is possible then application of fibre sealant is not necessary. Also, if procedures involve immediate application of a new flooring surface on top of the sub-floor then sealant would not be needed. During renovation work avoid sanding asbestos contaminated surfaces wherever possible. If there will be no re-occupancy then the above measures apply except that the recommendation for wet wash-down would not apply as part of site decontamination as long as decontamination methods ensure removal of all visible ACM.
Scenario 8: Loose-fill vermiculite attic or wall cavity insulation containing asbestos, with re-occupancy
Designated work area; or Partial contain- ment	HEPA-equipped vacuum suction system (eg. Vec loader); Wetting of vermiculite and air misting if manual removal methods (eg. scooping and bagging) are used; and For locations such as attics, maintain negative pressure to prevent fibre spread. Do not use compressed air to blow vermiculite	Powered air purifying respirator with NIOSH 100 Series filters if manual removal procedures are used in attics and similar spaces; Protective clothing; and Laceless rubber boots or other appropriate footwear designed to be easily decontam- inated	Full shower decontam- ination facility if manual removal procedures are used in attics and similar spaces	Impervious waste containers for waste removal; HEPA-equipped vacuum to ensure removal of all visible ACM; and Fibre sealant on exposed surfaces after cleaning.
Comment: Vermiculite itself does not contain asbestos. However, some vermiculite is contaminated with asbestos, typically tremolite or actinolite. Representative bulk sample collection and analysis of asbestos-contaminated vermiculite, by a qualified person, is needed to determine the type and amount of asbestos, and to establish any required safe work procedures for preventing harmful exposure. For bulk sample collection, take samples from the bottom of the insulation. This is because any asbestos will likely be present in greater amounts at the bottom due to the settling out of asbestos fibers from the vermiculite particles. Sampling only the top of the vermiculite may result in a false negative analysis for asbestos. While most vermiculite is likely to be found in attics and similar spaces, the product may also be found in locations such as hollow concrete block walls. In all cases, safe removal procedures are required. A heat stress assessment must be conducted if workers are or may be exposed to thermal conditions that could cause heat stress, for example, in enclosed attics. If there will be no re-occupancy then the above measures apply except that site decontamination may not require the application of sealant. In such cases misting of surfaces may be an appropriate alternative. Also, the use of a HEPA-equipped vacuum may not be necessary in site decontamination as long as decontamination methods ensure removal of all visible ACM.
Scenario 9: ACM asphalt roofing materials, with or without re-occupancy
Designated work area; or Partial containment where required to prevent wind dispersion	Controlled manual procedures, or HEPA-filtered local exhaust ventilation on equipment	Half-facepiece dual cartridge air purifying respirator with NIOSH 100 Series filters; and Protective clothing	Wash-up decontam- ination facilities	Polyethylene-lined disposal bin; and Decontam- ination methods that will ensure the removal of all visible ACM
Scenario 10: Using mechanical demolition equipment (for example, a backhoe) to demolish all or part of a house, building or other structure in proximity to publicly accessible areas
Designated work area around whole site	Remove asbestos cement products and friable ACM. Presoak remaining non-friable ACM, and use Water dust suppression. Monitor wind and control any potential for fibre spread offsite.	Half-facepiece dual cartridge air-purifying respirator with NIOSH 100 Series filters; and Protective clothing for affected workers including equipment operators	Wash-up decontam- ination facilities	Polyethylene-lined disposal bin; and Decontam- ination methods that will ensure the removal of all visible ACM
Comment: In Scenario 10, all friable ACM, for example, textured ceiling and wall material, and sprayed-on insulation or fireproofing, is to be removed before mechanical demolition of a structure. containment of asbestos by enclosure or encapsulation is typically not an option. It is also appropriate to remove all asbestos cement products, which can become friable during demolition. Selective sorting of waste materials can significantly reduce the quantities of asbestos waste. If the structure is in such a condition that it is dangerous to workers to undertake prior removal, the employer is expected to provide a risk assessment demonstrating such removal is unsafe and take necessary control measures that properly protect workers and others, including transportation and landfill personnel. Where the project involves removal of asbestos by means other than mechanical demolition equipment, then the applicable controls in Scenarios 1-9 apply.

Notes to the Table

Note 1 - Personal protective equipment (PPE)
The equipment noted in the Table is for protection against exposure to asbestos. Other hazards may also be present that require other PPE, for example, eyewear and hearing protection. One of the main issues in the selection of PPE for protection against asbestos is respiratory protection.

The selection of an appropriate respirator, including the facepiece, is based on the assurance that the maximum use concentration for that respirator is not exceeded (See OHS Regulation section 8.34; OHS Guideline a G8.34).

Single use or disposable respirators sometimes known as "dust masks" are not acceptable for any work with asbestos materials. The half-facepiece dual cartridge air purifying respirator with NIOSH 100 series filters is the minimum standard and is noted for some scenarios. In other scenarios with higher levels of risk, powered air purifying respirators (PAPRs) with NIOSH 100 Series filters or air supplied respirators are required.

The guidance on respiratory protection in the Table is based on the understanding that effective measures are in place to control the release of airborne asbestos. If the risk posed in a scenario is higher than anticipated in the Table, a more stringent level of protection is required.

