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1.0 PURPOSE

This procedure is a requirement when handling any material containing asbestos, tremolite,
anthophyllite, or actinolite and supplements the Brown & Root Asbestos Abatement Guidelines
for Business Practice" manual that is a primary source for compliance for the projects that are
subject to performing minimal asbestos abatement

2.0 SCOPE

This procedure applies to Brown & Root operations worldwide. . Brown & Root approach to
performing asbestos-related work, recognizing the potential for asbestos and asbestos-related
material to exist on various project worksites.

3.0 REVISION HISTORY

Rev 0 – Moved from HSE Reference Manual to Occupational Health and Industrial
Hygiene Reference Manual. May 1, 2020

4.0 PROCEDURE

Brown & Root utilizes a three-tiered approach to the business of asbestos related work, listed
below in order of preference.

4.1 Option 1 - The preferred course of action is for the Owner/Client to contract a
survey for asbestos and asbestos related material in the area of Brown & Root's
work scope. If asbestos is found to exist, the Owner/Client is to contract for its
abatement then certifies to Brown & Root that work areas and equipment are
asbestos-free prior to Brown & Root beginning work.

4.2 Option 2 - When asbestos is detected or known to exist and the Owner/Client is
unable or unwilling to contract for its abatement, Brown & Root will subcontract the
abatement work to an Approved Asbestos Abatement Contractor. The contractor
would be identified by a joint review and approval process conducted by Brown &
Root's Legal, Procurement and HSE departments. Again, following certification of
an asbestos-free work zone, Brown & Root would then begin work.

4.3 Option 3 - Where asbestos removal is required on an occasional basis in order to

complete other required work and is small in nature, Brown & Root will maintain
personnel trained and medically certified to conduct the removal in a safe manner
following Brown & Root removal protocols. This group would receive an annual
physical and a post-employment physical upon their termination of employment.
Each project would assess their needs to determine the minimum number of
required removal personnel (including a trained Competent Person). Business
Units will develop a specific Asbestos Business Plan in compliance with the Brown
& Root Asbestos Program and details asbestos work activities at a project level.

4.4 In all cases, the Owner/Client remains as the EPA Hazardous Waste Generator of
record.

5.0 DEFINITIONS

5.1 ACM - Asbestos-Containing Material

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5.2 PACM – Presumed Asbestos-Containing Material

5.3 TSI - Thermal Systems Insulation

5.4 EPA - Environmental Protection Agency

5.5 Competent Person – one who is capable of identifying existing asbestos hazards
in the workplace and selecting the appropriate control strategy for asbestos
exposure, one who has the authority to take prompt corrective measures to
eliminate the hazards. For Class I & II work, one who is specially trained in a
training course which meets the criteria of EPA Model Accreditation Plan (40 CFR
763) for supervisors, or its equivalent. For Class IV work, one who is trained in a
manner consistent with EPA requirements for training of local education agency
maintenance and custodial staff as required in 40 CFR 763.92(a)(2).

5.6 “Class I” asbestos work is defined as activities involving the removal of thermal
system insulation (TSI) and sprayed-on or troweled-on or otherwise applied
surfacing asbestos-containing material or presumed asbestos –containing material
(PACM).

5.7 “Class II” asbestos work is defined as removal of ACM or PACM which is not TSI
or surfacing ACM or PACM. Roofing material such as mastic, flashing, and
cements when they are still intact are excluded. Debris must be less than one
glove bag, or standard-sized waste bag not exceeding 60 inches in length and
width, or it will be considered “Class I” asbestos work.

5.8 “Class III” asbestos work is defined as repair and maintenance operations which
are likely to disturb ACM or PACM. “Disturbance” means activities that disrupt the
matrix of ACM or PACM, crumble or pulverize ACM or PACM, or generate visible
debris from ACM or PACM. Operations may include drilling, abrading, cutting a
hole, cable pulling, crawling through tunnels, or attics and spaces above the ceiling
where asbestos is actively disturbed or asbestos-containing debris is actively
disturbed.

