BOP Program Statement 1614.01 § 42

29 CFR 1910.1000 of OSHA regulations is the governing authority for determining employees’

exposure to any material listed in table Z-1, Z-2, or Z-3 of that section. A determination of

noncompliance with permissible exposure limits (PELs) requires measurement and

documentation of an overexposure to at least one employee. For air contaminants with PELs,

sampling must be conducted by a qualified source as directed by the Bureau’s Industrial

Hygienist.

When testing indicates controls are needed to prevent atmosphere contamination, engineering

control measures must be used if possible (e.g., enclosure or confinement of the operation,

general and local ventilation, and substitution of less toxic materials).

a. Lead. Projects involving lead must comply with federal, state, and local laws and

regulations. Guidelines from 29 CFR 1926.62, Lead, are the minimum standards for operational

and maintenance procedures. Before beginning any work involving lead, the SA must review the

project.

Personnel who have received training and follow proper health and safety requirements may

work on projects where lead-contaminated materials are found.

Lead paint may not be used or stored in Bureau facilities.

Indoor firing ranges used by Bureau employees, whether owned and operated by the Bureau or

contracted, must have properly permitted exhaust ventilation engineered to maintain airborne

lead particulate concentrations below 30 micrograms per cubic meter (30 ug/m³) as an eight-hour

time-weighted average.

b. Asbestos. If a substance is suspected to be an asbestos-containing material (ACM), it must be

handled as such until proven otherwise by laboratory analysis. Except for UNICOR brake shoe

and clutch operations, at no time may known or suspected ACM be removed or disturbed without

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the approval of the SA and the Facilities Manager on an “Asbestos Work Permit.”

Other than small-scale emergency repair/cleanup or UNICOR brake or clutch work, projects

involving asbestos must be contracted and meet the requirements of 29 CFR 1926.1101. Inmates

must not work on projects that involve abatement or repair of asbestos, except UNICOR inmates

completing brake or clutch work who have received verifiable training. These inmates may

inspect, remove, and repair asbestos brake and clutch assemblies per 29 CFR Part 1910 Subpart

Z.

Qualified employees may perform short-duration, small-scale operations involving no more than

one glove bag of asbestos-containing material per 29 CFR 1926 (e.g., pipe repair, valve

replacement, and patch or repair jobs on asbestos insulation).

 Respirators and Protective Clothing. Work involving known or suspected ACM

requires, at a minimum, half-face respirators with filters and disposable coveralls.

 Respiratory protection and disposable full-body coveralls must be worn by personnel

doing asbestos brake or clutch work until initial personal air monitoring indicates

asbestos levels below the OSHA exposure limit.

 Automotive Work. Except for UNICOR brake and clutch operations, institutions must

never allow personnel to replace or remove asbestos-lined equipment from a vehicle,

including brake pads, brake shoes, and clutch linings.

Contract work must be done on an as-needed basis until asbestos-containing material is

removed and documented in the vehicle file. Documentation must indicate “non-asbestos

replacement parts” and the installation date.

These procedures also apply to Automotive V ocational Training (VT) programs. Mock

training aids using non-asbestos-containing materials may be used instead of hands-on

training. “Live” work may only be done on documented non-asbestos-containing

materials.

 Responsibilities.

 The SA must ensure:

 Monthly inspection documents for needed repairs on known or suspected ACM

are completed and maintained. Institutions with documentation showing they are

free of asbestos-containing material can eliminate these inspections.

 PPE is provided and used. UNICOR funds PPE for its facilities.

 Work orders are forwarded to the Facilities Manager, who must ensure:

• New projects potentially involving asbestos removal are presented to the

Work Programming Committee.

• Proper work procedures are followed by Facilities employees working with

asbestos.

• Waste generated during facilities-related asbestos work is disposed properly.

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 The UNICOR Factory Manager must ensure:

 Employees supervising brake and clutch repair operations receive training from

an outside source, per 29 CFR Part 1910 Subpart Z. This qualifies the supervisor

to train inmates who perform asbestos brake removal.

