Asbestos Management

PepsiCo EHS Standard - 16

EHS STANDARD 16
ASBESTOS MANAGEMENT
(Published/Effective: January 2015 [Version 2])

1.0 PRINCIPLES AND PURPOSE

Breathing air containing asbestos fibers can lead to asbestos-related diseases. Asbestos-
containing materials (ACM) have been widely used in production of building materials,
insulation and equipment components. The following list provides examples of potential
ACM:

 Spray coatings on steel work, or concrete walls and ceilings for fire protection and
insulation

 Decorative spray applied surfaces

 Insulation lagging on pipe work, boilers and ducting

 Insulation board for wall partitioning, fire doors and ceiling tiles

 Asbestos cement products (transite) such as sheeting on walls and roofs, gutters,
and pipes

 Floor tile/adhesives

 Roofing materials

Examples of potential asbestos-containing components in equipment may include:

 Gaskets

 Packing

 Friction materials (brakes, clutches)

 Heat resistant textiles

 Special filters

The purpose of this Asbestos Management standard is to define the minimum requirements
for a program to:

1) Prevent occupational exposure to asbestos at Facilities/Selling Operations

2) Ensure proper handling and disposal of any ACM that must be removed from the
PepsiCo facility or equipment
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This program includes inspection of buildings and the review of building equipment for the
presence of ACM or presumed ACM (PACM), and development of procedures to manage ACM
or PACM in place until verified and/or removed.

2.0 APPLICABILITY
This standard applies to all company-owned businesses, company-managed leased facilities
and majority-owned joint venture operations with structures or equipment that may contain
asbestos materials (Facility/Selling Operation or Facilities/Selling Operations).

3.0 RESPONSIBILITIES
3.1. FACILITY/SELLING OPERATION

Conduct a preliminary evaluation (visual inspection) of the facilities and equipment to

determine the location and condition of all materials suspected to contain asbestos, and
document the results of the evaluation in a written report. If the presence of asbestos is
confirmed within the facility or equipment, develop and implement a written AMP that
specifically addresses the risks associated with asbestos-containing materials in accordance
with this standard.

In the case of some very small operations where staffing levels or expertise is not enough
to develop and maintain an effective AMP, the operation must obtain support from BU or
Sector level staff, as necessary, to ensure compliance with this standard.

3.2. BUSINESS UNIT OR SECTOR

Support the Facilities/Selling Operations in conducting the preliminary evaluation and in the
development of their AMPs. As appropriate, provide example AMP documents or prepared
Sector/BU AMP procedures to smaller facilities, to ensure their compliance with this
standard.

3.3. PEPSICO CORPORATE

The PepsiCo Senior Director of Environmental Compliance and Vice President of

Environment, Health and Safety shall update this standard to ensure its continued relevance
to PepsiCo, and for communicating it to all PepsiCo operations. This standard shall be
reviewed and updated, as needed, at least every three years.

4.0 REQUIREMENTS
Each Facility/Selling Operation constructed prior to the PepsiCo Asbestos Management Date
(AMD) for their region or country, must perform a preliminary evaluation (such as, visual
inspection) of the facility and/or equipment to determine whether ACM or PACM are known
or suspected to be present. Facilities constructed after the AMD (date of the beginning of
construction) may use construction date as evidence to assume that the building structure

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does not contain ACM or PACM. Equipment and fixtures (such as, floor coverings) within the
building must be evaluated, regardless of age of building.

The AMD is the date selected by PepsiCo representing the time after which it is deemed
extremely unlikely that ACM was used in the construction of the facility. The AMD varies,
based on the country or region where the facility is located, as follows (all dates are January
1):

 United States and Canada – 1990

 Mexico, Caribbean, Central and South America – 2005

 Western Europe (United Kingdom, France, Germany, Spain, Belgium) – 2000

 Eastern Europe - 2005

 AMEA - 2005

Facilities/Selling Operations constructed prior to the AMD must document in a written report
the results of the preliminary evaluation. The report must include the basis for the
determination and the location(s), amount (area of surface insulation, length and diameter
of pipe insulation, approximate volume of bulk materials, etc.) and condition (for example,
well-maintained or potentially friable or dispersible) of all known or suspected ACM or PACM.

