DFD (June 1998) GUIDELINE FOR SUPERVISON OF
ASBESTOS ABATEMENT ON DFD PROJECTS
A Memorandum of Agreement (MOA) between Department of Natural Resources and Department of
Administration was executed in 12/97. This agreement covers how asbestos abatement work at state
facilities will be managed and supervised. This agreement clarifies responsibilities and sets standards for
implementing, supervising, and inspecting abatement projects. As a result of this MOA, both the DFD
Asbestos Specialist and the DFD Project Representatives will be responsible for specific quality control
and contract enforcement activities. The purpose of this guideline is to identify and clarify these
Abatement of asbestos containing materials (ACM) is regulated by several agencies. While OSHA, EPA,
DNR, DHFS and DCOM have set standards for exposure limits for asbestos workers and rules for safe
removal and disposal of asbestos, there is no current requirement for removal of asbestos materials from
state buildings. DFD recommends that ACM materials be identified and managed and that only damaged
or friable asbestos be removed or encapsulated. Non-friable asbestos should be removed only if it poses
a potential health hazard. For example, ACM used as insulation in a plenum space, or ACM that is in high
traffic areas and at high risk of repetitive damage. Removal of asbestos materials encountered in a
remodeling project should generally be limited to the affected space only rather than throughout the entire
building. The determination of the extent of asbestos to be removed will be made by the Asbestos
Specialist or the Project Representative based upon their best judgement of the existing conditions.
Anytime during the course of asbestos abatement the DFD Project Manager must be informed if there is a
change in scope requiring additional funding to complete the abatement work.
This guideline provides a brief overview of the asbestos abatement process and essential information and
references needed by the Project Representative or the Asbestos Specialist to comply with the MOA and
properly supervise/inspect asbestos abatement activities on state projects.
Attached to this guideline are the following additional items:
Asbestos Abatement Flow Chart
Asbestos Project Information Transmittal Form
Pre-abatement Meeting Format for Statewide abatement Contract
Asbestos Abatement Inspection Form and Definitions
List of Abatement Contractors and Air Monitoring Consultants
Memorandum of Agreement with DNR
DNR Asbestos Information and Disposal Fact Sheet
List of Regulatory Assistance Resources
HFS/DNR Form 113 - Notification of Demolition and/or Renovation
DFD Asbestos Specialists will provide advice and assistance as needed to resolve abatement project
issues or to provide direction on how to proceed when unusual problems are encountered. Contact Tim
Stratton (608-261-4348) or Dan Day (608-266-1297).
Questions about clarification or application of the MOA should be directed to Tim. He will consult with
DNR and others, if necessary, and provide an appropriate response.
Federal Code 29 CFR 1926.1101, OSHA Standard for construction became fully effective in July 1995.
This standard provides a permissible exposure limit of .1f/cc(fibers per cubic centimeter) time weighted
average over the entire shift, or a maximum exposure level of 1.0f/cc for 30 minutes per 8 hr. shift.
This rule defines four different classes of asbestos removal work:
Class 1 - removal of thermal system insulation and surfacing asbestos containing materials.
Class 2 - removal of floor tile, siding, roofing, wallboard, linoleum, mastics, ceiling panels, and
other ACM that is not thermal insulation or surfacing material.
Class 3 - Repair and maintenance projects that will disturb thermal system insulation and
Class 4 - Maintenance or custodial activities that come in contact with or cleanup ACM debris.
Each class has specific requirements for control and isolation of work area, supervision of work, protecting
workers, air monitoring, abatement work practices, cleanup and decontamination, and project
documentation. The contractor is responsible for compliance with these specific requirements per project
Federal Code 29 CFR 1910.134, OSHA Employer’s respirator Program, covers requirements for selection
of respirator equipment, training, employee exposure monitoring, etc. when required for abatement of
WI Code NR 447, defines friable and non-friable ACM and provides requirements for handling, transport,
storage, and disposal of ACM. Notification must be made to DNR Bureau of Air Management for all ACM
abatement work with greater than reportable quantities at least 10 business days prior to beginning of
demolition or removal.
WI Code HFS 159, covers requirements for training and certification of asbestos workers. Notification for
ACM abatement work with greater than reportable quantities must also be given to HFS at least 10
business days prior to commencement of work. Any abatement activities involving less than the
reportable limits must be reported to HFS at least 24 hours prior to start of work, with a courtesy copy sent
Initial sampling, testing, and documenting of ACM materials is the responsibility of the agency. In some
instances, DFD has conducted a thorough room by room inventory of the facility for asbestos containing
materials. This data is available in the Wisconsin Asbestos and Lead Management System (WALMS) web
site. Contact the DFD asbestos specialist for a current listing of facilities with WALMS inspections. If
removal of ACM is needed to protect employees or the public or to facilitate a maintenance or renovation
project it must be accomplished prior to start of such a project. The agency or the Project Manager
submits a request to the Asbestos Specialist for implementing the abatement work.
The Asbestos Specialist verifies the request and the abatement work is either assigned to DFD for
execution under a statewide abatement contract or to an Asbestos Consultant for additional testing and
development of scope of work for bid documents.
