Module 5: Safe Working Practices for Data Center Cleaning

Learning Objectives

By the end of this module, learners will be able to:

• Identify and apply safe work practices to avoid disturbing asbestos-containing materials

• Follow correct emergency procedures if asbestos is discovered or accidentally disturbed

• Understand and implement proper waste handling and disposal protocols

• Recognize the core practical skills for cleaners—what to do and what not to do in a data center environment

5.1 Introduction: The Foundation of Safe Work Practices

Why Safe Working Practices Are Critical

Asbestos fibers are only released into the air when asbestos-containing materials (ACMs) are disturbed, damaged, or deteriorate over time. Intact and undisturbed asbestos materials do not pose a significant health risk. However, data center cleaning activities—from vacuuming floors to lifting ceiling tiles for cable access—can inadvertently disturb ACMs if staff are not properly trained and equipped.

The core principle of safe working practices is simple: prevent disturbance through awareness, planning, and proper techniques.

The Three Pillars of Safe Work

5.2 Avoiding Disturbance: Proactive Measures

Pre-Work Preparation

Before any cleaning or maintenance work begins in a data center, the employer must establish if asbestos is likely to be disturbed during the work. This involves:

1. Reviewing the Asbestos Register: The building's asbestos register or survey must be checked to confirm the location and condition of ACMs.

2. Pre-Work Approval: If accidental disturbance is possible, pre-work approval from the Asbestos Program Manager is required.

3. Risk Assessment: Any work that may disturb asbestos must be risk assessed, planned, and completed by appropriately trained and competent workers.

The Likelihood of Disturbance Framework

EPA guidance classifies maintenance activities based on the likelihood of disturbing ACMs:

What NOT to Do: Prohibited Practices

NEVER use the following methods when cleaning in areas where asbestos may be present:

• Dry sweeping or dusting: This re-suspends asbestos fibers into the air

• Using compressed air: Compressed air blasts fibers into the air, contaminating the entire area

• Using regular vacuums: Standard vacuums do not capture asbestos fibers; they exhaust them back into the air

• High-pressure water spray: This can destroy the binding matrix of ACMs and spread contamination

What TO Do: Safe Cleaning Techniques

HEPA Vacuuming
Only HEPA-filtered vacuum equipment must be used for vacuuming. The equipment must be used and emptied in a manner that minimizes the reentry of asbestos into the workplace. HEPA vacuums capture 99.97% of particles down to 0.3 micrometers in size.

Wet Methods
Use wet methods (e.g., damp cloths, water sprays) to suppress dust when handling or cleaning areas where asbestos may be present. Water prevents fibers from becoming airborne.

Wet Wiping
Surfaces should be cleaned by wet wiping, followed by HEPA vacuuming. Records of cleaning activities—including name, location, date, and time—should be documented for recordkeeping.

5.3 Emergency Procedures: What to Do If You Discover or Disturb Asbestos

Discovery vs. Disturbance

Discovery: You find material you suspect may contain asbestos but have not disturbed it.
Disturbance: You have accidentally damaged, broken, or released fibers from ACM.

Both situations require immediate action, but the response for disturbance is more urgent.

If You Discover Suspect Material

1. Stop work immediately

2. Do not touch or disturb the material

3. Speak to your employer or the building owner to find out if asbestos is documented in the asbestos register

4. If the material is not in the register, report it to your supervisor immediately

If You Accidentally Disturb Asbestos

Immediate Actions - STOP, EVACUATE, REPORT

If asbestos is disturbed during your work, it must be dealt with quickly and appropriately. Follow these steps in order:

Step 1: Stop Work Immediately

Stop all activities in the area. Do not continue working or try to clean up the material yourself.

Step 2: Evacuate the Area

Immediately vacate the room or area and restrict access using signage and barrier tape.

Step 3: Report the Incident

Issue an emergency report to the Asbestos Coordinator or supervisor. Outside of normal business hours, call the designated emergency contact or building security.

Step 4: Do NOT Attempt Cleanup

Do not attempt to clean up the ACM unless you are a licensed asbestos abatement contractor. Cleanup of an incidental disturbance must be conducted by a licensed asbestos abatement contractor, with oversight from an environmental consultant.

Emergency Asbestos Kit

Some sites maintain an "Emergency Disturbance of Asbestos Kit" to help operatives respond to accidental disturbance. A typical kit contains:

• FFP3 dust masks

• Industrial wet wipes (wet rags)

• Waste bags and tape (for potentially contaminated clothing)

• Type 5 coveralls

• Laminated instructions for personal decontamination

• Lists of client-specific contact numbers for help with internal procedures

This kit is designed to help operatives minimize exposure and prevent the spread of asbestos during an unexpected disturbance.