 Inmates who work on known or assumed asbestos-containing brakes and clutch

linings receive training from a qualified supervisor, per 29 CFR Part 1910 Subpart

Z.

 Proper work procedures are followed by personnel working with known or

assumed asbestos-containing brakes and clutch linings.

 Through the services of an industrial hygienist, initial and annual personal air

monitoring of workers is provided to confirm the effectiveness of engineering

controls and workplace practices.

 Asbestos waste generated during UNICOR-related asbestos work is disposed of

properly.

 With the assistance of the Occupational Safety and Health Department, a written

Asbestos Brake and Clutch Removal Plan details engineering controls, work

practices, training methods, and waste disposal procedures.

 Removal/Demolition. Removal/demolition projects involving asbestos-containing

materials must adhere to OSHA 29 CFR 1926 and EPA 40 CFR Part 61 Subpart M –

National Emission Standard for Hazardous Air Pollutants, and state and local

requirements. Due to the complexity of such projects and their strict regulatory

safeguards, in-house asbestos removal or demolition, except for small-scale emergency

repair/cleanup, is prohibited.

Contracts for asbestos abatement projects and specifications must be approved by the Regional

Facilities Administrator and the RSA before work begins. While specifications vary from project

to project, compliance with applicable regulations is mandatory.

As required by 40 CFR Part 61 Subpart M, the Regional EPA Asbestos Coordinator or governing

state environmental agency must be notified in writing at least 20 days before the start of an

asbestos removal or demolition project. A copy of the notification must be kept in the Facilities

project file.

c. Respirable Crystalline Silica. OSHA Standards 1910.1053 and 1926.1153 address the

requirements for protecting employees from exposure to silica dust in the workplace. The SA,

along with assistance from the Facilities Manager, are the technical experts in assessing program

requirements under the standards.

 Written Program. A written Respirable Crystalline Silica plan must be developed that

includes, at a minimum:

 Description of the tasks in the workplace that involve exposure to respirable

crystalline silica

 Engineering controls, work practices, and respiratory protection used to limit

exposure for each task

 Housekeeping measures used to limit exposure

 Description of procedures used to limit access to work areas in which respirable

crystalline silica is produced

 Tasks that Involve Exposure to Respirable Crystalline Silica. The SA, along

with assistance from the Facilities Manager must evaluate the workplace to

determine any tasks that involve exposure to respirable crystalline silica. These

tasks need to be addressed in the written plan.

 Engineering Controls. Control methods listed in Table 1 of 29 CFR 1926.1153

must be used to limit exposure based on the type of task or equipment.

 Housekeeping. Dry sweeping or dry brushing must not be used where it could

contribute to employee exposure to respirable crystalline silica. Wet cleaning

methods or the use of vacuums with HEPA filtration should be used in the

cleaning process.

 Procedures Used to Limit Access to Work Areas. Access to areas where

exposure to silica dust is present must be restricted to only those employees

involved in the specific work being conducted.

 Medical Surveillance. Employee monitoring must be conducted if engineering control

measures and respiratory protection cannot limit exposure to respirable crystalline silica

to below the action level of 25 μg/m3, calculated as an eight-hour time-weighted-average.

The medical surveillance program must be in accordance with 29 CFR 1910.1053

Appendix B.

 Training. Affected employees must be trained in the following:

 Health hazards associated with exposure to respirable crystalline silica

 Tasks in the workplace that may result in exposure to respirable crystalline silica

 Measures to protect employees from exposure to respirable crystalline silica,

including respiratory protection, if applicable

 Identity of the Program Manager

 The purpose and description of the medical surveillance program, if applicable

 Hazard Communication. Crystalline silica must be included in the institution’s Hazard

Communication Program for those affected employees. At a minimum, the following

hazards must be addressed:

 Cancer

 Lung effects

 Immune system effects

 Kidney effects

 Written Plan Review and Evaluation. The SA must review and evaluate the effectiveness

of the written plan at least annually and update the written plan as necessary.

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