For example, if exposure to asbestos-containing dust is expected to be substantial during the removal of drywall filling compounds, or if the removal of asbestos cement products generates substantial dust because of the methods used or condition of the material, then PAPRs may be required in place of half-facepiece cartridge respirators. In all cases, the employer must ensure the level of risk is properly assessed, and that protective equipment addresses that risk.

In some cases the risk may be lower than presumed in the Table. For example, if a mechanical method such as a Vec loader is used to remove vermiculite from wall cavities, a half-facepiece dual cartridge air purifying respirator may be sufficient. A lesser standard of respiratory protection may also be permitted in some other cases, if supported by the on-site risk analysis and application of section 8.34 of the OHS Regulation. Risk depends on factors such as removal methods, extent of disturbance of material, and the amount and concentration of asbestos.

Note 2 - Personnel decontamination facilities
The expectations for these facilities are based on estimates of typical conditions. There may be some variation in required facilities depending on the level of risk. In some cases more substantial facilities may be required. Examples include procedures that involve extensive overhead work to remove ACM, and circumstances where substantial dust can be generated, such as when pulverizing non-friable ACM. The need for a full shower decontamination facility in several scenarios is due to the anticipated ACM contamination inside protective clothing. In some cases a full shower facility may not be necessary if the hazard is sufficiently controlled. An example is Scenario 9, if HEPA vacuuming is used to remove vermiculite from hollow concrete block walls.

Note 3 - Site decontamination measures
For most of the scenarios in the Table, HEPA-vacuuming is noted as the appropriate means of site decontamination. This is because of its effectiveness. Where removal involves wet methods, it is good practice to HEPA-vacuum the surface after it has dried. In some cases, wet wash-down is recommended as an additional measure, for increased assurance of protection.

All asbestos-containing and asbestos contaminated wastes generated are to be placed in impervious containers. The containers must be labeled as asbestos waste material. The employer must ensure that hazardous wastes are handled in compliance with the OHS Regulation and the requirements of provincial and municipal authorities.