Any locations of known or suspected ACM must be labeled to inform employees of its
presence and to indicate that the material shall not be disturbed until pre-work confirmation
sampling is conducted. In rooms or areas with a high incidence of suspected ACM or PACM
it may be acceptable to post general signage warning of suspected ACM or PACM in the area
or room, rather than on each individual object, subject to local regulatory requirements.

Facilities/Selling Operations with known or suspected ACM must conduct a physical

inspection and sampling, if warranted, (using a qualified a third party contractor) to
determine whether ACM is actually present prior to conducting any work on areas of the
building or equipment where suspected ACM or PACM exist.

Each Facility/Selling Operation that confirms the presence of ACM must then develop and
put into action a written AMP that defines policies and procedures to prevent exposure to
airborne asbestos fibers and complies with applicable regulay standards. The AMP must
address:

 Roles, Responsibilities and Accountabilities

 Qualified Consultant

 Inspection of Facilities and Equipment for Suspect ACM

 Hazard Assessment

 Control Measures

 Accidental Damage to or disrepair of ACM

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 Contractors and Visitors

 Continual Improvement

Small Facilities/Selling Operations, that do not have the staffing levels or expertise to
develop, put into action and maintain an AMP must arrange for staffing support from BU or
Sector representatives to ensure risks associated with ACM are effectively managed in
accordance with this standard and applicable regulatory standards, whichever is more
stringent.

4.1. AMP ROLES, RESPONSIBILITIES AND ACCOUNTABILITIES

Define and document the roles, responsibilities and accountabilities for all personnel who
play a role in implementing the AMP, including:

 Site Management

 EHS Managers

 Facility Planning

 Equipment Procurement

 Engineering and Maintenance

 Competent/Responsible Person

 Employees

 Consultants

 Contractors

 Human Resources

4.2. CONSULTANTS/CONTRACTORS /VISITORS

Consultants/Contractors retained by the Facility/Selling Operation for work related to this

standard shall be recognized and experienced (and licensed, if applicable) in asbestos
identification, bulk material and air sampling, hazard and risk assessment, and design and
management of asbestos abatement procedures.
The services of suitably qualified external consultants/contractors are to be engaged to
conduct inspections, bulk material and air sampling. Where the required expertise is not
available from PepsiCo’s resources, qualified external consultants/contractors may also be
utilized to conduct hazard assessments and training, and in the development of the AMP.
Contractors shall be made aware of and must fully comply with the Facility/Selling
Operation’s AMP.

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The AMP must address necessary communications to visitors, per local regulatory
requirements, as well as areas of the facility from which visitors should be excluded.

4.3. INSPECTION OF FACILITIES AND EQUIPMENT FOR SUSPECTED ACM

Any Facility/Selling Operation constructed prior to the AMD must conduct a preliminary
evaluation (such as, visual inspection) to identify suspected asbestos-containing building
materials and equipment components. This preliminary evaluation must be conducted by a
properly trained and qualified individual (competent person). The evaluation must identify
building materials, insulation and equipment components which, based on previous
common-place usage and materials components, may contain ACM. Until verified otherwise
through actual sampling and analysis, these materials must be considered to be presumed
ACM (PACM).

Prior to any work being conducted on identified PACM at the Facility/Selling Operation, pre-
work bulk sampling of the affected PACM must be conducted, as appropriate, to determine if
asbestos is actually present.

