CEMP-RA

Engineer Pamphlet

1110-1-22

Department of the Army

U.S. Army Corps of Engineers

Washington, DC 20314-1000

EP 1110-1-22

15 September 2000

Engineering and Design

ASBESTOS SURVEYS AND 

 ASSESSMENTS 

STANDARD SCOPE OF WORK

Distribution Restriction Statement

Approved for public release;

distribution is unlimited.

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APPENDIX A

ASBESTOS SURVEYS AND ASSESSMENTS

STANDARD SCOPE OF WORK

TABLE OF CONTENTS

1.0 PROJECT OVERVIEW, OBJECTIVES, AND DESCRIPTION OF WORK..................................................A-3

1.1 REFERENCES .................................................................................................................................A-3

1.1.1 Federal ..............................................................................................................................................A-3

1.1.1.1 U.S. Environmental Protection Agency.............................................................................................A-3

1.1.1.2 Occupational Safety and Health Administration (OSHA).................................................................A-4

1.1.2 U.S. Army .........................................................................................................................................A-4

1.1.3 State, Local, Outside Continental United States (OCONUS) Agreements, etc.................................A-4

1.1.4 Other Organizations ..........................................................................................................................A-4

1.1.4.1 American Industrial Hygiene Association .........................................................................................A-4

1.1.4.2 American Society of Testing and Materials (ASTM)........................................................................A-4

1.1.4.3 National Institute of Occupational Safety and Health (NIOSH)........................................................A-4

1.1.4.4 National Institute of Standards and Technology................................................................................A-4

1.2 REGULATORY REQUIREMENTS................................................................................................A-5

1.2.1 Regulatory Authority/Requirements..................................................................................................A-5

1.2.1.1 Federal Requirements........................................................................................................................A-5

1.2.1.2 State and Local Requirements ...........................................................................................................A-5

1.3 SITE CHARACTERISTICS, OBJECTIVES AND DESCRIPTION OF WORK............................A-6

1.3.1 Site Location/Characteristics ............................................................................................................A-6

1.3.2 Previous Studies and Results ............................................................................................................A-6

1.3.3 Project Objectives and Description of Work ....................................................................................A-6

1.3.4 Data Quality Objectives (DQOs) ......................................................................................................A-6

1.3.5 Bid Assumptions...............................................................................................................................A-7

2.0 PROJECT REQUIREMENTS ..........................................................................................................................A-7

2.1 TASK 1 DESCRIPTION OF CURRENT CONDITIONS/PROJECT WORK PLAN.....................A-7

2.1.1 Background Data ..............................................................................................................................A-7

2.1.1.1 Asbestos Management Program........................................................................................................A-7

2.1.1.2 Interviews..........................................................................................................................................A-7

2.1.1.3 Summary of Pre-existing Data, Asbestos Management Plan, and Interviews ...................................A-8

2.1.2. Project Boundaries Identification/Floor Plans ..................................................................................A-8

2.1.3 Preliminary Site Visit/Walkover .......................................................................................................A-8

2.1.4 Occupant Notification Unit Access...................................................................................................A-8

2.1.5 Project Work Plan.............................................................................................................................A-8

2.2 TASK 2 CONDUCT SURVEY AND ASSESSMENT ....................................................................A-9

2.2.1 Facility Walk-Through/Survey..........................................................................................................A-9

2.2.1.1 Sample Location Documentation ....................................................................................................A-10

2.2.2 Collection of Bulk Samples ............................................................................................................A-10

2.2.3 Sample Identification ......................................................................................................................A-10

2.2.4 Sample Chain-of-Custody...............................................................................................................A-10

2.2.5 Decontamination .............................................................................................................................A-11

2.3 TASK 3 SAMPLE DATA ANALYSIS, EVALUATION OF FINDINGS.....................................A-11

2.3.1 Sample Preparation and Analysis....................................................................................................A-11

2.3.2 Analysis of Bulk Samples ...............................................................................................................A-11

2.3.2.1 Laboratory Turnaround Time..........................................................................................................A-12

2.3.3 Quality Assurance and Quality Control (QA/QC)...........................................................................A-12
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2.3.3.1 Laboratory QA/QC .........................................................................................................................A-12

2.3.4 Laboratory Report...........................................................................................................................A-12

2.3.5 Contractor Certification of Project Data Validity ...........................................................................A-13

2.4 TASK 4 ASBESTOS SURVEY AND ASSESSMENT REPORT .................................................A-13

2.4.1 General Report Contents.................................................................................................................A-13

2.4.2 Summary of Pre-existing Data, Asbestos Management Program, and Interviews...........................A-14

2.4.3 Contractor Data Certification..........................................................................................................A-14

2.4.4 Electronic HALO/Installation Data Downloading into Installation System....................................A-14

2.4.5 Update Installation Management Plan ............................................................................................A-15

2.4.6 Comparison of Contractor Findings to Installation HALO Findings ..............................................A-15

2.4.7 Contractor Conclusions and Recommendations..............................................................................A-15

3.0 SUPPLEMENTAL REQUIREMENTS FOR CONTRACTED SERVICES ..................................................A-15

3.1 CONTRACTOR FIRM/PERSONNEL QUALIFICATIONS.........................................................A-15

3.1.1 Contractor Firm Experience............................................................................................................A-15

3.1.2 Contractor Inspector and Management Planner Qualifications.......................................................A-16

3.1.2.1 EPA, State and Local Certification .................................................................................................A-16

3.1.2.2 Evidence of Certification ................................................................................................................A-16

3.1.2.3 Record of Experience......................................................................................................................A-16

3.1.2.4 Use of Asbestos Survey and Assessment Teams.............................................................................A-16

3.1.2.5 Project Manager Experience...........................................................................................................A-16

3.1.3 Contracted Laboratory Qualifications.............................................................................................A-17

3.1.4 Contractor Errors and Omissions Liability Insurance .....................................................................A-17

3.2 PROJECT RECORDS ....................................................................................................................A-17

3.2.1 Record Keeping Requirements .......................................................................................................A-17

3.2.1.1 Project Work Plan...........................................................................................................................A-17

3.2.1.2 Asbestos Survey and Assessment Report........................................................................................A-17

3.2.1.3 Correspondence, Conference and Field Notes, Forms, Other Documentation................................A-17

3.3 PROJECT COORDINATION ........................................................................................................A-17

3.4 GOVERNMENT SUPPORT..........................................................................................................A-17

3.4.1 Government Quality Control Oversight and Support......................................................................A-18

3.4.2 Rights of Entry, Security, and Escorts ............................................................................................A-18

3.4.3 Temporary Office/Equipment Storage/Staging Areas.....................................................................A-18

3.5 TRAVEL AND MEETINGS..........................................................................................................A-18

3.5.1 Preliminary Project Site Visit/Walkover.........................................................................................A-18

3.5.2 Project Work Plan Review and Startup Meeting.............................................................................A-18

3.5.3 Final Asbestos Survey and Assessment Report Meeting.................................................................A-19

3.5.4 Additional Meetings........................................................................................................................A-19

3.6 SCHEDULES .................................................................................................................................A-19

3.7 SUBMITTALS ...............................................................................................................................A-19

3.7.1 Project Work Plan...........................................................................................................................A-19

3.7.2 Progress Reports .............................................................................................................................A-19

3.7.3 Asbestos Survey and Assessment Report........................................................................................A-20

3.8 MISCELLANEOUS .......................................................................................................................A-20

3.8.1 Glossary ..........................................................................................................................................A-20

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NOTE TO THE SCOPE OF WORK EDITOR

This standard scope of work (SOW) is to be used for performance of asbestos surveys

and assessments at government facilities. In order to ensure that site-specific conditions

and requirements are adequately addressed, the editor must possess current certification
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as an Asbestos Inspector/Management Planner, and should have prior knowledge and

experience related to asbestos surveys.

This standard SOW was designed to comply with Army and other Federal

requirements regarding asbestos surveys, assessments, and hazard management,

including disposal of any waste generated. Consult state and local authorities to

determine whether established requirements and procedures more protective than

those outlined in this SOW exist. This SOW was developed using the most current

standards in force at the time of issue. The editor should determine whether current

Federal and Army regulations differ from those cited.

Select the appropriate options denoted in brackets [ ] for the specific needs of the

asbestos survey and assessment project. The installation may not have adequate

information to specify the type of assessment, or may not possess the training and

experience required to make this decision. In this case, the USACE will assist the

installation in determining the appropriate type of assessment. This may require a

site visit and a preliminary records review.

The Federal regulations listed in Section 1.1.1 of this SOW are updated frequently.

The editor should monitor the Federal Register and also be familiar with any

changes to the Army requirements to ensure that all aspects of the survey and

assessment project comply with the most current Federal regulations and Army

requirements. State and local regulatory agencies should also be consulted to

determine if any additional requirements exist that might impact the project. For

example, state and local regulatory agencies may require special certifications or

licenses for persons conducting asbestos inspections, or developing management

plans.