5.9 “Class IV” asbestos work means maintenance and custodial activities during
which employees contact, but do not disturb ACM or PACM, and activities to clean
up dust, waste, and debris resulting from Class I, II, and III activities. This may
include dusting surfaces where ACM waste and debris and accompanying dust
exists and cleaning up loose ACM or PACM debris from the thermal system
insulation or surfacing.

5.10 Regulated Area – any marked off area where airborne concentrations of
asbestos fibers exceed or are expected to exceed the time-weighted average
Permissible Exposure Limit.

6.0 WHERE ASBESTOS CAN BE FOUND

6.1Asbestos can be found in the workplace, particularly if you work or

have worked as a(n).
6.1.1 Carpenter Demolition Worker Dry Wall Finisher
6.1.2 Electrician Insulation Worker Pipe or Steam Fitter
6.1.3 Plumber
6.1.4 Roofer
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6.1.5 Shipyard Worker

6.1.6 Brake Repair Mechanic
6.1.7 Welder

6.2Outdoor workers, such as construction workers, landscapers, and

excavators may be exposed to naturally occurring asbestos found
above the ground through activities that crush asbestos-containing
rock or disturb dust in soils that contain asbestos. Asbestos can be
found in consumer products, mostly in:

6.2.1 Building Materials

6.2.2 Friction Products

6.2.3 Heat-Resistant Fabrics

7.0 METHODS OF RECOGNIZING ASBESTOS

7.1Assume that insulation or other suspicious materials contain

asbestos unless there is positive proof that they are asbestos-
free.

7.2Proof that a material is asbestos-free may be obtained by laboratory

analysis or by a reliable marking system used at the facility. Examples of
marking systems include colored bands, threads or flecks incorporated
into the insulation, or stencils.
7.3Marking systems used on this project include:
7.3.1 ___________________________

7.3.2 ___________________________
7.3.3 ___________________________

7.4Brown & Root employees are not to disturb the asbestos containing
material until they have received the proper training, have been
deemed medically fit to remove the ACM by a physician and have
received authorization to remove the ACM.

8.0 PERMISSIBLE EXPOSURE LIMIT (PEL)

8.1 In accordance with asbestos standards for the construction industry

and general industry, the PEL is 0.1 fibers per cubic centimeter (f/cc)
of air (as an eight-hour time-weighted average). There is also an
excursion limit of 1 f/cc as averaged over a sampling period of 30
minutes.

9.0 NOTIFICATIONS

9.1 Agencies require notification as follows:

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9.1.1 10-working day advance notice for all demolition projects

9.1.2 10-working day advance notice for renovation work involving
regulated asbestos containing materials (RACM) of at least 160
square feet from

facility components, 260 linear feet from piping or 35 cubic

feet when unable to calculate quantities by the other methods.
9.1.3 An annual notification is required for incidental RACM removals
that are below the reportable quantities.
9.1.4 Normally, the owner of the facility where the asbestos
removal is taking place is responsible for the notification. A
copy of this notice must be kept in the project files.
9.1.5 _______________(Name) will be responsible for the above
notifications.

9.1.6 Communication among all employees working on a

project is also required.

9.1.7 Brown & Root is performing work under the guidelines of

this procedure, ____________(name) will notify all
other employees on this property of:

9.1.7.1 Type of work being performed. The location of the work.

9.1.7.2 Restricted areas where access is required, and
their restrictions.

10.0 LICENSES/REGISTRATIONS

Many countries and states require licenses, registrations, or certifications

to conduct asbestos-related work. Some countries and states require
both a license for the Company and certificates/licensing for the workers.
Contact the Corporate HSE department for information regarding
requirements.

11.0 MEDICAL EXAMINATIONS

11.1 Required for all employees exposed to airborne concentration of

asbestos in accordance with the asbestos procedure in the Asbestos
Abatement Guidelines Manual.