If maintenance, construction or other work is planned on materials that have been

determined to be PACM, bulk samples must be collected by a competent person, from each
type of material to be impacted, prior to conducting any work that may disturb the material.
The collected samples must then be analyzed to determine if asbestos is actually present.
The number of samples collected to determine the presence of asbestos must be
determined by a competent person. The location of all samples taken and the results must
be recorded by the inspector and a copy retained in facility files. All inspection and sampling
MUST be performed by a qualified third party contractor, and samples must be analyzed by
accredited laboratories. Analysis of bulk samples must be by Polarized Light Microscopy.

If ACM are confirmed present, a hazard assessment must then be conducted and a written
Asbestos Management Program must be developed.

Suspect or confirmed ACM building materials and equipment components may remain in
place if they are undamaged, appropriately labeled and unlikely to be disturbed by
maintenance, construction or other activities. However, materials containing asbestos must
be replaced with non-ACM whenever the materials are likely to be disturbed by such
activities. Additionally, all ACM (and PACM) must be visually inspected annually to verify the
condition of the materials.

4.4. CONTROL MEASURES

The AMP must indicate the control measure(s) required for all ACM and/or PACM identified
at the Facility/Selling Operation. Control measures may include the following:

 Permanent labeling of materials as Asbestos Containing or Presumed to be Asbestos

 Containing

 Removal

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 Encapsulation

 Enclosure

 Operations and Maintenance Procedures

The criteria for selecting the control measure must be documented and recorded.

During any removal / remediation activities, the facility must ensure building occupants at a
minimum are not exposed to levels of airborne asbestos fibers exceeding 0.1 fibers per
cubic centimeter (100 fibers per cubic meter) on an eight-hour, time-weighted average
(TWA) or 1.0 fibers per cubic centimeter on a 30-minute TWA. Where more stringent local
regulatory limits exist, those limits must be followed.

Only qualified, experienced (licensed, if applicable) contractors shall be used to conduct

removal, encapsulation or enclosure of ACM. It is generally not permissible for PepsiCo
employees to perform this work. Any exception to this requires prior written approval from
Vice President of Operations for the Sector/BU, as well as PepsiCo Corporate EHS.

Operations and maintenance procedures in the AMP must include procedures for employees,
contractors and other potentially exposed individuals who may work in the vicinity of any
ACM or PACM that remain at/in the Facility/Selling Operation. To facilitate proper
management of ACM or PACM left in place in the building, the following must be included:

 Procedures for conducting regular maintenance, repairs and housekeeping without

damaging the ACM or PACM

 Training of affected employees

 Requirements for labeling or for other means to alert people to the presence or
possible
presence of asbestos

 Asbestos clean-up, removal and disposal procedures

 Records of disposal

4.5. ACCIDENTAL DAMAGE TO, DISREPAIR OF, OR THE NECESSARY DISTURBANCE OF

ACM OR PACM

If ACM or PACM are accidentally damaged, noted to be in disrepair or needing to be

disturbed to immediately respond to a facility or equipment emergency (for example, critical
leak or other material failure) the area should be isolated and unauthorized entry to the
area prevented. A qualified contractor shall be immediately brought in to establish the
required and appropriate controls and monitoring, and affect the removal of the ACM or
PACM. If timing requirements with the emergency do not allow for sampling and
confirmatory asbestos analyses the materials must be handled as if the materials had been
confirmed to be ACM until such time that sampling and analysis of the materials can be
completed. If the material is confirmed to be ACM it must be removed and replaced with
non-ACM using a properly qualified and experienced contractor, as required by local
regulations.

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4.6. CONTINUAL IMPROVEMENT

Each Facility/Selling Operation must implement a process that ensures the continual
improvement of the AMP. This shall include:

 Annual documented review of the written program, including program effectiveness

and the processes, policies and procedures in place to support the program

 Annual inspections of known or suspect ACM to ensure that they are in good
condition and do not present an exposure hazard to building occupants

 Annual review of the appropriate signage to ensure proper location and visibility

 Annual review of the operations and maintenance plan and procedures

 Periodic review of consultant and contractor capabilities to ensure adequacy of

qualifications

 Corrective actions and follow up for any identified program deficiencies or

opportunities for improvement

 Specifications must prohibit the use of ACM in any new construction, as well as in
any new equipment purchased for the facility

 Any process equipment that is asset transferred from another PepsiCo facility must
be evaluated for ACM, prior to installation

 Any ACM in such equipment must be replaced prior to installation

Significant revisions to the AMP should be communicated in a timely manner to affected

parties.