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1.0 PROJECT OVERVIEW, OBJECTIVES, AND DESCRIPTION OF WORK

1.1 REFERENCES

1.1.1 Federal

1.1.1.1 U.S. Environmental Protection Agency

a. 40 CFR Part 763, Asbestos-Containing Materials in Schools; Subpart E, Final Rule;

52 FR 41846, October 30, 1987

b. U.S. EPA, Asbestos Hazard Emergency Response Act (AHERA) AHERA 3,5,7

Rule

c. U.S. EPA, “Asbestos in Building Simplified Sampling Scheme for Friable

Surfacing Materials

d. U.S. EPA, Guidance for Controlling Asbestos-Containing Building Materials,

560/5-85-024, June 1985

e. U.S. EPA, Managing Asbestos in Place, 20T-2003, July 1990

f. U.S. EPA, Model EPA Curriculum for Training Building Inspectors

g. U.S. EPA, Test Method for the Determination of Asbestos in Bulk Building

Materials, 600/R-93/116, July 1993
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1.1.1.2 Occupational Safety and Health Administration (OSHA)

29 CFR Part 1910 and 1926 Implementing the Occupational Safety and Health Act

1.1.2 U.S. Army

a. AR 200-1, Environmental Protection and Enhancement, Paragraph 8.2.h

b. AR 420-70, Facilities Engineering, Buildings and Structures, Paragraph 3-3

c. Department of the Army, Public Works Technical Bulletin (PWTB) 420-70-8,

Installation Asbestos Management Program, (http://www.hnd.usace.army.mil/)

d. DA Hazardous Asbestos and Lead Optimal Management System (HALO)

e. USACE, EM 200-1-2, Technical Project Planning Process

f. USACE, EM 385-1-1, Safety & Health Requirements Manual

1.1.3 State, Local, Outside Continental United States (OCONUS) Agreements, etc.

[Insert applicable references.]

1.1.4 Other Organizations

1.1.4.1 American Industrial Hygiene Association

American Industrial Hygiene Association (AIHA) administers the Bulk Asbestos

Proficiency Analytical Testing Program (BAPAT) (http://www.aiha.org)

1.1.4.2 American Society of Testing and Materials (ASTM)

a. ASTM C 732 (1995) Aging Effects of Artificial Weathering on Latex Sealants

b. ASTM E 736 (1992) Cohesion/Adhesion of Sprayed Fire-Resistive Materials

Applied to Structural Members

c. ASTM D 1331 (1989: R 1995) Surface and Interfacial Tension of Solutions of

Surface-Active Agents

d. ASTM E 1368 (1997) Visual Inspection of Asbestos Abatement Projects

1.1.4.3 National Institute of Occupational Safety and Health (NIOSH)

NIOSH Manual of Analytical Methods NIOSH Pub No. 84-100, 1984; and

Supplements

1.1.4.4 National Institute of Standards and Technology

National Voluntary Laboratory Accreditation Program (NVLAP))

(http://ts.nist.gov/ts/htdocs/210/214/214.htm)
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1.2 REGULATORY REQUIREMENTS

1.2.1 Regulatory Authority/Requirements

The Contractor shall conduct all work in accordance with Federal, state and local regulations and

requirements. Where inconsistencies exist between Federal, state, and local requirements and this

SOW, the Contractor shall follow the most protective requirements.

1.2.1.1 Federal Requirements

a. Survey and Assessment Procedures and Requirements

Following the AR 200-1 and AR 420-70, all persons conducting asbestos surveys and/or

assessments shall possess current USEPA asbestos training certifications as specified in 40 CFR

Part 763, Sub-part E, Appendix C. The types of certifications required for specific tasks are

detailed in this SOW. The Contractor shall complete the asbestos surveys and assessments

utilizing the guidance provided in PWTB 420-70-8, Installation Asbestos Management Program,

Chapter 5 (Appendix B), Chapter 8 and in Asbestos Hazard Emergency Response Act (AHERA)

protocols.

b. Health and Safety Requirements

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NOTE: The procedures discussed in 29 CFR 1910.146 must be considered when a

potential for confined space entry (i.e., crawl spaces, duct work, vaults, etc., which

meet the definition of a confined space) exists.

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The Contractor shall comply with OSHA requirements, particularly 29 CFR 1910.134 and 29 CFR

1910.1001, during the performance of activities described in this SOW. Special emphasis shall be

placed on safe practices for confined space entry, fall protection, and electrical hazards. The

Contractor shall also follow all requirements stated in the USACE Safety and Health Requirements

Manual (EM 385-1-1), including submission of an Accident Prevention Plan (APP). Field

activities shall not be initiated before the Contracting Officer’s designated Contracting Officer

Technical Representative (COTR) has accepted the APP.

1.2.1.2 State and Local Requirements

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NOTE: Reference state, local, (OCONUS where applicable) or installation specific

requirements that differ from the Federal requirements cited above that are

applicable to the work addressed in this SOW.

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[The Contractor shall comply with the following state [and local] [ and installation] requirements
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in completing the activities required by this SOW. [Insert applicable references.]]

1.3 SITE CHARACTERISTICS, OBJECTIVES AND DESCRIPTION OF WORK

1.3.1 Site Location/Characteristics

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NOTE: Consult the installation POC to obtain site location information including

installation and building designations or addresses, and other appropriate location

information for all facilities and areas to be included in the survey. Include details

regarding the number of facilities and their sizes to be included in the asbestos

surveys and assessments.

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The survey shall address the following facilities at the following locations:

[Insert installation and building designations or addresses, and other appropriate location

information for all structures, facilities/units and areas to be included in the survey.]

1.3.2 Previous Studies and Results

[Prior to initiating field activities required by this SOW, the Contractor shall review the previous

study data results collected at the location(s) identified in Paragraph 1.3.1 and provided as an

attachment to this SOW.]

1.3.3 Project Objectives and Description of Work

The project objectives are: [insert text as applicable]. The Contractor shall conduct asbestos

surveys and assessments at the structures, facilities/units and areas listed in this SOW. The

asbestos survey shall identify the location and estimate the quantities of Asbestos Containing

Materials (ACM) that must be removed or managed in place for the structure(s), facilities(s)/units

and areas listed above. An asbestos assessment shall further evaluate the potential for ACM

identified to become airborne and cause potential human exposure. Procedures and requirements

for completing the asbestos survey and assessment are defined in the paragraphs that follow.

1.3.4 Data Quality Objectives (DQOs)

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NOTE: Project-specific DQOs must be developed in keeping with installationspecific factors and requirements and followed to provide project required data

quality.

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The Contractor shall meet the project-specific Data Quality Objectives (see Glossary) for the

sampling, analysis and Quality Assurance/Quality Control (QA/QC) defined in Paragraphs 2.2 and

2.3. The DQOs include collection of the proper numbers and types of samples, the appropriate

sample collection and analytical methodologies, the field and laboratory QA/QC procedures, and

the data validation and evaluation processes in order to provide required data quality. The
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sampling data collected shall be compared to action levels defining asbestos hazards provided in

this SOW.

1.3.5 Bid Assumptions

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NOTE: Include project-specific assumptions for the Contractor to use in

developing a cost estimate. Contact the installation POC for site-specific

information to assist in the development of realistic assumptions. For example,

floor plans may accompany the SOW to give the Contractor an understanding of the

level of effort required to survey each facility. Typical analysis cost per sample can

range from $5 to $8.50 for PLM and $60 to $90 for TEM. Check with several labs

in the area of the project on sample costs and procedures. Also assume the QC

samples will equal 5% to 10% of total samples analyzed.

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Bid assumptions include: [insert bid parameters]

2.0 PROJECT REQUIREMENTS

2.1 TASK 1 DESCRIPTION OF CURRENT CONDITIONS/PROJECT WORK PLAN

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NOTE: Determine the need for the Contractor to review the installations Asbestos

Management Program and provide a copy if required.

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The Contractor shall coordinate with the COTR and the installation POC to obtain any useful

information describing current conditions of the facilities that will be included in the surveys and

assessments. This shall include information concerning facility construction, maintenance, and

management history, and any useful information from previously conducted asbestos surveys and

assessments.

2.1.1 Background Data

The Contractor shall review general facility information [and summarize the results of any

previous surveys or analyses] that established the possible presence of ACM to be investigated

under this SOW.

2.1.1.1 Asbestos Management Program

[The Contractor shall review the installation’s Asbestos Management Program.]

2.1.1.2 Interviews

[The Contractor shall conduct interviews of personnel familiar with the facility history and

maintenance patterns. Personnel to be interviewed shall include:

a. Installation Asbestos Management Team Leader

b. Installation Environmental Officer to review preexisting data and verify

maintenance histories
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c. Director of Public Works (to discuss assessment logistics, i.e., accesses and surveys

scheduling.)

d. [Safety Officer]

e. [Insert others whose interviews may be pertinent to the project]]

2.1.1.3 Summary of Pre-existing Data, Asbestos Management Plan, and Interviews

[The Contractor shall include a project deliverable as an attachment to the Project Work Plan that

summarizes the review of the pre-existing data, the Asbestos Management Plan, and the

interviews. The summary shall address the following:

a. Reliability of Previously Collected Data

A brief summary of the data reliability from previous studies.

b. Asbestos Management Plan

A brief description of the Installation’s Asbestos Management Plan and a summary of information

pertinent to any previous asbestos identification data, maintenance history, or maintenance

practices.

c. Interviews

A brief summary of the interviews and the conclusions reached.]

