Standard Interpretations - Table of Contents
• Standard Number: 1926.1101

April 28, 1997

Mr. Clifford Frey
Project Scientist
Malcolm Pirnie, Inc.
104 Corporate Park Drive
Box 751
White Plains, New York 10602-0751

Dear Mr. Frey:

This is in response to your letter of December 30, 1996, that was addressed to the Office of Health Compliance of the Occupational Safety and Health Administration (OSHA). We apologize for the delay in providing you a response. Your questions concern the classification of asbestos work for employees performing asbestos inspections and obtaining bulk samples. Your second question asks, is Class III training required for asbestos inspectors if they have already received the EPA approved asbestos inspector training?

Bulk sampling for asbestos is a Class III operation as defined by the asbestos standard in construction, 29 CFR 1926.1101. It is a disturbance that entails activities that disrupt the matrix of asbestos-containing material (ACM), or presumed asbestos containing material (PACM). The employee performing the task of collecting bulk samples shall conduct the work in accordance with the work practices and engineering controls as required in paragraphs (g)(9)(i)-(v) of the standard. In summary, these paragraphs require the use of wet methods, local exhaust ventilation where feasible, dropcloths or barriers, and the use of a respirator. Once a negative exposure assessment has been determined, the use of barriers and respirators can be discontinued. These requirements are commonly practiced and easily accomplished. Professional asbestos inspectors, consultants, industrial hygienist and assistants observed taking precautions, serve as a good role model as well as protecting their own health.

The second issue is the question of training. You ask if an individual