OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 1, 1999

Richard L. Frey
Project Scientist
Professional Service Industries, Inc.
1707 South Cameron Street
Suite B
Harrisburg, Pennsylvania 17104

Dear Mr. Frey:

This is in response to your letter of February 24, 1999 concerning the Occupational Safety and Health Administration's (OSHA's) standards for asbestos. You request clarification of the training that the standards require to be provided for an on-site asbestos consultant providing on-site abatement monitoring services. We apologize for the delay in our response.

If the only management service provided by the on-site asbestos consultant is sampling of airborne asbestos at asbestos abatement projects, then the consultant would need training as specified in the General Industry Asbestos standard at 29 CFR 1910.1001(j)(7). Please note that according to 29 CFR 1926.1101(o)(3)(i) of the construction industry asbestos standard, on all worksites where employees are engaged in Class I or II asbestos work, a competent person designated in accordance with 29 CFR 1926.1101(e)(6) must supervise the employee exposure monitoring, and ensure that it is conducted as required by 29 CFR 1926.1101(f).

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact OSHA's Office of Health Compliance Assistance at (202) 693-2190.

Sincerely,

Richard E. Fairfax
Director
Directorate of Compliance Programs