2.1.2. Project Boundaries Identification/Floor Plans

Site maps identifying structures, facilities/units and areas that will be assessed, and copies of floor

plans for each are attached as a part of this SOW. The Contractor’s inspector shall use these plans

when performing Task 2 to identify and record sample locations in developing the Sample

Location Documentation.

2.1.3 Preliminary Site Visit/Walkover

The Contractor, the COTR and the Installation POC shall conduct a joint preliminary site

visit/walkover. This walkover will be used to ensure that all site-specific conditions and special

accessibility requirements are addressed in the Project Work Plan.

2.1.4 Occupant Notification Unit Access

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NOTE: Occupant notification of planned assessment activities is an installation

responsibility. Coordinate with the Director of Public Works and the

Environmental Manager.

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The Government shall notify occupants impacted by the survey and arrange access regarding the

activities planned [Insert text as applicable.] days prior to beginning the assessment activities. The

Contractor shall coordinate with the COTR and installation authority responsible for notification

and access to establish an entry schedule based on the Contractor’s Project Work Plan.

2.1.5 Project Work Plan

The Contractor shall prepare a Project Work Plan that describes the required information in

sufficient detail to assure the COTR that the Contractor fully understands the project. The survey
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and assessment strategy will be based on Appendices B and C. The plan shall include but not be

limited to the following:

• Accident Prevention Plan (APP) including project safety and health requirements.

• Project objectives/requirements, including [usability of pre-existing data,] access requirements,

scheduling, escort requirements, and laboratory turn-around time requirements.

• DQOs.

• Asbestos Sampling Plan including sample identification process and location decision logic.

• Identification, qualifications, and photocopies of certifications of the project personnel/team.

• Identification and qualifications of each laboratory that will be used to analyze samples.

• Site maps, building identifications, building numbers, floor plans/sketches, (provided as part of

this SOW).

• [Summary of Pre-existing Data, Asbestos Management Plan, and Interviews.]

2.2 TASK 2 CONDUCT SURVEY AND ASSESSMENT

2.2.1 Facility Walk-Through/Survey

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NOTE: Confirm with the Installation POC which field data collection forms will be

required to be used during the walk-through survey, and select the appropriate

bracketed sentence. Confirm with the Installation POC that cameras may be used at

the installation for documentation purposes.

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The Contractor shall conduct a thorough walk-through survey as described in Appendix B. During

the walk-through survey, the Contractor shall identify all surfacing material, Thermal System

Insulation (TSI) and miscellaneous materials that potentially contain asbestos. The survey will

include exterior building surfaces, roofing, outside steam lines, and all interior areas such as pipe

chases, closets and other out-of-the-way places. Prior to developing a specific sampling approach,

the Contractor shall carefully delineate homogenous areas based on similar appearance, color,

texture, and date of application.

During the walk-through survey, the Contractor shall utilize [field collection forms in the HALO

Users Manual,][Data input forms supplied by the customer,][Army Asbestos-Containing Materials

Checklist provided in Appendix C. This checklist addresses both the extent of damage to ACM,

and the potential human exposure from damaged ACM.] [The Contractor shall also photograph

each homogenous area.]

The Contractor shall distinguish between friable and nonfriable suspect ACM on all surfaces

including walls, ceilings, and structural members by determining if the material can be crumbled or

reduced to powder by normal hand pressure. Note that under the USEPA definition, the term

friable material also includes both damaged material and material that possesses the potential for

damage when touched or otherwise disturbed. The Contractor shall also assess the condition of all

suspect ACM and classify the condition of suspect ACM as “Significantly Damaged”, “Damaged”,

or “Good Condition”.
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2.2.1.1 Sample Location Documentation

Upon completion of the walk-through survey, and prior to actual sampling, the Contractor shall

clearly mark, number and otherwise uniquely identify all homogenous areas of suspected ACM and

samples to be taken, by marking the locations on the floor plan or sketch including room layout.

The resultant information shall be compiled and labeled the “Sample Location Documentation”

before actual sampling commences. Sampling shall be completed immediately following the walkthrough survey and the documentation of sample locations, prior to exiting the facility.

The COTR reserves the right to audit the Sample Location Documentation, at any time during the

course of the project. The Sample Location Documentation shall be included as an attachment to

the Asbestos Sampling Plan, and shall be submitted as a part of the Asbestos Survey and

Assessment Report.

2.2.2 Collection of Bulk Samples

The Contractor shall ensure that all personnel collecting bulk samples are currently certified as

AHERA Asbestos Inspectors. The Contractor shall collect bulk samples following the guidance

provided in PWTB 420-70-8, Chapter 8-3, “Bulk Sample Collection” and in the ACM in Schools

Rule found in 40 CFR 763.86. The Contractor shall use the specific procedures and techniques for

bulk sample collection described in Section I of the USEPA “Model EPA Curriculum for Training

Building Inspectors”. The Contractor shall collect a minimum of three bulk samples per

homogeneous area that is 1000 ft2

 or less, except as provided in 40 CFR 763.87, for all surfacing

materials. Suspect surfacing materials (i.e., sprayed or troweled on) shall be sampled randomly

following the USEPA document entitled “Asbestos in Building Simplified Sampling Scheme for

Friable Surfacing Materials”.

The Contractor shall collect a minimum of three samples for TSI that is not assumed to be ACM.

If a TSI section is less than six linear feet or six square feet, a minimum of 1 bulk sample shall be

collected, unless the TSI is assumed to be ACM.

[Destructive bulk sampling of [any] [exterior] [roofing] miscellaneous materials is not authorized.]

[Destructive bulk sampling of miscellaneous materials is authorized, and sample location shall be

coordinated with the facility management.] The Contractor shall collect the minimum number of

bulk samples of miscellaneous materials following the guidance in the “AHERA 3,5,7 Rule”.

2.2.3 Sample Identification

A unique sample identification code number shall be used for all bulk samples. The number is

intended to facilitate sample tracking without revealing the identity of the sample to the laboratory.

All sample containers shall be labeled immediately upon collection of the sample. Information on

sample labels shall include the sample identification printed with a waterproof marker. Labels are

used for identification and to preserve sample integrity.

2.2.4 Sample Chain-of-Custody

The Contractor shall follow a standard chain-of-custody protocol to document and ensure a

continuous record of sample possession from the time of sample collection to the samples’ receipt
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by the laboratory. The Contractor shall complete and maintain chain-of-custody forms for each set

of samples shipped to the laboratory, and a copy of the forms shall accompany each shipment of

samples. The labeled sample containers (i.e., zipper sealed baggie) shall be packaged and shipped

in sturdy containers. Corresponding chain-of-custody documentation shall accompany each

shipping container to the laboratory. The shipping container shall be securely taped shut and a

custody seal shall be placed across the seams between the lid and the body of the shipping

container. All shipping containers shall be [express] mailed to the laboratory. The samples shall

be mailed, at a minimum, on a [weekly] [insert time period] basis during the project’s duration.

2.2.5 Decontamination

Field sampling equipment shall be decontaminated following standard methods. At a minimum,

the field decontamination procedures for non-disposable sampling equipment (e.g., knives and

coring devices) shall consist of either wiping off the equipment twice using a clean wet wipe or

washing in a solution of non-phosphate detergent, and rinsing with distilled water. The equipment

shall be decontaminated prior to each use, between each sample collection, and prior to leaving the

site. The Contractor shall coordinate with the installation environmental officer to determine

requirements for disposal of sampling decontamination waste, and used personal protective

equipment.

2.3 TASK 3 SAMPLE DATA ANALYSIS, EVALUATION OF FINDINGS

2.3.1 Sample Preparation and Analysis

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NOTE: Army guidance specifies that the laboratory performing the analyses of bulk

samples all be accredited by NVLAP. The AIHA also accredits laboratories for bulk

samples. Normally requirements for the use of NVLAP accredited Laboratories will

be specified. Consult with the customer and the state to determine what accrediting

status is required.

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Samples collected during the survey and assessment(s) shall be sent to a laboratory accredited by

[NVLAP] [or] [AIHA] for analysis. The laboratory must be accredited for each type of analysis

required. Bulk samples collected by the Contractor during the survey shall be analyzed for asbestos

using polarized light microscopy (PLM) [and transmission electron microscopy (TEM)].

2.3.2 Analysis of Bulk Samples

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NOTE: There is a conflict between the OSHA construction worker protection

asbestos standard and the EPA NESHAP standards regarding the composting or

segregating of multi-layered systems during analysis. For example, OSHA considers

wallboard, joint compound and joint tape as separate products. Therefore, under

OSHA the wallboard, the joint compound and the joint tape must be analyzed

separately. EPA, however, looks at wallboard, joint compound and joint tape as a

single system and requires only a single, composite analysis of the three

components. Another example is floor tile and mastic; these materials may be
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sampled together, but must be analyzed and reported separately. When analyzing

samples consisting of more than one component, each sub-component shall be

analyzed and the analytical results reported separately, but listed together as a single

sample consisting of several components. Specify the requirement for collection and

analysis of multi-layered systems.

