icon (which brings you back here), then select one of the following links: Environment-i-media, Inc. |
To return to the demonstration, click on the icon (which brings you back here), then select one of the following links:
- Contractual and financial basics
- Cost
- Security
- Definitions
- Consultants and Tenants
- Environment-i-media, Inc.
- Locations and Precautions Pages
- Regulations
- Notification Forms
- Assessments, Quantities and Costs
- The future of the Customized Compliance Program for Asbestos
Contractual and financial basicsThe Customized Compliance Program for Asbestos is licensed only to building owners, as OSHA defines the term in the Construction Industry Standard for Asbestos. This also includes property managers and some tenants.
• The entity to whom the Program is licensed is called the Licensee.
• Consultants to the Licensee can use the Program through the Third Party User arrangements.
• Each copy of the Program is licensed for use at one facility and the materials are delivered on a CD for that facility.
• The CD contains the files needed for the Initial Set-up, which adds content specific to the facility to the Locations and Precautions pages and the Assessment and Cost pages. The CD also contains a Practice Set-up and a User Tutorial for familiarization with the program.
• Other software, including a browser, Microsoft Word and Excel, and Dreamweaver needed to run and set up the program, is not included on the CD.
• Additional facilities can be added for the same Licensee by using the "Designation of Additional Facilities" form.
• Environment-i-media, Inc. will provide technical support to assist Licensees with setting up and using the program, including training of staff and/or consultants, or will set up the entire program for the Licensee under terms mutually agreed to.NOTE: The above is only a summary. Use of the Program is governed by the License Agreement.
How much does the Customized Compliance Program for Asbestos cost?
For $995 per facility you receive a CD with the program materials. Andy Oberta, the creator of the CCPA, will personally provide up to six hours of technical support by e-mail or telephone for each $995 license fee that you pay. If more support is needed, a credit card or purchase order will be requested to cover the charges at a rate of $100/hr. On-site support can be provided at $100/hr; travel time and expenses are additional.
How secure is the information in the program?
Security of information about your facility is a major consideration and we share your concerns. The photographs, floor plans and other details must be carefully safeguarded to prevent unauthorized access -- or worse. The Customized Compliance Program for Asbestos can actually help you to control access to sensitive areas by employees and contractors who need to work on or near asbestos-containing materials.
Of course, you need to enforce existing security procedures. Use the Customized Compliance Program for Asbestos to complement those efforts by indicating on the floor plans the designated entry point(s) to your building or facility for contractors and approved travel routes through the building or across the premises. Put some brief instructions about security on the Locations & Precautions pages and on the Notification Forms.
For our part, Environment-i-media, Inc. will review any information security requirements that you provide to us and advise you if there is an additional cost to comply, or if we are unable to do so. We suggest doing this before sending us information about your facility. If necessary, we will password-protect the information on the CD that we deliver with your program on it.
Once you receive the CD and install the program on your own computer, the information is as secure as any other files on your hard drive. Any files that you share on a network, by e-mail or on portable media will be as secure as your own procedures can make them.
Finally, remember that the Customized Compliance Program for Asbestos does not alter any files or programs on your hard drive. The only executable file opens when you insert the CD.
For purposes of using this program, a facility is "an institutional, commercial, public, industrial or residential structure, installation or building, or a combination thereof at a single location that is under the ownership, management or otherwise controlled by a single company, agency or institution".
Examples:
1. All buildings in a shopping center or mall on one contiguous property are one facility if the owner or manager of the shopping center or mall is the Licensee.
a. A shopping center or mall owned by the same Licensee at a different location is another facility. It can be registered by using the "Designation of Additional Facilities" form and paying the required fee.
b. If the Licensee is one of the tenants of the shopping center or mall, such as an anchor store, the program may be used only for that store. A store in another shopping center or mall would be another facility, which can be registered by using the "Designation of Additional Facilities" form and paying the required fee.2. Each school and each administrative building or complex of buildings in a school district is a separate facility.
3. The buildings on one campus of a college or university are a single facility. Off-campus buildings are separate facilities.