Explanation of terms used in the table

ACM (Asbestos-containing material)	Any materials where the asbestos content is equal to or exceeds 1% by weight using analytical procedures acceptable to the Board. Refer to section 6.1 of the OHS Regulation for the legal definition. Note: Where asbestos is present in amounts less than 1% as determined by bulk analysis methods, handling procedures and work processes may still generate airborne-asbestos fibre concentrations above the Exposure Limit of 0.1 f/ml. For example, this situation could arise with vermiculite insulation contaminated with asbestos. The potential for such conditions must be assessed. Work procedures and other necessary controls must be implemented to ensure asbestos fibre concentrations are controlled to levels at or as low as reasonably achievable below the Exposure Limit as per section 5.57(2) of the OHS Regulation.
Asbestos cement products	Include asbestos cement shingles, roofing tiles, siding (transite panels) and pipe, as well as non-friable cementitious stucco and plaster materials.
Asbestos waste	Any waste material generated on a worksite which meets the criteria for special waste set out by the Ministry of Environment or which contains 1% or more by weight of asbestos as determined by analytical procedures acceptable to the Board.
Controlled manual procedures	Manual removal procedures that are designed to minimize or prevent breakage and disturbance of asbestos materials, and do not involve the use of powered equipment or power tools.
Designated work area	A work area that includes the following measures: a) The boundaries of the work area identified by barricades, fences or similar means, with signs are posted at all entrances to the work area indicating that asbestos abatement work is in progress, the hazards of asbestos exposure, and the precautions that are required for entering into the work area. b) The work area cleared of all moveable objects, equipment, and materials that are not required during the work. c) Polyethylene drop sheets placed on the floor of the work area beneath the asbestos materials that are being removed, and over objects and materials that cannot be removed from the work area. d) All windows, doorways and other openings including ducts and vents sealed to prevent the release of asbestos fibres into areas beyond the boundaries of the work area. e) Access to an Asbestos Abatement Work Area restricted to trained, authorized, and supervised workers wearing appropriate respiratory protection and protective clothing.
Friable	In reference to a material, means that when dry, it can be easily crumbled or powdered by hand pressure, or is already crumbled or powdered. In other words, this term describes any asbestos-containing material that can, when dry, release airborne asbestos fibre easily due to manual handling methods and practices. Note: Non-friable material, including asbestos cement products, can become friable as a result of deterioration, mechanical destruction or abrasion forces.
Full contain- ment	Involves all of the requirements of the "Designated Work Area," as well as: a) Complete airtight isolation of the work area to prevent the escape of asbestos fibres by use of polyethylene sheeting (at least .15 mm (.0006 inch, or 6 mil)) thickness and duct tape, or similar impermeable materials. b) All floors, walls, and other surfaces in the work area covered with polyethylene sheeting of the same thickness sealed with tape. c) The work area containment inspected and repaired as necessary on at least a daily basis, and otherwise as required, to ensure that an airtight seal is maintained during asbestos abatement work.
Full shower decontamination facility	The facility will include a physical connection to the containment, a shower facility and provision for the safe entry and exit of workers. It will also meet the applicable requirements of section 5.82(2) & (3) of the OHS Regulation.
HEPA filter	High Efficiency Particulate Aerosol filter that is at least 99.97% efficient at collecting an aerosol particle 0.3 micrometer in size.
HEPA-equipped local exhaust ventilation	Local exhaust ventilation with HEPA filter used for the control of contaminants at the source; for example, a HEPA-equipped vacuum mounted on a power tool. Note the requirements of section 6.19 of the OHS Regulation to assess and maintain filters.
HEPA-equipped vacuum	HEPA filter-equipped vacuum used for cleanup and decontamination procedures or for local exhaust ventilation where appropriate. Note the requirements of section 6.19 of the OHS Regulation to assess and maintain filters.
HEPA-equipped ventilation cabinet	Portable ventilation cabinet equipped with HEPA filtration used to ventilate a containment and create a slight negative air pressure differential that ensures net air movement from outside the containment into it. This air movement reduces the risk of asbestos-contaminated air moving out of the containment. Note the requirements of section 6.19 of the OHS Regulation to assess and maintain filters.
Impervious waste container	Any container designed and made of a material which will contain all asbestos waste and will prevent the release of asbestos wastes and fibre during transport to and disposal at an approved disposal site. Examples include double 6 mil polyethylene disposal bags, and fibre barrels. The outside of the waste container must be labeled as asbestos-containing waste, as required by section 6.25 of the OHS Regulation. Tight-fitting lids or other covers that seal the container must be used with rigid containers such as barrels and bins. Disposal site operators may require specific types of containers or may have restrictions on the type of containers they will accept.
Laceless rubber boots or other appropriate footwear	Appropriate footwear will be in compliance with section 8.22 of the OHS Regulation, which requires among other things that footwear be of a design, construction and material appropriate to the protection required. Typically, wherever asbestos-containing dusts or debris are present, footwear is expected to be of a design that permits it to be easily decontaminated. Laceless rubber boots are an example of such a design. If other risks are present, such as slipping, uneven terrain, crushing potential or puncture hazards then the footwear must address those issues. Footwear must not create hazards greater than those it is intended to protect against.
Material saturation procedures	Procedures that involve the sufficient wetting of asbestos-containing material before and during removal to eliminate or substantially control airborne dust. Note that amended water containing surfactants (wetting agents) increases the capability for effective dust control, and is to be used particularly in high risk operations. The obligation to wet materials is found in section 6.22 of the OHS Regulation, and applies whenever such procedures are practicable
Mechanical demolition	Demolition methods and practices in which heavy machinery and equipment is used to tear down buildings and structures safely by use of a systematic plan of demolition.
Non-friable	A material whose composition or form creates a solid matrix which is not easily broken down. This term is used to describe any asbestos-containing material that binds the fibre into the composition matrix in a manner that prevents the release of the fibre under normal daily usage conditions. Normal daily usage conditions do not include situations such as installation, alteration, maintenance or removal practices. For example, floor tile can be walked on without changing its classification as non-friable, but removal may generate friable asbestos wastes.
Partial contain- ment	Involves all of the requirements of the "Designated Work Area," as well as isolation of the work area using polyethylene sheeting and duct tape or other impermeable materials to seal openings such as windows, doorways, stairways, elevators, heating ducts and vents. A partial containment will create an airtight work area that prevents the escape of asbestos fibres, without the complete draping of walls, floors, and ceilings as required by a full containment.
Presoaking of non-friable ACM	Presoaking of all non-friable ACM prior to mechanical demolition being done which may disturb the ACM, for example, by flooding asbestos-containing flooring material or other ACM.
Protective clothing	Clothing which is made of a material resistant to penetration by asbestos fibres, fits snugly at the neck, wrists and ankles, and as necessary to protect against the risk covers the head and feet as well as the body. Disposable protective clothing is recommended. Reusable coveralls are to be cleaned and laundered as required by sections 6.30 and 6.31 of the OHS Regulation. Protective clothing is to be immediately repaired or replaced if torn. Street clothes are not to be worn under protective clothing if work is conducted inside a containment or in circumstances that require the use of full shower decontamination facilities. Heat stress potential must be considered and properly addressed.
Re-occupancy	A circumstance where one or more workers or other building occupants will be returning into the abatement area following the abatement work.
Stationary drop sheets	Drop sheets taped in place to prevent lifting.
Wash-up decontamination facilities	Facilities for wash-up and decontamination, with provision for soap and water, changed regularly after use to ensure cleanliness.
Water dust suppression	Use of water for dust suppression, for example, area water spraying to suppress dust during mechanical demolition procedures.

G6.10 Substitution

Issued August 1, 1999

Section 6.10 of the OHS Regulation requires that, when practicable, the employer substitute asbestos with less hazardous material. In selecting a substitute, the requirements of section 5.55(2) apply. That is, the employer must ensure that the hazards of the substitute are known and that the risk to workers is reduced. In addition, the substitute should not create a significant hazard that the asbestos-containing product or material would otherwise abate or control. For example, some gaskets made of alternate material may blow out under certain conditions of use, thereby creating a safety hazard. OHS Guideline G5.55 contains a list of factors that should be considered when selecting a suitable substitute.

Designated Work Areas and containments

G6.13 Authorized persons - Designated area

Issued August 1, 1999

Section 6.13(3) of the OHS Regulation provides that the employer must restrict entry into designated work areas to "authorized persons who are adequately protected against the level of risk within the designated work area."