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The Contractor shall assure that the laboratory follows the guidance provided in PWTB 420-70-8,

Chapter 8-4 “Analysis of Bulk Samples for Asbestos” for all bulk sample analyses. Bulk samples

collected by the Contractor during the survey(s) shall be analyzed by polarized light microscopy

(PLM). TEM analysis shall be performed on the samples when PLM analysis is inclusive for

percent (%) asbestos.

The most current version of the methodology shall be used. Use of other methodologies must be

accepted in advance by the COTR. Results shall be reported in units of percent (%). Multi-layered

systems shall be surveyed and assessed in the following manner [insert appropriate text]

2.3.2.1 Laboratory Turnaround Time

The Contractor shall submit the laboratory report analytical results to the COTR within [insert

number of days] days of the sampling.

2.3.3 Quality Assurance and Quality Control (QA/QC)

The Contractor shall establish a QA/QC protocol according to EPA 560/5-85-024, June

1985, Guidance for Controlling Asbestos-Containing Building Materials. QA/QC sample

information must be carefully documented in the Asbestos Survey and Assessment Report,

including the Asbestos Sampling Plan and Sample Location Documentation, analytical

results, and Chain-of-Custody records. The Contractor shall collect a minimum of one QC

sample for every twenty investigative samples collected. [QA/QC samples shall be sent to

a different [NVLAP] [or] [AIHA] accredited laboratory [and not the primary laboratory

subcontracted]]. The Contractor shall specify the most advantageous technique to provide

extra samples to the laboratory, should additional samples be required by the laboratory to

replace sampling or QA/QC data lost due to laboratory mistakes. The Government is not

liable for cost of additional sample collection due to laboratory mistakes, Contractor sample

collection problems, or chain-of-custody errors.

2.3.3.1 Laboratory QA/QC

The Contractor shall verify that sample duplicates and laboratory blanks are used by the laboratory

to measure precision and accuracy of laboratory analytical procedures in accordance with

[NVLAP] [or] [AIHA] requirements.

2.3.4 Laboratory Report

The Contractor shall require that the laboratory provide the information necessary for the

Contractor to comply with the data evaluation/validation procedures outlined in this SOW. This

shall be included in a package containing the following information:
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• Name, address and telephone number of [each] accredited laboratory conducting analysis of

samples.

• Survey findings including a list of all materials sampled and analyzed, the analytical results,

and lists of Friable ACM, Non-friable ACM, and Non-ACM.

• Laboratory analytical data sheets including identification and results of QC samples to include

duplicates and laboratory blanks used by the Laboratory to measure precision and accuracy,

samples, batch identification if applicable, and Chain-of-Custody forms

• Copy of Laboratory [NVLAP] [or] [AIHA] accreditation for bulk ACM analysis

2.3.5 Contractor Certification of Project Data Validity

The Contractor shall certify that all field data collected for purpose of determining the presence of

asbestos are valid and meet the DQOs.

2.4 TASK 4 Asbestos Survey and Assessment Report

*******************************************************************************

NOTE: The SOW editor should confer with the installation POC to determine the

specific reporting formats required.

*******************************************************************************

The Contractor shall prepare an Asbestos Survey and Assessment Report containing the elements

described in Paragraphs 2.4.1 through Paragraph 2.4.7 below. An Asbestos Survey and

Assessment Report shall be prepared for each facility to document the findings of the asbestos

survey.

2.4.1 General Report Contents

• Installation name and location

• Address (street, city, state and zip) and building identification number of assessed facility

• Facility manager or POC [and phone number]

• Contractor firm name, [address (street, city, state and zip)] [phone number]

• Date of assessment

• Name, signature and certification number of each inspector, management planner, and

projected designer participating in the survey and assessment

• Name, address, and telephone number of the Contract firm and POC doing the assessment,

• Executive summary of survey and assessment including a list of all ACM

• Asbestos Sampling Plan with Sample Location Documentation

• Laboratory Report

• Recommendations

• Decision tree flow chart and explanation of Hazard Ranks/Assessments

• Bulk sample log

• Extent of materials drawing for each floor (estimated amounts)

• Photograph log

• Photographs of each homogenous area
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• Glossary/Definitions of terms

*******************************************************************************

NOTE: Specify which (if any) facilities should be combined into a single report, or

if individual reports are required for every facility.

*******************************************************************************

The Contractor shall provide [specific number] copy(ies) of the Asbestos Survey and Assessment

Report(s). [The Contractor shall also provide an individual Asbestos Survey and Assessment

Report for each building.] Requirements for content and format of each report(s) is detailed in

Section 2.4 of this SOW. The report(s) shall be submitted to COTR in [pre-draft], [draft], [and]

[final] forms in both electronic and hard copy formats.

2.4.2 Summary of Pre-existing Data, Asbestos Management Program, and Interviews

[The Contractor shall attach a copy of the Summary of Pre-existing Data, Asbestos Management

Program, and Interviews.]

2.4.3 Contractor Data Certification

The Contractor shall certify that the data used to develop all conclusions and recommendations

were reviewed, validated, and met the DQOs (i.e., that the data was sufficient to identify and

characterize asbestos present).

2.4.4 Electronic HALO/Installation Data Downloading into Installation System

*******************************************************************************

NOTE: All data collected during activities specified in this SOW are to be provided

to the Army in a format compatible with the Army’s Hazardous Asbestos and Lead

Optimal Management System (HALO) or, if the installation does not utilize HALO,

with the installation data management system requirements. HALO is a hazard

management system designed to track asbestos hazards and actions taken in

response to identified asbestos hazards. HALO requires an IBM-compatible

personal computer (with a Pentium processor), Windows 95, 16 MB of RAM,

10MB of available hard disk space, Word 97, and display resolution of 800x600

pixels. The current POC for HALO is:

USACE Engineering Research and Development Center (CEERDC)

Facilities Division, Materials and Structures Branch (CF-M)

(217) 352-6511 ext. 7239 (commercial)

Where the installation has no unique data management system for asbestos data,

HALO shall be the default program for all deliverables under this SOW. The SOW

should detail the procedures for the Contractor must follow when providing the

results of asbestos surveys and assessments to the USACE representative for

uploading into HALO or comparable system used by the installation.

At a minimum, the Contractor must be provided a copy of the HALO Data
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Dictionary. The Dictionary identifies the table names, field names, data types, and

all other required default values. The Dictionary is part of the HALO program and

may be obtained by the installation, or by contacting CEERD CF-M. If the

transferee is known, consult with them for reporting requirements. In every case,

electronic archives should be produced for the record.

*******************************************************************************

The Contractor shall provide laboratory data to the COR in both hard copy and electronic format.

The electronic data report shall be provided in [HALO format] [insert other data management

system as applicable].

2.4.5 Update Installation Management Plan

*******************************************************************************

NOTE: If the installation does not use HALO for Asbestos Management Plan data

management, the editor may choose to include a requirement in the SOW that the

Contractor must update the installation Asbestos Management Plan data management

system to incorporate the new data. Consult the customer to determine the scope of this

task (e.g., whether to limit the task to the entry of new data into the appropriate electronic

format, whether to include an update of a hard copy document, or whether to complete an

addendum to the existing installation plan).

*******************************************************************************

[After entering the assessment data into HALO, the Contractor shall run the HALO program to

generate an updated installation Asbestos Management Plan.]

[The Contractor shall update the installation Asbestos Management Plan with the new survey

data.]

2.4.6 Comparison of Contractor Findings to Installation HALO Findings

[The Contractor shall include a comparison of the assessment findings and recommendations to

those generated by HALO.]

2.4.7 Contractor Conclusions and Recommendations

The report shall contain conclusions and asbestos control recommendations. The Contractor shall

follow Chapter 6 in PWTB 420-70-8 in developing conclusions and control recommendations.

[Where the assessor’s findings and recommendations differ from those generated by HALO, the

report shall provide the rationale for the assessor’s findings and recommendations.]

3.0 SUPPLEMENTAL REQUIREMENTS FOR CONTRACTED SERVICES

3.1 CONTRACTOR FIRM/PERSONNEL QUALIFICATIONS

3.1.1 Contractor Firm Experience

The contracted firm shall posses a minimum of [specific number of] years experience in

conducting asbestos surveys and assessments and shall posses adequate numbers of qualified staff.

Three references, at a minimum, shall be required for previously completed projects of equal

complexity to the project addressed in this SOW.
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3.1.2 Contractor Inspector and Management Planner Qualifications

In accordance with the Model Accreditation Program described in 40 CFR 763 Subpart E,

Appendix C, the Contractor shall use [one] [or more] persons currently accredited as AHERA

Inspector and Management Planner. The Inspector shall determine the presence and physical

characteristics of ACM. The Management Planner shall estimate the degree of current or potential

hazard posed by the ACM, and shall develop a plan for management of the ACM.

3.1.2.1 EPA, State and Local Certification

*******************************************************************************

NOTE: Specific EPA, state and local certification/licensure should be detailed in

this section.

*******************************************************************************

The Contractor shall use only personnel who possess current EPA, state and local (if necessary)

accreditation and licenses as Asbestos Inspectors, Asbestos Management Planners, as appropriate,

for the specific tasks described in this SOW. [It is the Contractor’s responsibility to contact state

and local regulatory agencies to determine specific certification/licensure requirements.] [Specific

state [and local] certification/licensure pertinent to this installation include: [specify here.]]