4. An industrial complex on one contiguous property is a single facility, regardless of the number of buildings. Buildings and other structures, or complexes thereof, at other locations are individual, separate facilities.
Our definition of a facility is somewhat flexible. If it is not clear how many facilities your property includes, ask before ordering the program.
What are Additional Facilities?
Each copy of the Customized Compliance Program for Asbestos is created and registered for one facility, which is identified on the application form. This might be your corporate or agency headquarters building, or your main manufacturing plant, and you may have other facilities where you want to use the program. These are "Additional Facilities", and you obtain a copy of the program for each of them by submitting a "Designation of Additional Facilities" form and paying the required fee.
OSHA defines a Building/facility owner as "the legal entity, including a lessee, which exercises control over management and record keeping functions relating to a building and/or facility in which activities covered by this standard take place." We call this entity the " Licensee" for contractual purposes as well as the "Building Owner". to describe their relationship with other parties who enter the facility. The Building Owner / Licensee doesn't have to own the facility in the legal sense -- they could also be a property manager as long as they have primary responsibility for asbestos management.
The Construction Industry Standard requires notification of "Tenants who will occupy areas containing such material" whenever work is done that is covered by the standard. Remember that this is a worker protection regulation and the purpose of notification is to inform workers. "Tenant" is therefore the entity that is an "employer of other employees" to use OSHA's phrase. This is different from a residential tenant who occupies a rented house or apartment. Because there is no employment relationship between the landlord and residential tenants, the landlord has no obligation under the OSHA regulations to notify them. There may be such an obligation under other regulations and informing residential tenants about asbestos may be advisable for liability purposes and other reasons. The Notification Forms feature includes a Non-Occupational Notice for residential tenants, visitors and other “invitees.”
A contractor is someone who performs work at your facility but doesn't work for you as an employee. A contractor may be a firm or individual and is responsible for conveying the information about asbestos that you give him to his own employees. Contractors include not only construction and asbestos abatement firms, but also firms and individuals who service your vending machines, maintain your mechanical equipment, run your food service operations and do the other things that keep your facility operating.
Submit an Application for License form for each facility at which you want to use the CCPA. You will receive a CD with the program materials, including three sets of instructions in PDF to print out and follow. After going through a Tutorial and Practice Set-up, you or your consultant will add the facility-specific content through a process called the Initial Set-up. The CD you receive from us will contain the files and instructions for doing this, including a set of files to practice with. The files include a set of templates that requires using the Dreamweaver web authoring software (the software is not included with the CCPA). These templates are provided for a number of layouts of the Locations and Precautions pages, as well as the Assessments and Costs pages. The files also include a list of precautions for each of several common types of ACM, as well as a set of O&M procedures. We can provide technical support to assist you with this process.
How do consultants use the Customized Compliance Program for Asbestos?
The Licensee designates a consultant as "Third Party User" for one or more facilities and pays the required fee to Environment-i-media, Inc. This entitles the consultant to receive a set of program materials for each facility instead of, or in addition to, the Licensee. The consultant can take the photos and assist the Licensee in using the program according to their own agreement. Environment-i-media, Inc. is not trying to compete with consultants for their client's business. We want to help consultants help their clients manage asbestos-containing materials as efficiently and economically as possible.
Under the "Third Party User" arrangement, the primary contractual arrangement is still between the Licensee and Environment-i-media, Inc. The Licensee remains responsible for consultant's use of the program.
Why can't consultants purchase the Customized Compliance Program for Asbestos?
The Customized Compliance Program for Asbestos is not available directly to consultants, but can be used by them through a "Third Party User" arrangement. A consultant may play an important role in asbestos management, but he doesn't have legal responsibility for asbestos management as defined by OSHA. The License Agreement for the program establishes a contractual relationship between Environment-i-media, Inc. and an entity that qualifies as a Building/Facility owner, which definition does not include consultants.
Can a tenant be licensed to use the Customized Compliance Program for Asbestos?
Certainly. Tenants often contractually assume responsibility for asbestos management and therefore meet OSHA's definition of a Building/facility owner and our requirement for purchasing the program.
