Asbestos competent-person course for Class II roofing

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

February 29, 1996

William A. Good, CAE
Executive Vice President
National Roofing Contractors
Association
[Recipient address omitted]
Dear Mr. Good:

Thank you for your letter of August 21, 1995, regarding the training requirements of the competent person for class II roofing work as addressed in the Occupational Safety and Health Administration's (OSHA's) asbestos standard for the construction industry (29 CFR 1926.1101). We regret the delay in this response.

Your concerns appear to be that neither the clarifications (Federal Register June 29, 1995) to the asbestos standard, nor the roofing settlement agreement of March 15, 1995, addressed specific training requirements for the competent person related to the roofing trade. Also you indicate that the current 5-day training requirement for class II work is not specific to the roofing trade; therefore, the information is generally not useful to that person receiving the training.

The standard, as well as the settlement agreement, provides an exception to the 5-day training requirement when the roofing material being removed is intact (section (g)(11) of the standard). All other roofing work would require the competent person to have the 5-day training course. The training is to be provided by an EPA or a state approved training provider.

We hope this information has been helpful in answering your question.

Sincerely,
John B. Miles, Jr., Director
Directorate of Compliance Programs

[Requester letter reproduced on OSHA page; omitted here.]