3.1.2.2 Evidence of Certification

The Contractor shall include a copy of original certificate of accreditation and the most current

refresher certificate for each asbestos inspector and management planner in the final report[s].

3.1.2.3 Record of Experience

A resume or other professional history for each of the certified inspector(s) and management

planner(s) who are involved in the activities required under this SOW shall be included in the

Project Work Plan.

3.1.2.4 Use of Asbestos Survey and Assessment Teams

*******************************************************************************

NOTE: Indicate the number and size of survey teams for large, complex projects.

*******************************************************************************

The Contractor shall specify the number of two-person teams that will conduct the survey

evaluation in the Project Work Plan. The overall team leader shall have a minimum of three years

experience conducting asbestos surveys.

3.1.2.5 Project Manager Experience

The project manager shall have a minimum of three years experience in managing asbestos survey

and assessments, or related activities. The Contractor shall provide a resume or other description

of the project manager’s experience, which is directly applicable to the activities required under

this SOW.
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3.1.3 Contracted Laboratory Qualifications

The Contractor shall provide, as a part of the Project Work Plan, evidence that the laboratory(ies)

used for sample analysis have current [NVLAP] [or] [AIHA] accreditation. The laboratory(ies)

must be accredited for each analytical method used. All samples collected during the survey(s)

shall be analyzed by a laboratory accredited under the [NVLAP] [or] [AIHA] for analysis by

polarized light microscopy (PLM) as specified in 40 CFR 763.87, following EPA Method 600/R93/116, July 1993. The laboratories must be independent of the Contractor and employ qualified

analysts. The Contractor shall provide a copy of each laboratories’ [NVLAP] [or] [AIHA]

certification to the COTR or Installation POC, and also must include a copy in the final report.

3.1.4 Contractor Errors and Omissions Liability Insurance

*******************************************************************************

NOTE: Consult with the customer and Contracting Officer to develop requirements

for Contractor errors and omissions liability insurance as appropriate for the scope

of the project.

*******************************************************************************

The Contractor shall provide documentation to the Contracting Officer that the Contractor is

currently covered by an errors and omissions liability insurance policy. [Insert the errors and

omissions text as appropriate.]

3.2 PROJECT RECORDS

3.2.1 Record Keeping Requirements

The Contractor shall maintain all records related to the survey activities for at least [insert

appropriate number of years] following completion of the activities outlined under this SOW.

Records shall include:

3.2.1.1 Project Work Plan

3.2.1.2 Asbestos Survey and Assessment Report

3.2.1.3 Correspondence, Conference and Field Notes, Forms, Other Documentation

3.3 PROJECT COORDINATION

The Contractor shall coordinate activities through the COTR. Contact with installation personnel,

including the installation POC, members of the installation asbestos hazard management team,

building occupants or POCs, and other installation personnel shall be coordinated through the

COR.

3.4 GOVERNMENT SUPPORT

*******************************************************************************

NOTE: Little standard language is offered in this section, since the requirements

will be very project-specific. The specific language will need to be defined by the

customer. Include the name of the person who is responsible.

*******************************************************************************
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3.4.1 Government Quality Control Oversight and Support

[Insert appropriate provisions.]

The COTR reserves the right to audit the Sample Location Documentation at any time during the

course of the project.

3.4.2 Rights of Entry, Security, and Escorts

*******************************************************************************

NOTE: It is advisable that Contractor personnel be accompanied by an escort. The

escort should introduce the team on behalf of the Asbestos Management Team, state

how long the work is expected to take, answer questions, and observe the team

while it works. This is a good public relations practice and helps to protect the

installation, the Contractor, and the occupants from disputes regarding claims of

loss and damage. The escort may use the time, on behalf of the Asbestos

Management Team, to discuss occupants’ concerns and to observe actual and

potential hazards, and maintenance problems.

If an escort cannot be provided, special precautions must be taken to protect all

parties. These precautions may include:

• A notice to occupants about the impending work including information for the

occupant on how Contractor personnel should identify themselves.

• An agreement regarding what Contractor personnel may tell occupants about the

work in response to questions.

*******************************************************************************

[Insert appropriate provisions.]

3.4.3 Temporary Office/Equipment Storage/Staging Areas

The installation shall provide space to the Contractor for the duration of the field activities for use

as a temporary office, equipment storage, and staging area. [The Government] [The Contractor]

shall provide [insert appropriate text regarding utilities, phone lines, permits, etc.].

3.5 TRAVEL AND MEETINGS

All meetings shall be attended by the Contractor’s PM, accredited inspector, [the Contracting

Officer] [the COTR] [and installation POC].

3.5.1 Preliminary Project Site Visit/Walkover

The Contractor [PM and] designated accredited inspector shall visit a representative number of the

facilities to be surveyed and assessed with the COTR and the installation POC. The purpose of the

site visit/walkover is to verify that the scoped level of effort is appropriate for the site conditions.

3.5.2 Project Work Plan Review and Startup Meeting

The Contractor shall attend a start-up meeting at the installation to review, finalize and approve the

Project Work Plan immediately prior to beginning field activities. The Contractor shall generate
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meeting minutes that will be submitted to the COTR within [two weeks] of the meeting.

3.5.3 Final Asbestos Survey and Assessment Report Meeting

The Contractor shall attend a Final Asbestos Survey and Assessment Report Meeting at the

installation to discuss the findings and recommendations of the report.

3.5.4 Additional Meetings

*******************************************************************************

NOTE: Depending on the scope and duration of the project, the editor may require

additional meetings during the performance of the project. For example, periodic

progress report meetings would be appropriate for a longer duration or open-ended

project.

*******************************************************************************

3.6 SCHEDULES

*******************************************************************************

NOTE: Because of the varying degree of complexity and extent of projects that

may be addressed under this SOW, no standard language regarding scheduling is

included in this SOW. The customer must be consulted to determine project

milestones that meet the needs of the installation, and to determine scheduling

requirements. Combine meeting topics where appropriate. At a minimum, the

schedule milestones include:

1) Site visit/project walkover

2) Project Work Plan submission meeting

3) Project start-up meeting, if not combined with item 2), above

4) Final Survey Report submission meeting

*******************************************************************************

[Insert appropriate schedule milestones.]

3.7 SUBMITTALS

3.7.1 Project Work Plan

The Contractor shall submit a Project Work Plan to the COTR, for government acceptance, as

outlined in Paragraph 2.1.4.

3.7.2 Progress Reports

The Contractor shall provide [specify time period] project progress reports to the COTR. The

report shall be due to USACE within one week of the end of a reporting period. The report shall

identify the reporting period, the [facility (ies)] [unit(s)] surveyed, the number and type of samples

collected, and the preliminary findings and recommendations.
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3.7.3 Asbestos Survey and Assessment Report

The Contractor shall provide a survey report, as described in Section 2.4 above.

3.8 MISCELLANEOUS

3.8.1 Glossary

This section contains acronyms and terms used in this SOW. For a more complete listing of terms

commonly used in reference to asbestos survey and assessment projects, refer to the regulations

and standards referenced in Paragraph 1.1 of this SOW.

ACM Any material containing more than 1% by weight of the regulated

asbestos minerals (USEPA)

COC Chain-of-custody. This refers to the custody procedures

implemented to ensure a trail of accountability for samples from the

time of collection to delivery at the laboratory. Also refers to the

forms used to implement the procedures.

DQO The qualitative and quantitative statements, guidelines, and

requirements of paragraphs 2.2 and 2.3 of this SOW that clarify

study objectives, define the appropriate type of data, and specify the

tolerance levels of potential errors that will be used as the basis for

establishing the quality of the data needed to support decisions. See

EM 200-1-2, Appendix G, DQO Attainment Verification Worksheet

for further refinement of the DQO definition.

EPA Environmental Protection Agency (usually refers to the United States

EPA, although the term USEPA is preferable when referring to the

Federal agency. This helps to avoid confusion in states where the

state environmental agency is also called the EPA, e.g., Illinois.)

HALO The Army’s Hazardous Asbestos and Lead Optimization

Management System, which is a management system designed to

track asbestos hazards and actions taken in response to identified

asbestos hazards.

MAP Model Accreditation Program identified in 40 CFR 763
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APPENDIX B

THE INSTALLATION ASBESTOS SURVEY AND ASSESSMENT

(REFERENCE PWTB 420-70-8, CHAPTER 5)

B-1 Organizing and Conducting the Installation Asbestos Survey............................................ B-2

B-2 Components of the Installation Asbestos Survey................................................................ B-2

B-3 Army Asbestos-Containing Material Assessment Checklist .............................................. B-4

B-4 Guide for Completing the Asbestos-Containing Material Assessment............................... B-5

B-5 Factors Used in the Assessment Process............................................................................. B-9

B-6 Exposure Analysis............................................................................................................. B-10

B-7 Management Considerations............................................................................................. B-11
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APPENDIX B

THE INSTALLATION ASBESTOS SURVEY AND ASSESSMENT

(REFERENCE PWTB 420-70-8, CHAPTER 5)

B-1 Organizing and Conducting the Installation Asbestos Survey

a. This survey must be conducted by either AHERA certified in-house personnel or

the project may be undertaken on a contract basis by a competent firm. The usual sequence of

steps to follow includes:

(1) Obtaining a complete listing and physical description of all buildings and

structures within the facility.