DFD has pre-bid hourly rates and set up statewide/regional construction contracts for small or incidental
asbestos abatement work. A copy of the specs for these contracts will be provided to the field offices, and
a list of the current abatement contractors is attached. Larger projects will be designed and bid under a
separate spec and construction contract.
Assignment of a Project Representative is mandatory for abatement work where reportable quantities are
being exceeded. In addition, the Project Representative will cover planned or incidental abatement work
on remodel projects already assigned. Incidental abatement work on other projects may be handled
directly by the Asbestos Specialist where a Project Representative is not involved.
The Asbestos Specialist, following award of contract, provides a Project Information Sheet, including
location and description of work, contract information and other pertinent data, to the Regional field office.
If asbestos unexpectedly becomes an issue after a building remodeling or maintenance project is
underway, the Project Representative should take responsibility for coordinating this activity and should
report the incident to the Asbestos Specialist and, if needed, obtain direction on who to contact for
identification and removal services.
A pre-abatement meeting is mandatory for all abatement work exceeding the reportable limits. The
Project Representative is responsible for scheduling and conducting this meeting. In addition to the
abatement contractor, the Asbestos Specialist and Project Manager, the Asbestos/Air Monitoring
Consultant, and DNR should be invited to this meeting. The asbestos consultant is responsible for pre-
abatement meeting minutes and distribution. A format to be used for a pre-abatement meeting with the
regional abatement contractor is attached. A standard pre-construction meeting format can be used for
other abatement contracts. Generally, a pre-abatement meeting is not required for abatement work with
less than reportable limits unless deemed otherwise by the Project Representative or the Asbestos
Specialist because of special site or scheduling considerations.
The Project Representative shall confirm that the contractor has provided proper notices as follows:
DNR - Prior to start of abatement work (10 working days for abatement activities involving more
than the reportable limits).
DHFS - Prior to start of any abatement activities (10 calendar days for projects involving more
than reportable limits and at least 24 hours prior to start of work for abatement activities
involving less than reportable limits).
Work shall not proceed unless proper notice is given. A copy of DNR Form 113 - Notification of
Demolition and/or Renovation is attached for reference. Contact the asbestos specialist or your immediate
supervisor for verification this notification has been filed.
Reportable Limits are defined in WI Code NR447 and include:
All Demolition Activities
Renovations, including any nonscheduled renovation operations, if the combined amount of
regulated asbestos containing materials to be stripped, removed, dislodged, cut, or drilled or
similarly disturbed meets any of the following:
1. At least 260 linear feet on pipes.
2. At least 160 sq. ft. on other facility components.
3. At least 35 cubic feet off of facility components where the length or area could not be
4. Saw cutting at least 5580 sq. ft of asphalt roofing area.
All areas of asbestos removal associated with the project shall be combined to determine the
applicability of reportable limits.
The Project Representative shall conduct periodic inspections of the abatement work as determined at the
pre-abatement meeting. Inspections may cover pre-abatement, preparation, abatement, and post-
abatement activities. Inspections will be a visual inspection performed outside the containment area. The
attached DFD Asbestos Inspection form shall be used to document the inspection and contractor's
compliance/non-compliance activities. If noncompliance items cannot be resolved with the contractor, the
Project representative should contact the Asbestos Specialist.
The Asbestos Consultant or an independent Air Monitoring Consultant will perform air monitoring for the
project and visual inspections inside the containment area. DFD has regional Engineering Services
contracts with several firms to provide air-monitoring services. A list of the current air monitoring
consultants is attached.
Abatement work on projects that exhibit "hazardous or unsafe conditions" shall be stopped. Examples of
unsafe conditions include but are not limited to:
Breach in containment that allows airborne asbestos particles to escape.
Contractor's job supervisor not on site.
Inadequate decontamination resulting in workers transferring asbestos fibers on shoes or
Electrical power to abatement area is not Ground Fault Protected.
Improper operations of HEPA unit resulting in insufficient air exchange and/or negative
pressure (min 4 air changes per hour and minus .02 column inches of water pressure
Improper wetting of ACM or other improper removal procedures or equipment.
Double bagging not provided or other improper handling and disposal procedures.
A work stoppage is not warranted if the contractor immediately corrects the problem. Decisions to shut
down the abatement work should be reviewed with the DFD Asbestos Specialist prior to implementing,
unless immediate action is needed to protect occupants form exposure.
Final Inspection and Air Clearance
The abatement contractor schedules the final inspection with the independent Air Monitoring consultant
who in turn notifies DNR and DFD. Compliance must be achieved before final payment for abatement
work is approved. The independent Air Monitoring consultant and the abatement contractor conduct the
actual inspection inside the containment area. The Project Representative shall, in accordance with
article 23 of the general conditions, determine substantial completion.
While the contractor must notify DNR of the final inspection, DNR may/may not attend.
All parties should receive a copy of the completed inspection and air monitoring report. The Project
Representative should follow up to see that deficiencies are immediately corrected.
Abatement Project Administration and Closeout
Contractor requests for payment and change order proposals shall be submitted to the Project
Representative for review and approval prior to submittal to the DFD Central Office. Use the FO system
to document scope clarifications and changes. Exceptions to this procedure should be addressed at the
Upon completion of the work, the Project Representative shall forward all files and documentation related
to the abatement project to the Asbestos Specialist for permanent record keeping.