Environment-i-media, Inc. produces, publishes and distributes training and information technology products related to asbestos. These products are known as the "Mult-i-media Suite" and include videotapes, DVD and Powerpoint™ programs and printed materials and the Asbestos Photo Gallery as well as the Customized Compliance Program for Asbestos. For a description of these products, return to the Environment-i-media, Inc. home page.
Who created the Customized Compliance Program for Asbestos?
Andy Oberta is the Producer and Publisher of Environment-i-media, Inc. As Andrew F. Oberta, MPH, CIH of The Environmental Consultancy, he is an internationally-recognized asbestos consultant with over twenty-five years of experience in the field. For information on his consultng services, visit www.asbestosguru-oberta.com.
What does the Environment-i-media, Inc. copyright cover?
The copyright covers the program software, structure and formats and all materials delivered on the CD, as well as content prepared for the Initial Set-up and thereafter by or for each Licensee. The pages produced for and by the program have our copyright notice on the bottom. This prevents an unauthorized person from creating and distributing pages in the same format, but does not prohibit the Licensee from sharing the pages according to the "License Agreement". The pictures and floor plans you provide remain your property and will not be divulged to others without your written permission.
Who provides the photos and floor plans?
You or your consultant can do it, or we can do it for you as technical support at additional cost. Remember, if you want your consultant to receive any of the program materials, you will have to register them as a "Third Party User". If you don't want to take the pictures and don't have a consultant, we can help you get it done. Call us.
What format are the CCPA pages in?
The Home Page, Locations and Precautions pages, and the Assessments and Costs pages, are in HTML format. To view them, you use the same browser that you are using to view the files on this website. The Notification Forms and printable/e-mailable versions of the web pages are in MS Word format. The Assessments and Costs feature uses Excel spreadsheets for the Initial Set-up.
We write them. The program includes a set of MS Word files, each containing a list of precautions for common surfacing material, thermal system insulation and miscellaneous material. As clients send us pictures of unusual materials (spray insulation on electrical wires and window caulking, for example), we add precautions to the list if needed. The lists are imported into the Locations and Precautions pages using Dreamweaver software when the pages are created.
Can I use photos and floor plans in digital format?
Yes. We provide detailed instructions for doing this. Photos and floor plans have to be digitized
for the Locations and Precautions pages. You can scan your prints or slides, use a digital camera or import drawing files. The simpler and clearer the drawing you use, the easier it is to work with.If you send photos and floor plans to us for your Initial Set-up, remember that these can be large files. Rather than e-mail several MB of files, please burn them onto a CD and send it to us, or send us the materials to scan..
Can I put more than one picture on an Locations and Precautions page?
Yes, and the Dreamweaver templates for the Locations and Precautions pages provide for this arrangement.
Dreamweaver is a program by Macromedia (part of Adobe Systems) for creating websites. It is professional-quality software but does not require the skills of an IT expert to use. The CCPA has been set up with basic Dreamweaver tools that are easy to learn and apply. You will use Dreamweaver templates when doing the Initial Set-up for your facility – these templates have already been created and are on the CD as part of the program materials. The Dreamweaver software is not included on the CD but it available at nominal cost from Macromedia and other sources. Using Microsoft Front Page or other web authoring software may compromise the functionality of the Dreamweaver templates and certain features of the CCPA, so we discourage you from trying to do so.
Does the CCPA explain the OSHA Asbestos Regulations
The section of the OSHA asbestos regulations that pertain to hazard communication are explained in the program. This section covers notification, training and also signs and labels.
Under the recent revisions to the EPA Worker Protection Rule (40 CFR Part 763), employees of government agencies in states not covered by an OSHA-approved State Plan must comply with the current OSHA Construction Industry and General Industry standards. School employees in these states are covered by this rule, so the Customized Compliance Program for Asbestos would be a valuable tool for the Local Education Agency Designated Person. In addition, public and private schools (K - 12) must comply with the specific notification and record-keeping requirements in §763.94 of the EPA "AHERA" regulations. An "AHERA" version of the Customized Compliance Program for Asbestos "Notification forms" can be prepared to respond specifically to these requirements.
What format are the Notification Forms in?