(2) Obtaining copies of all reports or databases pertaining to past asbestos

surveys or abatement projects.

(3) Performing site inspections of each building and structure.

(4) Collecting and analyzing bulk samples for asbestos.

(5) Assembling the database.

b. Each of these steps is shown in more detail in figure B-1.

B-2 Components of the Installation Asbestos Survey

a. Building and structure inventory. Before commencing the actual site inspections,

it is important to obtain a list and physical description of each building or structure to be

included in this survey. Additional information, such as the number of square feet, the present

use, and future plans for the building, will be useful survey data. As-built drawings or even a

reduced footprint of the building are useful in the field when mapping the areas of ACM.

Original construction specifications, when available, are notoriously unreliable as sources

concerning the presence of ACM. Construction specifications may specify an asbestoscontaining product, but the phrase or equivalent is frequently included, so that there is no

guarantee that the material is actually an ACM. The only truly reliable approach is to sample the

suspect material and have it analyzed.

b. Review existing facility ACM data. The presence of ACM in DA buildings has

been a topic of concern for well over a decade and a number of facilities had initiated their own

surveys. Existing databases may be out of date because of changes in personnel assignments or

the press of other commitments. Any previous surveys should be evaluated to determine

whether the data is currently relevant, and it may be possible to build upon an existing survey to

bring it up to date.
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Figure B-1. Asbestos Survey Flowchart

No

Yes

No

Yes Yes

No

Yes

No

Yes

Has a Visual

Survey Been

Done?

Are There

Highly Suspect

Buildings?

Do Other Sources

Indicate Suspect

Buildings?

Are Suspected

Buildings

Indicated?

Establish Preliminary

Priority Listing Based on

Available Records

Priorities for Highly

Suspect Buildings Based

on Priority Values

Set up Priorities of Work

for Suspect Buildings

Based on Priority Values

Priorities for Nonsuspect

Buildings Based on Relative

Importance or Priority

Values

Prepare Complete Building

Inspection Priority List:

Highly Suspect, Suspect,

and Nonsuspect

1. Organize ACM by

Location in Building

2. Categorize ACM as:

Surfacing Material

Pipe, Boilder, or Tank

Insulation "Other”

ACM

Initiate the

Building

Inspection

Do Any

Records Exist?
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c. Conducting site inspections.

(1) Walk-through survey. A thorough walk-through survey should be made of

each building. Each building manager should be contacted beforehand to arrange for access into

locked spaces. The inspection normally begins in the boiler room and expands to include other

functional spaces in the same building. Lagged vertical riser pipes commonly run through

closets, storerooms, or other out-of-the-way places. If it is known that the building is to be

demolished, it would be prudent, whenever practicable, to break into chases, or walls and

ceilings to determine whether ACM is present. Crawl spaces and attics should be checked

carefully. For structures built upon a concrete slab, asbestos lagged pipe may be present in

below-slab trenches. Building maintenance personnel are often a valuable source of information

regarding the details of construction and the locations where ACM may be present. It is

important to remember that if a situation is discovered that is immediately dangerous to life or

health, the inspector should immediately notify the Safety Office.

(2) Collection of bulk samples. Collecting a sufficient number of

representative samples of the various types of ACM is a vital part of the survey. These bulk

samples should be carefully selected from each type of suspect construction material from

locations throughout the functional space. In the case of pipe lagging, for example, the idea is to

distribute the bulk sample variants so as to include all variants of pipe lagging having different

physical appearances (e.g., changes in an outside diameter (OD), covering material, hardness, or

color). Additional information on bulk sampling and analysis are contained in chapter 8.

B-3 Army Asbestos-Containing Material Assessment Checklist

a. The Army ACM Checklist in appendix C is divided into two parts.

(1) Part I addresses the extent of existing damage and the potential risk of

damage to friable ACM.

(2) Part II addresses exposure potential and associated factors that contribute

to health hazards in the occupied functional space being evaluated.

b. Evaluating the extent of damage to the ACM or the potential for damage is an

important part of the assessment. This is because, in most cases, damaged ACM will release

more airborne asbestos fibers than undamaged ACM under identical conditions. Also, the more

extensive the damage, the greater the potential for fiber release.

c. Assessment factors, such as physical damage, water damage, asbestos content,

and the attendant value-weighted conditions, in Part I is self-explanatory. Other assessment

factors, in Part I and II however, have additional considerations that could influence the

evaluator’s choice of a value-weighted condition. The remainder of this section deals with some

additional considerations.
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d. The first assessment factor listed in Part I, physical damage to ACM, has the five

value-weighted conditions of high, moderate, low, minimal, and none. A consideration for the

evaluator should be the age of the ACM. If the age is greater than 30 years, the normal

deterioration of the binding agents may have produced a surface material that has a potential for

fiber release, per unit of surface area damaged, much greater than for newer and similar surface

ACM. An evaluator who would normally rate a certain extent of damage as low for 15-year-old

sprayed-on ACM might want to rate the same extent of damage as moderate for a 35-year-old

material. The age of the ACM should also be considered when determining the potential for

damage from water and routine maintenance or repair. In some assessment algorithms, the

design of a roof above the ACM is considered. There is a greater potential for rainwater damage

to ACM under a flat roof than under a sloped or hipped roof.

e. In considering the asbestos percent content of ACM factor, the assumption is that

as the percentage of asbestos in the ACM increases so does the potential for airborne fiber

release. This would undoubtedly be true if the same binding agent were used in all ACM.

However, not all ACM is created equal. It is quite possible that an ACM with an easily degraded

starch, water-soluble binder and an asbestos content of 15 percent would have a greater fiber

release potential than an ACM with 50 percent asbestos and a water-insoluble binder.

f. The evaluator’s choice of a value-weighted condition for each assessment factor

should be based upon all detailed and relevant information available.

B-4 Guide for Completing the Asbestos-Containing Material Assessment

a. A survey is defined in this manual as the inspection of functional spaces to locate,

identify, and measure the amount of ACM present.

b. An assessment further evaluates the ACM in terms of:

(1) Its potential to become airborne, or the actual extent to which it is a source

of airborne fibers (damage).

(2) What extent humans are exposed to airborne fibers in the functional

spaces of a facility containing asbestos.

c. Army asbestos management programs will include an assessment with any survey

conducted.

d. An assessment is used to determine if corrective action is needed, what corrective

action to use, and prioritizing the corrective actions. The assessment process includes:

(1) Identifying the type of ACM by taking bulk samples (i.e., wall board, pipe

insulation, surface compound, etc.)

(2) Evaluating the potential for fiber release (exposure potential).
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(3) Identifying and assessing the current condition of ACM using the

following information:

(a) Physical damage. If damage is present from vandalism, accidental

physical contact, or any other cause. Evidence of debris on horizontal surfaces, hanging

material, dislodged chunks, scrapings, indentations, or cracking are indicators of poor conditions.

If coated surface gives when slight hand pressure is applied or the material moves up and down

with light pushing, then the ACM is no longer tightly bonded to its substrate.

(b) Water damage. Inspect the area for visible signs of water damage,

such as discoloration of or stains on the ACM; stains on adjacent walls or floors; buckling of the

walls or floors; or areas where pieces of the ACM have separated into layers or fallen down,

thereby exposing the substrate.

(c) Deteriorating or delaminating from substrate. Inspects the area

for quality of installation (i.e., separating into layers, adhesive failure) or environmental factors

which affect the cohesive strength of ACM.

(4) Identifying potential for future damage, disturbance, or erosion of

material, including accessibility of material, frequency the area is used, activity likely to cause

damage, and any planned changes to the area.

e. Other important factors that must be included in the assessment of ACM are the

inherent friability of the material, percentage of asbestos in the material, where material is

located, number of people in the area, the duration of occupancy, location of ACM to air plenum

or direct airstream, and importance of the area.

f. In most cases the asbestos material is covered with a protective jacket of cloth,

tape, paper, etc. These bonding materials will prevent the material from becoming friable and/or

airborne. Most nonfriable materials can be broken without releasing significant quantities or

airborne asbestos fibers. Surfacing materials are usually bonded and will not become airborne

unless disturbed (i.e., vibration, drilling, etc.) The amount of ACM should be identified as linear

feet or square feet. All supporting building documentation should be included in the individual

building reports (i.e., building drawings, sampling data, assessment data of homogenous

materials per functional area, work sheets, etc.)

g. The evaluator must be minimally an AHERA certified inspector, if he or she is to

complete the assessment. Completion of the assessment requires, in accordance with AR 420-70

and AR 200-1, the evaluator to be minimally an AHERA accredited management planner. Prior

to commencing survey and assessments of functional spaces in a facility, the evaluator should

have participated in AMT meetings during which inspection strategies and plans were discussed

and written. Also, the evaluator should be provided and be familiar with any available facility

site plans, as-built drawings, previous inspection reports, abatement records, and any other

records, reports, plans, or accounts relevant to the ACM survey-assessment.
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B-7

h. As stated in paragraph B-3, suggested ACM checklists are provided in two parts

in appendix C. Use these checklists for assigning risk and exposure numbers. Using the

numbers derived from the checklists, enter the matrix in table B-1 and find the corresponding

assessment index. Then refer to table B-2 for definition of assessment index. For example,

using table B-1, if the damage/risk potential is 25 and the exposure potential is nine, then the

assessment index would be A. This would correspond to an immediate action from the

information obtained in table B-2. The higher risk and exposure numbers and assessment index

letters should be used only if there is a high probability of personnel exposure. The assessment

scheme in the checklists is identical to the algorithm shown and discussed, with a few

exceptions. The weighted numerical values corresponding to assessment choices in the

algorithm do not appear in the checklists and some of the line items contain additional

assessment choices. Management planners who want to prioritize functional spaces and, in turn,

facilities, based upon a numerical score ranking, should use the values for the assessment choices

given and the procedures discussed. In the future, management planners may use a database

management system.

i. Once a checklist has been completed for every functional space within a facility,

an AHERA-accredited management planner will compile and process the information. This

information will allow the management planner to document and/or confirm the existence of

homogenous areas of ACM and prioritize the facility in terms of its asbestos hazards relative to

other facilities at an installation.

j. The following asbestos report format should be used:

(1) Survey introduction, general summary of findings, and recommendations.