11.1.1Information Provided to the Physician to the Company

doctor. A copy of the "Physician's Written Opinion" form
with doctor’s findings must be provided to the employee
within 30 days of its receipt.
11.1.2“Medical Questionnaire” must be completed as part of the
initial examination
11.1.3“Medical Questionnaire Supplement," may be substituted
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for annual examinations. Exit examinations are not

required if the employee has been examined in the
previous 12 months.
11.2 The licensed physician who performs these medical examinations
(in conjunction with a certified radiologist and pulmonary function
technician) for this project is:

11.2.1 Name:

11.2.2 Address:

11.2.3 Phone Number:

11.3 A record of these examinations will be maintained for the

duration of employment plus 30 years.

11.4 One copy is kept on the project site, and one is sent to the
Brown & Root Medical Department at the end of each year or
job completion, whichever comes first.
11.5 (Name and Title) is responsible for records routing and retention
and is the contact for Access to Employee Training.
12.0 TRAINING

12.1 Training must be provided prior to or at the time of initial

assignment and at least annually thereafter. Employees performing
Class I through Class IV asbestos operations, must be properly
trained pursuant to 29 CFR 1929.1101 (K) (9) or local equivalent.
12.2 The training program shall be conducted in a manner that the
employee is able to understand:

12.2.1Methods of recognizing asbestos.

12.2.2The health effects associated with asbestos exposure.
12.2.3The relationship between smoking and asbestos in
producing lung cancer.
12.2.4The nature of operations on this project that could
result in exposure to asbestos.
12.2.5Specific project site work practices and procedures that
limit exposure to asbestos, including personal protective
equipment, housekeeping, wet methods, engineering
controls, decontamination procedures, waste disposal and
emergency procedures.
12.2.6Medical surveillance program.
12.2.7The purpose, proper use, fitting instructions, and
limitations of respirators.
12.2.8The appropriate work practices for performing the asbestos
job.

12.2.9The name addresses and phone numbers of public health

organizations that provide information, materials and/or
conduct programs concerning smoking cessation.
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12.2.10 The requirements for posting signs and affixing

labels and the meaning of the required legends for such
signs and labels.

12.3 Additional training will include:

12.4 Training is required at initial assignment of related work and

annually thereafter (with fit testing repeated annually).
12.5 Asbestos and respiratory training and fit testing records (with
topics, name, SSN and dates) are kept on the project site, and copies
are sent to the Medical Department for retention with medical
examinations. Documentation of training shall be readily available
upon request.

13.0 WORK PROCEDURES

13.1 Monitoring

13.1.1A statistical analysis conducted during incidental

insulation removal operations reveals that the airborne
asbestos concentrations do not exceed the PEL when the
required work procedures are followed.
13.1.2Monitoring is conducted in accordance with the Asbestos
Abatement Guidelines Manual, and OHSA 29 CFR
1926.1101 (f) or local equivalent.
13.1.3Employees are notified, in writing, of the results of their
monitoring. Notification should occur as soon as possible
following receipt of the results.
13.1.4Industrial Hygiene Department (Corporate HSE Department)
can be contacted to coordinate air monitoring.
13.1.5Copies of monitoring results generated by the project are
forwarded to the Industrial Hygiene Department for
computer entry and retention for 30 years.

13.2 Restricted Areas

13.2.1Prior to commencing asbestos work, barricades and warning

signs (posted at all approach directions) are erected at a
sufficient distance to permit a person to read them and take
precautions before entering any area where asbestos
abatement is in progress.
13.2.2The warning signs must
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DANGER
Asbestos
Cancer & Lung Disease Hazard
AUTHORIZED PERSONNEL ONLY
Respirators and Protective
Clothing
Are Required In This Area

13.2.3Eating, smoking and chewing tobacco or gum are

prohibited inside the regulated area.