In the context of this section, "authorized persons" are workers who are qualified to perform the work, have been designated by the employer as being permitted to do so, and are permitted to be present within the designated work area(s).

G6.16 High risk work

Issued August 1, 1999

For high risk work activities, section 6.16(2) of the OHS Regulation provides that the employer must inspect a containment and a decontamination facility at least daily to ensure that their effectiveness is maintained. Section 6.1 of the Regulation defines both high and low risk work activities.

Containment and decontamination facilities will be considered to be effective if they can be reasonably expected to confine asbestos materials and fibres within a contained and controlled area. In particular, the system should:

be airtight in design (see section 6.14),
be of substantial construction to support the anticipated stress factors likely to be encountered in the course of work (see section 4.2), and
utilize recognized design considerations common to the industry norms or follow reasonable parameters of control supported by occupational hygiene principles (e.g. good ventilation design, overlap of plastic poly sheet joints and water-resistant duct tape).

When evaluating compliance with this requirement, the system should be checked to see if it is under negative pressure. Smoke or air current tubes can be used for this purpose.

Additional information regarding procedures for removal or encapsulation of asbestos or asbestos-containing materials can be found in the WCB publication "Safe Handling of Asbestos - A Manual of Standard Practices."

Ventilation

G6.19 Ventilation - Filter testing

Issued August 1, 1999; Editorial Revision April 2005; Editorial Revision February 1, 2008

Regulatory excerpt
Section 6.19(1) of the OHS Regulation ( "Regulation") states:

The employer must assess the effectiveness of HEPA filters by DOP (dioctyl phthalate) testing or similar means at least annually, after a HEPA filter is replaced in a vacuum cleaner or ventilation system, and before use in high risk work activity.

Purpose of guideline
The purpose of this guideline is to describe how to assess the effectiveness of a HEPA filter under section 6.19(1).

Effective HEPA filters
Section 6.19(1) of the Regulation requires the employer to "assess the effectiveness of HEPA filters by DOP (dioctyl phthalate) testing or similar means at least annually, after a HEPA filter is replaced in a vacuum cleaner or ventilation system, and before use in high risk work activity." The definition of high risk work activity is provided in section 6.1 of the Regulation.

HEPA filters will be considered to be "effective" if the filter can pass a visual inspection of the filter media, as well as a filter testing protocol. The visual inspection is intended to identify any apparent damage and to examine the integrity of the seal in the filter frame. The filter testing protocol must use dioctyl phthalate (DOP) or other appropriate challenge test material. Where the HEPA ventilation unit(s) are moved or transported in a manner that could compromise the integrity of the HEPA filter, the units should be tested in situ prior to any disturbance of asbestos materials. The methods used for onsite testing should conform to the HEPA filter leak test requirements of National Sanitation Foundation (NSF) Standard 49-2002, Class II (Laminar Flow) Biohazard Cabinetry. These requirements are found in Annex F of the NSF standard. OHS Guideline G30.12 has additional information.

It is recommended that the following information be clearly posted on HEPA filters meeting the test criteria:

Testing agency
Name of the tester
Date of testing
Results of the test

This information could be in the form of a label.

The employer is also required under section 4.3(2) of the Regulation to maintain all HEPA filters in ventilation systems and vacuum cleaners in accordance with manufacturer's instructions, or as specified by a professional engineer, to ensure that they remain effective.

Other Means of Controlling Exposure to Asbestos

G6.24-1 Friction materials

Issued August 1, 1999

Section 6.24 of the OHS Regulation prescribes the control measures that an employer must implement in automotive service procedures involving asbestos-containing friction material or the dust arising from such material. This section applies primarily to the servicing of brakes and clutches involving (or potentially involving) asbestos-containing friction materials. For asbestos gaskets and muffler seals, other general duty requirements for controlling exposure to asbestos apply. Refer to relevant sections of Part 6 for controlling exposure to asbestos, as well as the sections in Part 5 on controlling exposure, ventilation, personal hygiene, and emergency washing facilities.

The term "may involve asbestos-containing friction material" is intended to address the uncertainty associated with determining where asbestos-containing friction materials are or have been used. The automotive service industry is not expected to test every material for the presence of asbestos. This would clearly be impracticable. However, in situations where it is unclear whether the friction material contains asbestos, the industry is expected to implement control measures to protect workers from being potentially exposed to asbestos.

G6.24-2 Dry removal of friction material dust

Issued August 1, 1999

Section 6.24(a) of the OHS Regulation prohibits the dry removal of friction material dust from automotive assemblies using compressed air, brushes, or other similar means. This prohibition is intended to cover open shop procedures or methods of dry removal. It is not intended to prohibit dry removal of friction material in HEPA-filtered vacuum enclosure systems. It is recognized that some systems specify the use of brushes and "controlled" compressed air within the enclosure systems. However, to ensure that the seal is not compromised, these systems must be used according to the manufacturer's instructions (see section 4.3). Further information regarding HEPA-filtered vacuum enclosure systems is provided below (see "HEPA-filtered vacuum enclosure systems").

Examples of "other similar means" of dry removal include any practice, method or procedure that is not designed to control the release and spread of dusts likely to contain asbestos fibre into areas where unprotected workers may be present.