5.0 REPORTING
A mechanism shall be implemented for the accurate notification, labeling and reporting of
the location of ACM and PACM as per local regulatory requirements and PepsiCo minimum
requirements, such as:

 Bulk sampling locations and results

 Location of ACM or suspected ACM

 Activities likely to disturb ACM and result in the release of airborne asbestos fibers

 Asbestos abatement activities and location

An awareness level overview of the AMP shall be included in the standard training for new
and transferred employees.

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6.0 RECORD KEEPING

The following records, at a minimum, must be maintained permanently, unless otherwise
directed in the PepsiCo Records Management Policy Retention Schedule or by regulation:

 Bulk sample results of suspect ACM

 Location and condition of ACM

 Incident reports of accidental or unplanned damage to ACM

 Results of air monitoring conducted during and after asbestos abatement activities

 Personal exposure monitoring results

 Health surveillance records

 Asbestos abatement records

 Training records

7.0 TRAINING
The minimum awareness level training program shall include but is not limited to:

 Health effects of exposure to asbestos

 Basic anatomy and physiology of the lung

 Activities that may damage ACM and result in the release of airborne asbestos fibers

 Purpose and explanation of the Asbestos Management Program

 PepsiCo policies and procedures including enforcement and disciplinary procedures

Refresher training must be developed and provided periodically according to legal

requirements or at appropriate intervals. At a minimum, refresher training must be provided
at least once every three years.

Additionally, PepsiCo employees participating in, or authorizing, any program activities

involving ACM or PACM must receive training such that they acquire the competence,
knowledge (including regulatory requirements) and skills necessary for the safe and

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comprehensive performance of the assigned duties. This includes, but is not limited to, the
following:

 Types of materials that are typically expected to be ACM

 Specific requirements for testing and abatement of ACM

 Assessing the condition of known ACM in the facility

All training prepared and conducted with regard to this Standard shall also conform fully
with PepsiCo EHS Standard 08-Competence, Training, and Awareness and EHS Standard
03–Contractor Management.

8.0 LEGAL AND POLICY FRAMEWORK

 PepsiCo Global Environment, Health and Safety Management System (GEHSMS),
Elements 4, 6, 8

 ISO 14001: 4.3.2 (Legal and Other Requirements); 4.4.6 (Operational Control);
4.5.1 (Monitoring and Measurement)

 OHSAS 18001: 4.3.2 (Legal and Other Requirements); 4.4.6 (Operational Control);
4.5.1 (Performance Measurement and Monitoring)

9.0 REFERENCES
 PepsiCo Global Environmental, Health and Safety Management System (GEHSMS)

 PepsiCo EHS Standard 01-Incident Reporting and Investigation

 PepsiCo EHS Standard 03-Contractor Management

 PepsiCo EHS Standard 08-Competence, Training and Awareness

 PepsiCo EHS Standard 10 – Risk Management

 PepsiCo EHS Standard 15 legal and Other Requirements

 PepsiCo EHS Standard 14 Document Control and Records Management

 PepsiCo Records Management Policy Retention Schedule

10.0 DEFINITIONS
Refer to the PepsiCo EHS Glossary (Document Control module).

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11.0 EVALUATION AND HISTORY

Refer to the MyEHS Document Control module.

12.0 MYEHS IMPLEMENTATION

Refer to the relevant mapping document for MyEHS modules that support this standard.
Implementation of the modules, by selling operations, must be completed by the next
review date of this standard.

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