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SEC-007: Management of Asbestos-Containing Materials and Lead-Containing Materials in University Facilities

Date: 06/30/2005 Status: Final
Last Revised: 10/17/2023
Policy Type: University
Oversight Executive: Vice President for Research
Applies To:

Academic Division and the Medical Center.

Reason for Policy:

This policy and its procedures are intended to protect the University community from harmful exposures to asbestos and/or lead during renovation, maintenance, and demolition activities in University facilities.

Policy Summary:

Asbestos-containing materials and lead-containing materials within University of Virginia buildings and structures must be properly managed.

Definition of Terms in Statement:
  • Project Manager:A University representative who may be the Facilities Management Project Manager or Construction Manager, or any other University employee who arranges for a renovation, maintenance, or demolition project that could disturb building materials within a University facility.
  • University Facility:Any defined space of the University, including a room, lab, series of labs, building, or controlled outdoor area.
Policy Statement:

The University of Virginia will comply with all federal, state, and local regulations that apply to the handling and disposal of asbestos-containing materials and lead-containing materials in a University facility. Project Managers are required to contact the Office of Environmental Health and Safety (EHS) prior to renovation, maintenance, and demolition projects for the purpose of identifying the presence of asbestos or lead in work areas.

[Note: This policy applies to all University buildings and structures, including, but not limited to bridges, tunnels, towers, tanks, and other man-made assemblies of materials.]

Asbestos: If asbestos will be disturbed by the project, EHS (or State-Licensed Asbestos Inspectors, Designers, and Monitors) will provide the necessary inspections, project design, and project monitoring as required by federal, state, and local regulations.

Lead: If lead will be disturbed by the project, EHS or Facilities Management safety personnel are available to provide guidance in ensuring the safe and compliant conduct of activities involving lead, including the collection of OSHA-required personal air samples for University employees. EHS will characterize lead-containing waste materials to determine the appropriate course of disposal, in accordance with applicable regulations.

[Refer to the Asbestos and Lead Safety section of the EHS website for additional resources and procedures to be followed to achieve compliance with this policy.]

Compliance with Policy:
Failure to comply with the requirements of this policy may result in disciplinary action up to and including termination in accordance with relevant University policies.

In addition, non-compliance with:

  • asbestos inspections may be subject to enforcement and penalties as defined by Code of Virginia § 40.1-51.22 and § 40.1-51.39.
  • asbestos or lead OSHA requirements may be subject to enforcement and penalties as defined by the US DOL Federal Civil Penalties.
  • the EPA’s NESHAPS and RRP regulations may be subject to enforcement and penalties as defined by Section 409 of TSCA and civil penalties can be assessed pursuant to Section 16 of TSCA.

Questions about this policy should be directed to Environmental Health and Safety.

Major Category:
Safety, Security and Environmental Quality
Next Scheduled Review:
Approved By, Date:
Policy Review Committee, 06/30/2005
Revision History:
Updated Note 10/17/23; Merged SEC-007 and -008 12/10/19.
Supersedes (previous policy):

XIV.B.1: Asbestos-Containing Materials Management; XIV.N.1: Lead-based Paints Management.