G6.24-3 Suitable work procedures

Issued August 1, 1999

Section 6.24(c) of the OHS Regulation requires suitable work procedures be followed to minimize the generation of airborne dust. NIOSH has published recommended procedures to minimize exposure to asbestos and asbestos-containing dust during servicing of motor vehicle brake and clutch assemblies.

Suitable work procedures include

negative pressure enclosure/HEPA vacuum system methods (see OHS Guideline G6.24-4)
low pressure /wet cleaning methods
wet methods.

For further information, refer to OSHA Regulations Standard 1910.1001 Appendix F: "Work practices and engineering controls for automotive brake and clutch inspection, disassembly, repair and assembly." This 1995 document is available on the Internet at the OSHA website.

G6.24-4 HEPA-filtered vacuum enclosure systems

Issued August 1, 1999

"HEPA-filtered vacuum enclosure systems" refer to any number of enclosure systems designed to effectively isolate brake assemblies inside a cabinet, which is continuously vented through a vacuum system. A HEPA-filtered vacuum enclosure system is acceptable if

there is a tight-fitting collar or seal system, which provides a close fit around the brake assembly and wheel backing plate or rotor,
an inward air flow through the system can be demonstrated,
the vacuum filters have been tested as required under section 6.19 of the OHS Regulation,
the manufacturers' instructions for the assembly, use, maintenance and repair of the system are followed, and
workers are adequately instructed and trained in its use and operation.

Waste Handling and Disposal

G6.27 Asbestos waste removal

Issued May 24, 2002; Editorial Revision October 2004

Section 6.27 of the Occupational Health and Safety Regulation states:

The employer must remove all asbestos dust and debris from the work area with a vacuum cleaner equipped with a HEPA-filtered exhaust, or by other means acceptable to the board, while the work is in progress, at the end of each work shift, and at the completion of work involving asbestos.

The purpose of this section is to minimize the potential for asbestos fibres to accumulate and become airborne when someone is working with asbestos. This guideline provides information on what are "other means acceptable to the board." When the OHS Regulation refers to asbestos waste cleanup, this activity is expected to be carried out only in a controlled environment such as a designated work area or a containment area as described by section 6.13, with workers wearing the appropriate personal protective equipment.

In these controlled environments, other than using a HEPA-filtered vacuum cleaner, the following asbestos waste cleanup procedures are acceptable to the Board.

Wiping surfaces with a damp cloth or sponge to clean up residual amounts of debris.
Wet sweeping or wet mopping of larger amounts of debris.
Using a shovel to place larger amounts of dampened debris into a designated container or plastic bag.
Using a controlled water stream amended with a wetting agent (surfactant).
Applying a sealant or encapsulant with an airless or low-pressure application method.

Other practices, such as dry sweeping or dry dusting, blowing with compressed air, and washing with high-pressure water, should not be used for asbestos waste cleanup.

Further details are provided by the WCB publication Safe Work Practices for Handling Asbestos (BK27). This publication is available in PDF format on the Board's Internet site at www.worksafebc.com/publications/health_and_safety_information/
by_topic/assets/pdf/asbestos.pdf. A print copy may be ordered by contacting the local WCB office.

Personal Protective Clothing and Equipment

G6.31 Contaminated personal protective clothing - Information to laundry workers

Issued August 1, 1999

Section 6.31 of the OHS Regulation provides that "the employer must ensure that workers who launder clothing contaminated with asbestos are informed of the hazards of asbestos and the precautions required for handling the clothing."

Under section 5.82(1)(b) of the OHS Regulation, the employer is responsible for laundering protective clothing contaminated with asbestos (see OHS Guideline G5.82). However, before protective clothing contaminated with asbestos can be sent to an acceptable laundry facility, the employer must, under section 6.30(5) of the OHS Regulation, ensure that it is cleaned with a vacuum cleaner, equipped with a HEPA-filtered exhaust, and placed in a water-soluble plastic bag. This plastic bag must be sealed and labelled. A commercial laundry or linen service would be considered an "acceptable" laundry facility if they are capable of handling contaminated laundry.

The requirements of sections 12.157 and 12.158 of the OHS Regulation also apply.

Documentation

G6.32 Documentation - Types of records

Issued August 1, 1999

Section 6.32(1) of the OHS Regulation requires the employer to maintain records of inventories and risk assessments, inspections (risk assessments) and results of air monitoring (refer to sections 6.4, 6.6, and 6.12, respectively). These records must be maintained for at least 10 years. In addition, under section 6.32(2), the employer must maintain records of any corrective actions taken to control the release of asbestos fibre, training and instruction of workers, written work procedures and written notifications of the board. These records must be maintained for at least 3 years.

