Standard Interpretations - Table of Contents|
| Standard Number:||1926.1101|
December 4, 1995
Kenneth H. Mueller, Esq.
Greentree Consulting Incorporated
163 Stockton Street
Highstown, New Jersey 08520
Dear Mr. Mueller:
This is to confirm your phone conversation on October 20, with Doug Ray of my staff, that your interpretation (letter of June 12th) of 1926.1101(f)(2)(iii)(B) of the asbestos standard is correct. More specifically, per your conversation with Doug Ray, a negative exposure assessment has been established when the workplace conditions "closely resemble" the process, type of material, control methods, work practices, environmental conditions, and employee training of an asbestos job monitored within the past 12 months. Documentation should address the above 6 areas for a negative exposure assessment, and should be available at each new worksite.
We apologize for the delay in responding to your letter of June 12, and any inconvenience it may have caused.
Ruth McCully, Director
Office of Health Compliance
June 12, 1995
Mr. John Miles
Director of Compliance Programs
200 Constitution Avenue, N.W.
Washington, DC 20210
RE: Request for written OSHA Interpretation on Use of Asbestos Air Monitoring Data from a Prior Job to Establish a "Negative Exposure Assessment" for a Projected Job: 29 CFR 1926.1101(f)(2)(iii)(B)
Dear Mr. Miles:
In researching the OSHA Asbestos Exposure Assessment and Monitoring Regulation 29 CFR 1926.1101(f)(2)(iii)(B), the need has arisen for a written interpretation from OSHA on the use of asbestos air monitoring data from a prior job to establish a "Negative Exposure Assessment" for a projected job in a different geographic region (i.e. state). For purposes of clearly explaining this issue, the following illustration is presented.