13.3 Respiratory Protection

13.3.1All personnel must comply with "Respiratory Protection

Program" in this manual and the Asbestos Abatement
Guidelines manual.
13.3.2Compete the written respiratory protection plan.
13.3.3Minimum requirement for this project (brand name used):
half mask air purifying respirators with P-100 high-
efficiency filters (magenta color).
13.3.4Respirator fit testing conducted annually.
13.3.5Additional respiratory protection requirements for this
project are:
_____________________________________________
_____________________________________________
14.0
_____________________________________________

14.1 Protective Clothing

14.1.1Disposable coveralls for this project are available at

and consist of:

14.1.2(Brand Name) with/without hood and attached foot

coverings.

14.1.3Hoods, worn over respirator, and made tight at

coverall junction (when separate).

14.1.4Boot coverings made tight at leg junction (when

separate).

14.1.5Gloves to be used are: (specify)

14.1.6Street clothing will not be worn under disposable

protective coveralls.
14.1.7Either disposable underclothing or cotton coveralls (which
requires special, daily laundering) will be worn under
disposable coveralls.
14.1.8Eye protection, as required by the job HSE plan
and the situation, will be worn.
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14.1.9All disposable protective clothing is disposed of as

asbestos waste when exiting the restricted area exit.

14.2 Dust Control

14.2.1For Transite cutting operations, power-operated tools will be

equipped with an exhaust system connected to a High
Efficiency Particulate Air Filter (HEPA) vacuum system.

14.2.1.1 The HEPA vacuum bags are changed while in the

restricted area in full protective equipment.

14.2.2 The ground or floor at asbestos cutting or removal sites must

be covered with 6 mil polyethylene sheets to facilitate proper
clean up.
14.2.3 Glove bags are mandatory for incidental thermal insulation
pipe jobs.
14.2.4 A HEPA vacuum must be available for clean-
up and decontamination.
14.2.5 Insulation must be immediately and thoroughly wetted when
exposed to ambient air.

14.2.6Use commercially available wetting agents

(amended water) or preferable encapsulating
agents.
14.2.7Use a low-pressure sprayer (with a narrow tip) to wet down
all exposed surfaces and wet cracks and seams with the
sprayer tip.

14.2.8If insulation removal is performed in elevated areas,

do not allow full bags to fall or drop to the ground
level.

14.2.9Bags are lowered to the "ground helper", who immediately

wets and bags any insulation material that falls to the
ground level.

14.2.10 After bulk (or gross) removal is completed, some

residual fibers may be left behind. If neglected, they can
eventually become airborne.

14.2.11 Fine cleaning with nylon brushes using wetting

agents and spray-on sealant coating ensures a complete
asbestos removal job.

14.3 Cleanup
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14.3.1All asbestos waste bags/drums and containers must be

marked as follows:

DANGER
Contains Asbestos Fibers
Avoid Creating Dust Cancer
and Lung Disease Hazard

14.3.2Any broken bags must be re-bagged prior to removal

from the regulated area.
14.3.3The polyethylene floor/ground cover is treated as
asbestos waste.
14.3.4All properly marked asbestos waste bags (or drums) are
taken to:

14.4 Decontamination for incidental asbestos work

14.4.1At a minimum, employees should remove contamination

from their outer disposable work suit (a HEPA vacuum is
the best method) and dispose of the suit as
contaminated waste.
14.4.2Reusable items such as hard hats, glasses, boots, etc.,
must be wet-wiped or HEPA vacuumed clean. Some items
that are not easily decontaminated, such as safety belts,
can be stored in a plastic bag and reserved for use only on
asbestos jobs.
14.4.3Each employee must wash his/her face and hands.
14.4.4The respirator is washed or wiped clean while still on the
face. The respirator is the last item removed.
Jobs other than incidental duration require the use of a
decontamination facility as described in Section X, Non-Asbestos
Fiber Precaution.
Details of the decontamination procedure for this project are as
follows:

12.0 ADDITIONAL ITEMS

12.1. If Brown & Root should be responsible for any off-site asbestos waste
disposal, contact Corporate HSE Department.
(specify) is responsible for disposal for this site.
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12.2. Additional requirements may include but are not limited to the following:

Three-compartment changing facility with equipment, shower

and clean rooms.
Negative pressure enclosure with air change of a minimum of
four per hour via negative air machine w/HEPA filter.
Daily area and personnel monitoring.
Trained/certified Competent Person on site.