Guidelines Part 6 - Biological agents

G6.34-1 Exposure control plan

Issued August 1999; Editorial Revision July 2004; Editorial Revision February 2, 2006; Revised February 1, 2008

Regulatory excerpt
Section 6.34(1) of the OHS Regulation ("Regulation") states:

(1) If a worker has or may have occupational exposure, the employer must develop and implement an exposure control plan, based on the precautionary principle, that meets the requirements of section 5.54 and that includes the following:

(a) a risk assessment conducted by a qualified person to determine if there is a potential for occupational exposure by any route of transmission;

(b) a list of all work activities for which there is a potential for occupational exposure;

(c) engineering controls and administrative controls to eliminate or minimize the potential for occupational exposure;

(d) standard or routine infection control precautions and transmission-based precautions for all work activities that have been identified as having a potential for occupational exposure, including

(i) housekeeping practices designed to keep the workplace clean and free from spills, splashes or other accidental contamination,

(ii) work procedures to ensure that contaminated laundry is isolated, bagged and handled as little as possible, and

(iii) work procedures to ensure that laboratory or other samples containing a biological agent designated as a hazardous substance in section 5.1.1 are handled in accordance with the Laboratory Biosafety Manual issued by the World Health Organization, as amended from time to time, and the Laboratory Biosafety Guidelines issued by Health Canada, as amended from time to time;

(e) a description of personal protective equipment designed to eliminate or minimize occupational exposure;

(f) a program to inform workers about the contents of the exposure control plan and to provide them with adequate education, training and supervision to work safely with, and in proximity to, a biological agent designated as a hazardous substance in section 5.1.1;

(g) a record of all training and education provided to workers in the program described in paragraph (f);

(h) a record of all workers who have been exposed, while performing work activities, to a biological agent designated as a hazardous substance in section 5.1.1.

Purpose of guideline
The purpose of this guideline is to provide some examples of workplaces which are likely to require an exposure control plan (ECP).

Occupational exposure
The requirement to develop and implement an ECP applies to all workplaces where a worker has or may have occupational exposure. "Occupational exposure," as defined in section 6.33 of the Regulation, is the reasonably anticipated contact with a biological agent, that is designated as a hazardous substance in section 5.1.1, resulting from the performance of a worker's duties.

Most health care workers, lab workers, emergency responders, fire fighters and occupational first aid attendants in general industry, are likely to have occupational exposure. In addition some janitorial or custodial staff in hospitality industries in high risk areas, public utility or municipal workers with outside jobs in high risk areas, and social service agency workers in high risk areas may have such exposure.

Some workplaces in which workers typically have occupational exposure include, but are not limited to those listed in the table below.

Partial list of workplaces which are likely to require an exposure control plan
Physicians' offices Medical and dental laboratories Hospitals Hemodialysis centers Blood and tissue banks Nursing homes Home health care Fire and rescue Ambulance services Funeral homes and crematories Commercial laundries serving health care and public safety institutions Schools Workers employed in the woods involving potential exposure to ticks and Lyme Disease Workers who may have exposure to hantavirus when handling rodents or cleaning up dust contaminated with rodent urine and feces	Dental offices Medical & dental equipment repair Outpatient facilities (including renal dialysis clinics and cancer treatment centers) Drug treatment centers Research labs Residential care facilities Hospices Law enforcement Correctional institutions Health clinics in industrial facilities Personnel services Removal of regulated waste or sewage Workers in agriculture where there is potential exposure to mouldy hay, or who are exposed to zoonotic diseases (brucellosis, for example)

Partial list of workplaces which are likely to require an exposure control plan

Physicians' offices
Medical and dental laboratories
Hospitals
Hemodialysis centers
Blood and tissue banks
Nursing homes
Home health care
Fire and rescue
Ambulance services
Funeral homes and crematories
Commercial laundries serving health care and public safety institutions
Schools
Workers employed in the woods involving potential exposure to ticks and Lyme Disease
Workers who may have exposure to hantavirus when handling rodents or cleaning up dust contaminated with rodent urine and feces

Dental offices
Medical & dental equipment repair
Outpatient facilities (including renal dialysis clinics and cancer treatment centers)
Drug treatment centers
Research labs
Residential care facilities
Hospices
Law enforcement
Correctional institutions
Health clinics in industrial facilities
Personnel services
Removal of regulated waste or sewage
Workers in agriculture where there is potential exposure to mouldy hay, or who are exposed to zoonotic diseases (brucellosis, for example)

Elements of an ECP are listed in section 5.54 and section 6.34(1) of the Regulation. Required elements of an ECP will depend on the circumstances of the workplace and the outcome of the risk identification required by section 6.34(1)(a) of the Regulation.

G6.34-2 Risk assessment, engineering and administrative controls, and personal protective equipment

Formerly issued as G6.35, G6.36(1), and G6.36(2); Issued as G6.34-2 February 1, 2008. (Note: Former G6.34-2 on pandemic influenza has been renumbered as G6.34-6.)

Regulatory excerpt
Section 6.34(1) of the OHS Regulation ("Regulation") states:

(1) If a worker has or may have occupational exposure, the employer must develop and implement an exposure control plan, based on the precautionary principle, that meets the requirements of section 5.54 and that includes the following:

(a) a risk assessment conducted by a qualified person to determine if there is a potential for occupational exposure by any route of transmission;

(b) a list of all work activities for which there is a potential for occupational exposure;

(c) engineering controls and administrative controls to eliminate or minimize the potential for occupational exposure;

And section 6.34(1)(e) of the Regulation states:

(1) If a worker has or may have occupational exposure, the employer must develop and implement an exposure control plan, based on the precautionary principle, that meets the requirements of section 5.54 and that includes the following:
...