The forms are in Microsoft Word, which means that you can easily fill them out, save them and e-mail them as attachments. The instructions for the Notification Forms feature tells you how to do this.
Can the program generate NESHAPS notification forms?
The program does not contain the NESHAPs "Notification of Demolition and Renovation form as published by EPA in the Federal Register. Most of the states, and some local governments, that enforce the NESHAP regulations have created their own version of this form, which is usually filled out by a consultant or abatement contractor. We could add the version of the form applicable to your facility as technical support at additional cost.
Where did the assessment protocol originate?
The Current Condition and Potential for Disturbance ratings trace their origin to the ASTM Manual on Asbestos Control , published in 1995. The Manual was written by Andy Oberta, the creator of the Customized Compliance Program for Asbestos . The protocol has been incorporated in the ASTM E2356 Standard Practice for Comprehensive Building Asbestos Surveys and has reached its current state of development in the CCPA, where it far surpasses any previous methodologies in its versatility and value of the information to the user. Its use is described in detail in the Manual on Asbestos Control: Surveys, Removal and Management – Second Edition, also by Mr. Oberta, published in 2005.
Where do the quantiities and cost information come from?
The survey report for your building or facility probably included this information/ You or your consultant will use the survey report to prepare the tables for the Assessments and Costs pages and the program generates the three-dimensional color charts from these tables. Survey reports usually estimate removal costs on the basis of unit costs (e.g. $15/ft² for some types of surfacing material), and these costs can be modified when preparing the tables. There is considerable flexibility in how the Assessments and Costs pages can be set up.
What is "Probable Removal Cost?"
The survey report shows the cost of abatement you decided to remove the ACM – or had no choice, as before renovation or demolition. The Customized Compliance Program for Asbestos calls this the Potential Removal Cost, which might be $250,000 for example. But a lot of the ACM may be in good condition and in little danger of being disturbed, so the amount of money you are likely to spend on removal in the near future may be much less. The CCPA uses the Current Condition and Potential for Disturbance ratings to determine the probability you will remove the ACM solely on the basis of these factors and applies the probability to the Potential Removal Costs. The resulting Probable Removal Costs are what you should budget for removal, which might be $50,000 instead of $250,000, based on what you know about the ACM from having assessed it according to the protocol in the CCPA.
What does the future hold for the Customized Compliance Program for Asbestos
The Customized Compliance Program for Asbestos is still very much a work in progress. Here are some of the enhancements we are currently working on:
• Links to other asbestos management files
Many asbestos survey reports are now submitted in electronic format. We can link these files to the Locations and Precautions pages so that, for example, you can instantly retrieve the results of bulk samples taken in the room.
We can import information from your existing databases to create the files for the Locations and Precautions pages and the Assessments and Costs pages.
We can also link your Locations and Precautions pages to the procedures in your O&M plan that might apply to work done in the room.
• Horizontal layers on floor plans
We can show different materials in the horizontal plane, from the floor tile to the roof membrane, with cutaway views on the floor plan. The actual colors of the materials can be matched for plaster, fireproofing and other materials.
• Aggregation and selection of Assessments and Cost data
Owners and managers may want to combine the Assessments and Cost data from several buildings and/or facilities for a number of management and financial purposes, such as estimating the cost of removing all
• ACM in the building or facility they are responsible for;
• ACM in less than “Good” condition, or with a Current Condition rating of less than a certain value;
• Friable ACM or certain types of ACM;
• ACM in certain locations such as mechanical rooms or public areas.We are working on ways to sort, select and aggregate these data and displaying the information in the same three-dimensional color charts you have seen in this demonstration.
Life-cycle costs
There is a cost associated with having ACM in a building or facility until it is removed: this is called Operations and Maintenance, or O&M. We have developed a method of estimating these “Life cycle costs” based on the Current Condition and Potential for Disturbance ratings as well as other factors that affect the management of ACM in a building or facility. The resulting costs are displayed on three-dimensional color charts similar to those you have seen in this demonstration. This feature will be incorporated in the Customized Compliance Program for Asbestos in the future.
Many other ideas will evolve from the use of the program by yourself and others.