(2) Individual building information should include the following:

(a) Army ACM Checklist for each functional area and homogenous

material.

(b) Description of building use, summary of findings, and

recommendations.

(c) Building diagrams showing sample locations with photographs of

the sample locations.
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Table B-1. Determination of an Assessment Index

Each assessment factor in the checklist has one or more value-weighted conditions. For example, for the

assessment factor water damage to ACM, the value-weighted conditions are yes, valued at three points

and no, valued at zero points. For every value-weighted condition in the checklist, the corresponding

point value, in parentheses, follows a line, which is provided for the checkmark, used to indicate the

assessment factor condition selected by the evaluator. Following the selection of value-weighted

conditions for all assessment factors in part I of the checklist, the sum of the points is determined. The

sum is the damage value, entered at the end of part I and is used in the matrix below. The exposure value

is similarly determined from data in part II and used as the second entering argument in the matrix.

Using the damage/risk potential and exposure potential values derived from the checklist (Army ACM

assessment checklist), as entering arguments, use the matrix below to find the corresponding assessment

index.

Exposure Potential (1<E<26)

Damage/Risk

Potential

(1<D<20

26-17 16-10 10-5 4-1

20-17 A A A B

16-11 A B C D

10-5 A B C E

4-1 A C D F

Table B-2. Management Corrective Action

Assessment

Index

Recommended Management Corrective Actions

A Immediate action – Requires assessment by certified personnel (in-house or contractor)

who are experienced in and qualified to conduct asbestos assessments. Possible follow-up

actions may include isolation of the area and the restriction of access and/or immediate

removal of the ACM. If removal is indicated, action planning should include a detailed

survey. This condition will likely involve a near term expenditure of funds. Managers

must know exactly what needs to be done to eliminate the asbestos hazard and how to use

available funds most effectively.

B Action as soon as possible – Requires assessment by certified personnel (in-house or

contractor) who are experienced in and qualified to conduct asbestos assessments. Initiate

a special O&M program immediately. Possible follow-up actions may include the

limiting of access to the area and the scheduling of removal during periods of low activity

in the facility, not waiting for the normal repair and maintenance cycle.

C Planned action – Requires assessment by certified personnel (in-house or contractor) who

are experienced in and qualified to program. Initiate a special O&M program. Removal

should be scheduled as part of the normal repair and maintenance cycle of a facility,

minimizing cost and disturbance.

D Repair – Initiate special O&M using certified personnel. Damaged areas should be

repaired, where repair means returning damaged asbestos-containing building materials
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(ACBM) to an undamaged condition or to an intact state so as to contain fiber release.

Schedule removal when practical and cost effective. Take preventive measures to reduce

further damage.

E Monitoring – Continue special O&M using certified personnel. Take steps to prevent

damage to the ACBM or other ACM. Frequently monitor the condition of all ACM.

F Immediate action – Continue special O&M using certified personnel until major

renovation or demolition requires removal or until assessment factors change.

b. In the simplest of arrangements, the ACM checklists may be kept in a loose-leaf

binder with tabs separating the information for each building. A more efficient means would be

to contact the AEIS to obtain a copy of the current database in use. Utilization of a centralized

database source for maintaining specific building information required for asbestos surveys will

enable installations to access the system and keep it updated as removals/abatements, etc., take

place. More importantly, a statistical analysis of the homogeneous materials in the database

system would be performed to limit the amount of asbestos sampling required for future asbestos

surveys. This would allow a centralized asbestos program manager to evaluate homogeneous

materials used throughout Army installations to determine if this material is required to be

sampled in future asbestos surveys. Once a homogeneous material has been identified as being

an ACM then additional sampling of this material is not necessary. Additionally, non-ACM can

also be eliminated from future asbestos surveys therefore reducing the cost of sampling

homogeneous materials which are or are not ACM.

c. It is also important to note that a back up to the database and a current hard copy

should be retained in the event of accidental data loss.

B-5 Factors Used in the Assessment Process

a. Assessment information. The need for asbestos control beyond a special O&M

program depends on the likelihood of fiber release from ACM. It should be noted that the mere

presence of ACM does not in itself create a condition that requires its removal. The possibility

of fiber release can be assessed by evaluating the material’s condition, physical characteristics,

and location.

b. Potential fiber release. Factors for assessing potential fiber release are described

in paragraphs B-4 and B-5. The major factors to be considered are briefly reviewed here.

(1) Current condition of ACM. If water or physical damage, deterioration, or

delamination of the material is evident, then fiber release has occurred, is occurring, or is likely

to occur. The appearance of the material and the presence of peeling, cracking, or crumbling

material may indicate fiber release.

(2) Possibility for disturbance or erosion. Visible, highly accessible materials

in areas frequently used or needed periodic maintenance are the most vulnerable to physical

damage. Also, in this category are materials subject to vibration from mechanical equipment,

sound, or other activities. ACM in an air plenum or near a forced airstream (e.g., air from a
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heating vent) is likely to suffer surface erosion. In addition, fibers released into an airstream may

be transported to other parts of the building, possibly exposing more people. Any planned

changes in building use should also be considered when assessing future potential fiber release.

B-6 Exposure Analysis

a. An exposure analysis should be conducted prior to selecting an abatement

method. This analysis considers all descriptive and quantitative factors (related to material

condition, extent, etc.) compiled during the building asbestos survey and relates them to the

potential for occupant exposure to ACM. Prior to the conduct of an exposure analysis, the

Asbestos Management Team (AMT) should establish a written protocol that includes the

following:

(1) A procedure for ranking, prioritizing, or rating the visual assessment

factors described previously in paragraph B-4.

(2) Definitions of qualitative judgments, such as high exposure potential or

moderate damage.

(3) The relative importance of quantitative data, such as bulk sampling results

or air sampling results described in PWTB 420-70-8, Chapter 8.

(4) Assignments of exposure analysis responsibilities to members of the

AMT.

b. Some AMTs may find it useful to use an algorithm to provide a quasi-quantitative

basis to an otherwise subjective assessment. The recommended assessment method is easy to

understand and use; is quantitative enough to provide a measure of hazard severity to allow the

prioritization of facilities in terms of the need for corrective action; and provides a listing of

factors not readily amenable to quantification, but which should be considered by the IC in final

corrective action decision making.

(1) The assessment algorithm presented and discussed here is self-contained

and simple to use. The algorithm consists of a checklist (see appendix C), an assessment index

matrix, and a table of recommended management actions. In accordance with Army policy, the

checklist must be completed by an AHERA certified management planner. The management

planner may use the checklist either in concert with a survey inspection of a functional space or

in a separate evaluation of the ACM in a functional space at a later date, following a survey

inspection.

(2) The assessment algorithm discussed is a modified US Air Force system

that must have the conditions specified in PWTB 420-70-8, Paragraph 5-8 b and is more

applicable to small Army installations. The assessment algorithm for large Army installations is

found in PWTB 420-70-8, Appendix D. The Army ACM checklist Part I and Part II
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incorporates AHERA terminology and is the recommended method to use. To use this scheme, a

management planner works through the

checklist making value judgments for each of the damage/damage potential and exposure

situations which are then used in table B-1 to determine a letter assessment index. For each letter

index, a recommended corrective management action is listed in table B-2.

(3) The assessment algorithm is intended for use by a trained evaluator; that

is, someone who is familiar with ACM and knows of the layout and purposes of the facilities.

The checklist applies to friable ACM or normally nonfriable ACM which has become friable as a

result of damage. The ACM is also further classified as one of the major three types; surface

materials, thermal system insulation, and miscellaneous materials. Other nonfriable forms of

ACM shall be managed satisfactorily by an O&M program with abatement necessary only as

part of facility alteration/repair, maintenance, or demolition.

(4) An asbestos survey, locating, sampling, and measuring homogeneous

areas of ACM should be conducted concurrently with the assessment, when possible. The term

homogeneous area refers to an area of surface material, thermal system insulation, or

miscellaneous material that is uniform in color and texture.

B-7 Management Considerations

a. Even though an assessment index may accurately reflect the existing asbestos

health hazard within a functional space, it probably will not be an accurate and complete measure

of the AMP. The assessment index takes neither economic nor social factors into consideration.

