Feb. 23, 2023
When hiring a contractor or consultant, building owners have certain responsibilities under the Ontario Occupational Health and Safety Act and O. Regulation 287/05 Designated Substance – Asbestos on Construction Projects and in Building and Repair Operations. These responsibilities apply even when the contractor/consultant is not expected to perform asbestos work. Below is a summary of requirements for departments that do engage contractors and consultants for projects, maintenance, repairs and emergency work.
- Per the Asbestos Management Program (AMP), all contractor supervisors and workers must have completed at least Asbestos Awareness training, even if they are engaged for non-asbestos work. Due to the presence of asbestos in a variety of building materials, contractors are likely to encounter asbestos during the course of their work with the University. This training helps educate contractors on the potential presence of asbestos. Contractors must immediately stop all work and notify their UofT contact in the event of accidental disturbance of asbestos-containing materials or when previously unidentified asbestos-containing materials are discovered in the course of work (see Appendix D of the AMP, entitled “Emergency Procedures in the Event of Unexpected Asbestos Release”).
- In Ontario, regulations require that an owner identify designated substances on the project and provide a list to prospective constructors before contracts are finalized. Designated substances are not limited to only Asbestos, but also includes Lead, Silica, Mercury, etc. At UofT, this “list” is provided in the form of a designated substance report or a designated substance summary report (DSSR). This step is extremely important. Any work that may cause disturbance of the building fabric should be reviewed to ensure that designated substances are identified ahead of time. For UTSG, please provide necessary project details to the F&S Hazardous Construction Materials Group. For UTM and UTSC, external consultants are engaged to conduct a designated substance survey and prepare the required report.
- Consultants: This also applies to consultants (e.g., engineering, design, architectural or commissioning consultants) where the work requires them to physically investigate/study the site conditions. At UTSG, a consultant version of the DSSR is available for each building in the Asbestos Database (under the Documents tab). The Consultant DSSR also lists out conditions where a consultant is required to have asbestos training and/or contact the project manager/project owner.
- Contractors for non-project work (e.g., repairs, emergencies): This also applies to asbestos work for contractors falling for general building repairs and maintenance (O. Regulation 278/05, section 10). After providing the DSSR for the relevant buildings (in some cases, you will need to provide for “all buildings” if the contractor can work anywhere on campus), departments must obtain the contractor’s acknowledgement in writing. A template is available to assist departments.
- For Type 3 asbestos abatement projects that are internally designed by UofT (i.e., not scoped/designed by an external consultant), departments are required to have a 3rd party consultant review the design and provide feedback in writing. If there are no changes to the internally designed scope, departments must still obtain written confirmation. If your department has not integrated this requirement into your processes, please contact EHS for assistance. A template is also available for assistance.
- For Type 3 asbestos work, the consultant must notify EHS well in advance of air sampling begins. This step is required so that EHS can notify/consult with the relevant Joint Health and Safety Committee (JHSC) before the testing begins (a regulatory requirement). Results are also standardized on an easy-to-read template. If your department has not integrated this requirement into your processes, please contact EHS for assistance. Templates are available: Notice of Hygiene Testing, Ambient air sampling template result for Type 3 asbestos work.
The Asbestos Management Program and associated resources can be located on the EHS website. If you have any questions, please contact your local EHS group or your local facilities management group. On St. George Campus, you can also contact Irfan Miraj (Manager, F&S HCMG) at 946-0101 (email@example.com).