(e) a description of personal protective equipment designed to eliminate or minimize occupational exposure;

And section 5.55(3) of the Regulation states:

(3) The use of personal protective equipment as the primary means to control exposure is permitted only when

(a) substitution, or engineering or administrative controls are not practicable, or

(b) additional protection is required because engineering or administrative controls are insufficient to reduce exposure below the applicable exposure limits, or

(c) the exposure results from temporary or emergency conditions only.

Purpose of guideline
The purpose of this guideline is to provide information on what should be included in a risk assessment required under 6.34(1)(a), and discuss ways to control risks using engineering and administrative controls under section 6.34(1)(c). The guideline also discusses appropriate personal protective equipment (PPE) under section 6.34(1)(e).

Risk assessment
The objective of the risk assessment is to determine the jobs, tasks, and procedures for which occupational exposure is anticipated and to evaluate the likelihood that such exposure would occur. The factors to be considered will be dictated by the circumstances of the workplace and the type of biological agents designated as hazardous substances that workers are potentially exposed to.

A qualified person is required to conduct the risk assessment. A qualified person may be a medical or non-medical professional. This could include infection control practitioners, registered nurses, and physicians, occupational hygienists, microbiologists, or other individuals with specialized training in the area of biological agents designated as a hazardous substance under section 5.1.1 of the Regulation.

As part of the risk assessment, the job classifications should be reviewed within the workplace and categorized according to those jobs in which all workers have occupational exposure and those jobs in which some of the workers have occupational exposure. Where all workers have occupational exposure, such as scrub room nurses, clinical dental hygienists, and paramedics, it is not necessary to list individual work tasks, as long as it is made clear that all work activities have such exposure. Where only some workers have exposure, the specific tasks and procedures causing exposure need to be listed. All first aid attendants are considered to have occupational exposure.

When evaluating the potential for exposure, as well as the risk associated with exposure, the following sources of information should be considered:

History of firm, including first aid records and accident/incident investigation reports
WorkSafeBC claims records and statistics
History of similar industries, similar exposure conditions, history of other firms in the same geographical area, and industries dealing with the same client group
Information from other jurisdictions or agencies, such as Occupational Safety and Health Administration (OSHA) or National Institute for Occupational Safety and Health (NIOSH).

The potential for occupational exposure must be evaluated without regard to the availability or use of personal protective clothing and equipment. That is, the risk to an unprotected worker must be assessed.

If there is a question regarding the potential for exposure one should

Determine whether the worksite requires an exposure control plan (refer to OHS Guideline G6.34-1)
Consult the employers' risk assessment to determine if the occupation or task has been identified
Evaluate the risk of occupational exposure. If necessary, contact the WorkSafeBC occupational health physicians for assistance
If there is a risk of occupational exposure, determine whether the risk has been minimized with any of the following:
- Engineering controls
- Administrative controls
- PPE
- Adequate training and supervision of the workers

Engineering controls
Section 6.34(1)(c) requires an employer to use either engineering controls or administrative controls to eliminate or minimize the potential for occupational exposure. Part 1 of the Regulation defines "engineering controls" as follows:

the physical arrangement, design or alteration of workstations, equipment, materials, production facilities or other aspects of the physical work environment, for the purpose of controlling risk.

Engineering controls for occupational exposure include, but are not limited to

Safety-engineered needles (e.g. syringes that include a needle retraction mechanism or other type of integral needle guard mechanism)
Blunt tip sutures
Needleless devices (devices that do not use a needle for the collection of body fluids, administration of medication or fluids, or any other procedures with potential exposure to a bloodborne pathogen; e.g. needleless intravenous connectors)
Retracting lancets
Automatic re-sheathing of disposable scalpels
Puncture-resistant containers for sharps (sharps include anything that might produce a puncture wound that would expose a worker to blood or other potentially infectious material, such as broken glass, scalpels, contaminated ends of orthodontia wire, and suture needles)
Splatter guards
Biological safety cabinets
Mechanical pipetting systems
Negative pressure isolation, which is an isolation and ventilation control for biological agents that are transmitted via the airborne route and that pose an inhalation hazard. This involves isolating infectious patients in an isolation room under negative pressure through an independent air supply and exhaust system for the isolated area/room
Triage stations - isolating medical staff from potentially infectious persons requiring medical attention through installation of protective barriers

Engineering controls must be properly selected, used, inspected, maintained, and replaced as needed to ensure their effectiveness. Selected engineering controls must eliminate or minimize the risk of an exposure incident. Section 4.3 requires that each tool be selected, used, and operated in accordance with the manufacturer's instructions (if available), safe work practices, and the requirements of the Regulation.

For other engineering controls necessary in the laboratory, see sections 30.12 (Biological safety cabinets), 30.13 (Centrifuges), 30.16 (Transport of containers), and 30.17 (Personal protection) of the Regulation. For ventilation of isolation rooms refer to sections 4.72 to 4.78.

Administrative controls
Section 6.34(1)(c) requires an employer to use either engineering controls or administrative controls to eliminate or minimize the potential for occupational exposure. Part 1 of the Regulation defines "administrative controls" as follows:

the provision, use and scheduling of work activities and resources in the workplace, including planning, organizing, staffing and coordinating, for the purposes of controlling risk.