Major vs. Minor Fiber Releases

Major Fiber Release (more than 3 square or linear feet of ACM affected):

• Isolate the area by closing doors and erecting temporary barriers

• Post signs immediately outside the release site

• If asbestos fibers could enter the HVAC system, shut down and seal off the system

• Engage licensed asbestos abatement contractors

• Conduct thorough cleanup with final clearance air monitoring

Minor Fiber Release (3 square or linear feet or less):

• HEPA vacuuming and wet wiping

• Proper waste containment in labeled, leak-tight containers (e.g., 6-mil thick plastic bags)

• Worker protection procedures must still be followed

5.4 Waste Handling and Disposal Protocols

The Importance of Proper Waste Disposal

Asbestos waste is classified as hazardous waste and must be managed with extreme care. Improper disposal can lead to worker exposure, environmental contamination, and significant legal penalties. In Virginia, all asbestos-containing waste materials must be disposed of in a special purpose landfill or a designated area of a sanitary landfill. Additionally, owners must record a notation on the deed to the property in perpetuity notifying future purchasers that the property has been used for asbestos disposal.

Waste Containment Procedures

Packaging Requirements

Step-by-Step Waste Packaging Process

1. Place waste materials in an impermeable container (at least 6-mil thick plastic bag) within the contained asbestos work area

2. Seal the container and label it "ASBESTOS"

3. Double-bag the waste

4. Before removing sealed containers from the work area, decontaminate the exterior of each container by wet wiping or HEPA vacuuming

5. Package sealed impermeable containers to prevent puncturing during handling and transport—this is typically achieved by double-bagging

What NOT to Do with Asbestos Waste

• DO NOT dispose of asbestos waste in general waste, recyclables, or green waste bins

• DO NOT drag or slide bags across rough or abrasive surfaces (this can puncture bags and release fibers)

• DO NOT use regular trash compactors for asbestos waste

• DO NOT allow waste to remain unsealed or unlabeled

Transport and Final Disposal

• Asbestos waste must be transported to a landfill authorized to receive it

• Contact the landfill before transport to confirm acceptance procedures

• Licensed asbestos removalists should handle waste transport where possible

• Recordkeeping is essential—waste records must be maintained to document proper disposal

Waste Storage on Site

Strict rules apply to storing asbestos waste. If waste must be stored temporarily on site:

• Store in a secure, contained area with restricted access

• Ensure all waste remains double-bagged and sealed

• Label storage areas with asbestos warning signs

• Remove waste to an authorized landfill as soon as possible

5.5 Practical Considerations for Data Center Cleaners

Risk Assessment Before Starting Work

Before beginning any cleaning work in a data center, cleaners should:

1. Check the asbestos register for the building

2. Identify ACMs in the work area from the register

3. Plan work to avoid disturbing these materials

4. Use appropriate equipment (HEPA vacuums, wet cleaning supplies)

5. Wear appropriate PPE as required by the risk assessment

6. Know the emergency procedure for the specific site

Recordkeeping Requirements

Proper recordkeeping is essential for asbestos safety programs. Records should document:

• Location, date, and time of cleaning activities

• Employee training records (maintained for one year beyond last employment date)

• Employee exposure-monitoring records

• Medical surveillance records

• All data demonstrating that suspect materials do not contain asbestos

• All records of abatement projects and O&M activities

These records should be included within the Asbestos Management Plan (AMP) for the facility.

What to Do When Moving Between Data Centers

Data center cleaning personnel often work in multiple facilities. Each site may have different procedures, ACM locations, and emergency contacts. To avoid confusion:

• Attend site-specific inductions for each data center

• Review the asbestos register for each new site before starting work

• Know the emergency contact numbers for each site

• Carry an emergency asbestos kit or ensure one is available on site

5.6 Key Takeaways for Data Center Cleaning Personnel

Summary of DOs

Summary of DON'Ts

5.7 Emergency Action Card

If you discover suspect material:

1. STOP

2. DO NOT TOUCH

3. REPORT to supervisor

If you accidentally disturb asbestos:

1. STOP work immediately

2. EVACUATE the area

3. RESTRICT access (signage/barrier tape)

4. REPORT to supervisor/asbestos coordinator

5. DO NOT attempt cleanup