12.3. Special asbestos work procedures (not covered in Section VIII. of this
document) are:

12.4. If negative pressure enclosures are used on this project, detailed

procedures must be attached.

13.0 NON-ASBESTOS FIBER PRECAUTION

13.1. Refractory Ceramic Fiber – Published toxicology studies have indicated

potential health risks to employees exposed to refractory ceramic fibers.
As a result of information, specific handling procedures are recommended.
Following is a brief summary of the refractory ceramic fiber information
and the recommended word practices:
13.1.1 Potential Sources

13.1.1.1 Refractory ceramic fibers are glassy, alumina silica

products that are created from molten masses of
synthetic raw materials or naturally occurring kaolin
clays. The fibrous material, manufactured by different
companies including Babcock & Wilcox, SOHIO, and
John Manville, is marketed under numerous trade
names, including:
Kaowool Kaolana Uni-Bloc Unifelt
Fibralana Pyro-Log Ultrafelt Saber Bloc
Fiberfrax ACE Kaowool Pyro-Bloc

13.1.1.2 Refractory ceramic fibers are used in different

applications such as foundry work, heat treatment,
forging, and chemical refining and processing.

13.2.1 Health Hazards

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13.2.1.1 Animal studies have indicated that inhalation of

refractory ceramic fibers can potentially cause lung
tumors. However, the studies have been
contradictory. In order to clarify some of the
uncertainties raised, new studies have been designed
to evaluate the human experience as well as further
animal studies with refractory ceramic fibers.
13.2.1.2 Irritations of the skin and upper respiratory area have
also been reported by individuals working with
refractory fiber-containing materials. This irritation is a
reaction caused by the sharp broken ends of fiber that
rub or become embedded in body tissue.
13.2.1.3 The c. The permissible exposure level has been
established by the manufacturers at 2 fibers/ cubic
centimeter.
13.2.1.4 Refractory ceramic fiber material that has been in
service at elevated temperatures (greater than
1600°F.) may undergo partial conversion to
cristobalite, a form of crystalline silica that can cause
severe respiratory disease. The amount of cristobalite
present will depend on the temperature and length in
service.

13.3.1 Recommended work practices

13.3.1.1 When installing, fabricating, repairing, or removing

any refractory ceramic fiber material, the following
precautions should be followed:
13.3.1.2 Wear long-sleeved, loose-fitting clothing (preferable
disposable coveralls) and gloves to prevent skin
contact. Unwashed work clothes should not be taken
home by employees.
13.3.1.3 Safety glasses, goggles, or face shields should be
worn whenever refractory ceramic fiber materials are
being applied overhead or in areas where loose
particles may get into the eyes.
13.3.1.4 Approved respiratory protection (with P-100 filters)
should be worn to protect against breathing
contaminated air.
13.3.1.5 Mechanical dust collection systems should be used
whenever refractory ceramic fiber materials are sawed
or sanded by machine. All handling and cutting should
be done in a manner that creates the least amount of
airborne dust (i.e., wet method).
13.3.1.6 If refractory ceramic fiber particles accumulate on
exposed skin, wash the area gently with warm water
and mild soap.
13.3.1.7 Avoid unnecessary re-handling of scap materials by
keeping waste disposal equipment as close to the
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working areas as possible.

13.3.1.8 In conclusion, until more is known about the possible
health effects of refractory ceramic fiber, care should
be taken when using this material as discussed
above.
14.0 References
14.1 Asbestos Abatement Guidelines