Administrative controls for occupational exposure include, but are not limited to

Adopting general infection control measures
Washing hands with a suitable, non-abrasive cleansing agent and running water immediately after removal of gloves and as soon as possible after skin contact with blood or other potentially infectious material
Disposing of contaminated needles immediately after use in a readily available sharps container specifically designed for such use
Applying the "hands-free " method of passing scalpels during a surgical procedure, such as using a small hand tray to transfer scalpels and other sharps to and from the surgeon's hand
Placing contaminated reusable sharps in containers that are puncture-resistant and leak-proof, such as stainless steel trays
Using tongs or other suitable means, such as a dust pan and disposable brush, to pick up broken glass contaminated with blood
Prohibiting the bending, manual recapping, or removing of contaminated needles
Preventing the storage of food and/or drink in refrigerators or other locations where biological agents designated as hazardous substances under section 5.1.1 are present
Keeping the number of workers potentially exposed to a biological agent to a minimum
Restriction of visitors
Restricting contact between workers and potentially infectious persons during an epidemic or pandemic outbreak - refer to OHS G6.34-6
Limiting and controlling patient transportation/transfers
Isolating infectious persons once hospitalized
Medical surveillance for persons entering a medical facility
Quarantining exposed staff
Worker education and training, including drills

Personal protective equipment
The Regulation does not dictate what kind of PPE should be used for a given circumstance. This decision rests with each employer and must be based on the specific exposure circumstances in the workplace. The results of the risk assessment required under section 6.34(1)(a) and Part 8 of the Regulation can help the employer to determine appropriate levels of protection. Under section 8.4, the workplace evaluation to determine appropriate PPE must be done, where practicable, in consultation with the occupational health and safety committee or the health and safety representative, as applicable and with the worker who will use the equipment.

Workers must use appropriate PPE to prevent occupational exposure. Appropriate PPE may include, but is not limited to gloves, gowns, lab coats, coveralls, booties, face shields, eye protection, and respirators. For airborne or aerosolized occupational exposure, a NIOSH-approved, particulate respirator may be required.

Appropriate PPE for occupational first aid attendants includes an approved particulate face piece respirator and latex or other waterproof gloves to prevent accidental contact with blood or body fluids.

To evaluate compliance, the following questions should be considered:

Under normal conditions and time of use, does the PPE prevent a biological agent designated as a hazardous substance under section 5.1.1 from
- Passing through a worker's work clothes, street clothes, undergarments?
- Reaching an employee's skin, eyes, nose, mouth, or other mucous membranes?
- Being inhaled into the respiratory tract?
Has the PPE been selected and used in accordance with the manufacturer's instructions and recognized standards? Does it provide effective protection? See section 8.3(1)(a) of the Regulation
Does the PPE in itself create a hazard to the wearer? See section 8.3(1)(b)
Does the PPE cause allergenic or other adverse health effects? See section 8.2(3)

Some workers may be allergic to natural rubber latex gloves. The WorkSafeBC pamphlet, Dealing with Latex Allergies at Work, should be consulted for more information and used as a resource by workers exposed to natural rubber latex products. The Laboratory Centre for Disease Control (a branch of Health Canada) considers disposable, good quality, non-latex gloves made of vinyl, nitrile, neoprene, copolymer, and polyethylene to be adequate barriers to bloodborne pathogens.

Additional resources
For additional information on the prevention of occupational exposure, refer to the WorkSafeBC website http://www2.worksafebc.com/Portals/HealthCare/Home.asp or http://www2.worksafebc.com/Portals/HealthCare/InfectiousDiseases.asp (e.g. this site contains information on common injuries and illnesses in the health care industry and a booklet entitled HIV/AIDS, and Hepatitis B and C: Preventing Exposure at Work).

G6.34-3 Housekeeping and laundry practices

Formerly Issued as G6.36(3) and G6.36(4); Issued as G6.34-3 February 1, 2008

Regulatory excerpt
Section 6.34(1) of the OHS Regulation ("Regulation") states:

(1) If a worker has or may have occupational exposure, the employer must develop and implement an exposure control plan, based on the precautionary principle, that meets the requirements of section 5.54 and that includes the following:
...

(d) standard or routine infection control precautions and transmission-based precautions for all work activities that have been identified as having a potential for occupational exposure, including

(i) housekeeping practices designed to keep the workplace clean and free from spills, splashes or other accidental contamination,

(ii) work procedures to ensure that contaminated laundry is isolated, bagged and handled as little as possible, and

Purpose of guideline
The purpose of this guideline is to provide information on housekeeping and laundry practices.

Housekeeping practices
The requirements of section 6.34(1)(d)(i) of the Regulation apply to a broad range of fixed and non-fixed workplaces, including labs, operating rooms, accident scenes, ambulances, and refrigerated blood transfer vehicles.

To keep the workplace clean and sanitary, the employer must develop and implement appropriate methods of decontamination. This would include details on

Location within the facility (indoor vs. outdoor)
Type of surfaces to be cleaned
Size of the spill (for example, gross, splatter, smear) or type of organism present
Tasks or procedures to be performed, including
- What kind of sterilant or disinfectant is to be used
- How much should be used
- How often it should be applied

Decontamination is the use of physical or chemical means to remove viable microorganisms from surf

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