These factors often represent the greatest obstacles to managing and controlling asbestos

hazards. A set of appropriate considerations is listed below.

(1) Cost considerations (estimating cost effectiveness).

(a) Cost of abatement (contractor’s estimate plus in-house personnel

dedication).

(b) Cost of temporarily relocating personnel and equipment for the

abatement.

(c) Cost of nonproductivity resulting from relocation of personnel and

equipment.

(d) Cost savings in preplanned remodeling, renovation and/or repair

projects resulting from abatement activities.

(e) Cost savings associated with enhanced use of functional spaces, in

facilities which have been purged of ACM hazards.

(2) Morale considerations.
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(a) Effect on morale of abatement-related personnel relocation.

(b) Effect of the notification of the need for abatement action on the

morale of those individuals who occupy the space. Any abatement action will alert them to the

fact that they had been working in a space determined as a high health risk environment.

(3) Miscellaneous considerations.

(a) Effects of flooding, wind, and fire damage on ACM integrity.

(b) Climatological restrictions of abatements (amended water can

freeze, thus making spraying impossible).

(c) Geographical restrictions on abatements (OCONUS facilities may

have special problems).

(d) Problems with functional spaces that are controlled areas.

• Unauthorized access and potential compromise of classified

materials in high security areas.

• Pilferage in a warehouse.

• Existence of ignition sources (e.g., smoking, non-explosion

proof electrical equipment) in or near combustible material

storage areas, associated with asbestos abatement workers.

(e) Special facility use (childcare centers and hospitals).

(4) Determination of the appropriate option (i.e., abatement or special O&M)

for each situation ultimately depends on the experienced professional judgment of the members

of the AMT who are charged with this responsibility.

b. Internal discussion and review among members of the AMT are encouraged to

ensure that all relevant factors are considered in assessing the potential for release of asbestos

from ACM.
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APPENDIX C

ARMY ASBESTOS - CONTAINING

MATERIAL CHECKLIST

Part 1: Damage Assessment

Installation: _______________________ Bldg/Rm No.: __________

Facility/Office: ____________________ Inspector Name/Date:____

Functional Area: ___________________

Physical. Assess damage based on evidence of surface accumulation; or the condition of the

sprayed-on or troweled-on surface materials; or physical deterioration or delamination of

materials using hand pressure.

_____(0) None *Non-asbestos materials; or no damage or evidence of material fallout;

or material is in fair to good condition; or nonfriable ACM, (i.e., floor

tile, wallboard, etc.); or (ACM) with less than one percent.

_____(1) Minimal *Isolated and very small areas (less than 10 percent) of material damage

or fallout; or controlled space and accessed by maintenance personnel

only; or uncontrolled/occupied space.

_____(2) Low *Visible evidence of some surface accumulation; or controlled space and

accessed by maintenance personnel only; or uncontrolled/unoccupied

space.

_____(3) Moderate *Visible evidence of small areas (less than 10 percent) of surface

accumulation; or controlled space and accessed by maintenance

personnel only; or uncontrolled/unoccupied space.

_____(5) High *Visible evidence of widespread surface accumulation; or uncontrolled

space and easily accessed by occupants.

Water.

_____(0) None No water damage.

_____(1) Minor Visible water damage (less than 10 percent) of ACM.

_____(2) Major Visible water damage (greater than 10 percent) of ACM.

*Note: If any one or a combination of these criteria are met, assign the corresponding value and

line out the criteria that do not apply.
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Part I: Damage Assessment. (Continued)

Proximity to items for repair. If both A and B apply, score the one with the highest rating.

(Check all that apply. Maximum of 3 points.)

A. Sprayed-on or troweled-on. Could the friable ACM be damaged by routine maintenance

activities?

_____(0) No routine maintenance is performed within the areas.

_____(1) Equal to or greater than five ft.

_____(2) Equal to or greater than one ft but less than five ft.

_____(3) Less than one ft from routine maintenance areas or a ceiling panel

contaminated with ACM must be removed.

B. Pipe, boiler, or duct insulation. Could damage occur as a result of routine maintenance 

or by occupants of building?

_____(0) No.

_____(3) Yes.

Type of ACM.

_____(0) *Non-asbestos materials; or nonfriable (ACM, (i.e., floor tile, wallboard,

etc.) in good to fair condition; or ACM with less than one percent.

_____(1) Miscellaneous ACM (i.e., ceiling tiles, etc.)

_____(1) *Boiler; or pipe insulation; or other ACM insulation materials (not

accessible to occupants).

_____(2) Nonfriable ACM (i.e., floor tile, wallboard, etc.) in poor condition.

_____(2) *Boiler; or pipe insulation; or other ACM insulation materials (accessible

to occupants).

_____(3) *ACM on exterior of supply ducts; or capable of being introduced into

air ducts (i.e., deteriorated ACM located in area of air ducts; or above

suspended ceilings).

_____(4) *Sprayed-on; or troweled-on surface ACM (accessible to occupants).

*Note: If any one or a combination of these criteria are met, assign the corresponding value and

line out the criteria that does not apply.
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Part I: Damage Assessment (Continued)

Percent asbestos.

_____(0) Less than one percent ACM.

_____(1) One to 30 percent ACM.

_____(2) 31 to 50 percent ACM.

_____(3) Greater than 50 percent ACM.

Note: If the percent asbestos content is less than one percent or nonfriable asbestos (in good to

fair condition) then the total for percent asbestos category will be zero (0).

DAMAGE (d) TOTAL_____(Max 20, Min 0)

Bulk sample results should be reported using the following format:

Sample No. Type Asbestos % Source

Analysis Performed by (Lab/Name/Date)________________________________

Part II: Exposure Assessment

Material friability. USEPA definition: hand pressure can crumble, pulverize, or reduce to

powder when dry.

_____(0) Nonfriable Material (i.e., floor tile, wallboard, binder’s etc.) in good to fair

condition.

_____(1) Low Friability Material difficult to crumble by hand.

_____(2) Moderate Friability Material fairly easy to dislodge and crush.

_____(3) High Friability Material easily reduced to powder; or broken by hand.

Occupant accessibility to ACM fibers.

_____(0) Low Accessibility *Materials are not exposed; or totally isolated by permanent

barrier; or accessible only during infrequent, occasional

maintenance activity; or no air flow from the friable insulating

material location to occupants of the building or storage areas.
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Part II: Exposure Assessment (Continued)

_____(1) Moderate Accessibility *Only a small percent of material exposed; or material

above a suspended ceiling; or material contacted during

maintenance or repair; or material exposed, but not

accessible to activity of normal occupants.

_____(4) High Accessibility *A large percent of material exposed; or material accessible

to occupants; or airborne transport during normal activities.

*Note: If any one or a combination of these criteria are met, assign the corresponding value and

line out the criteria that does not apply.

Activity/use.

_____(0) None No activity/storage activities.

_____(1) Low Infrequent maintenance activities only.

_____(2) Moderate Frequent maintenance activities only.

_____(3) High Normal occupant activities.

Air stream/plenum.

_____(0) None No perceptible air flow in the room or area.

_____(1) Present Airflow and no evidence of ACM present.

_____(2) Present ACM is exposed to perceptible or occasional air streams.

_____(3) Present *Airflow and evidence of ACM present in supply ducts/plenum; or

recirculated; or subject to routine turbulence; or abrupt air movement.

Area of visible surface or damaged ACM.

_____(0) Less than 10 cubic or linear feet (small areas should be repaired as soon

as possible).

_____(1) 10 to 100 cubic or linear feet.

_____(2) 100 to 1000 cubic or linear feet.

_____(3) Greater than 1000 cubic or linear feet.
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Part II: Exposure Assessment (Continued)

For occupied facilities only.

Population. This involves defining average occupancy as the total number of building occupants

and outside visitor traffic into a room or area during an eight-hour period. For example, a

reception area in a DEH shop has one person assigned to the area. There are 15 individuals

(including the receptionist) assigned to the building. They have approximately 240 customers

(visitors) in the building during an eight-hour period. On overage, each customer (visitor) is

serviced and departs the building within 30 minutes.

*Note: If any one or a combination of these criteria are met, assign the corresponding value and

line out the criteria that does not apply.

(outside visitors x time spent/8 hours) in area/room + building occupants = average occupancy

Example: ([240 visitors x 0.5 hours]/8 hours) + 15 occupants = 30. ............... Score as 2

_____(1) Less than nine or for corridors.

_____(2) 10 to 200.

_____(3) 201 to 500.

_____(4) 501 to 1000.

_____(5) Greater than 1000.

_____(5) Medical facilities, youth centers, childcare facilities, or residential

buildings, regardless of the population, will be assigned to this category.

For unoccupied facilities only.

_____(0) No ACM or less than one percent.

_____(1) Nonfriable ACM in good or fair condition.

_____(2) Nonfriable ACM in poor condition.

_____(3) Friable ACM in good condition.

_____(5) Friable ACM with visible evidence of damage.

EXPOSURE (E) TOTAL ________ (Max 26, Min 0) Inspection (Date) _______________

Note: Provide any other relevant information on observations in the space provided below. If

additional space is needed, attach additional pages as necessary.