Asbestos competent-person training for roofing work

April 2, 1996

John Curran, Manager
Health Hazard Control Branch
North Carolina Department
of Environmental, Health
and Natural Resources
[Recipient address omitted]
Dear Mr. Curran:

Thank you for your letter of November 30, 1995, regarding the training requirements of the competent person for class II roofing work as addressed in the asbestos standard for the Construction Industry (29 CFR 1926.1101)

You asked whether the competent person for Class II roofing work must always attend a 5-day asbestos supervisory course?

For competent persons supervising roofing jobs limited to the removal of intact material, OSHA considers the employer to be in compliance with 1926.1101(o)(4) (competent person training) when a comprehensive course for the roofing trade has been conducted by an Environmental Protection Agency (EPA) or a state-approved trainer, certified by the EPA or a state, regardless of the number of training days.

For competent persons supervising roofing jobs involving non-intact material, OSHA requires that the competent person to receive training in a comprehensive course for supervisors that meets the criteria of EPA's Model Accreditation Plan (40 CFR part 763) or a course equivalent in stringency, content, and length.

We are enclosing pages D-22 and D-23 of our compliance directive that describes the training requirements for intact roofing jobs. Also enclosed from our compliance directive are pages D-24 through D-26 that describe intact and non-intact removals.

It should be noted that the North Carolina Department of Labor is operating its own occupational safety and health program under a plan approved and closely monitored by federal OSHA and is primarily responsible for enforcement of the OSHA asbestos standard in North Carolina. The North Carolina Occupational Safety and Health Program generally adopts identical standards and interpretations, but we urge you to coordinate your effort with them. Their address is as follows:

Mr. Charles N. Jeffress
Deputy Commissioner
North Carolina Department of Labor
319 Chapanoke Road
Raleigh, NC 27603-3432
Telephone: 919 662-4585

We hope this information has been helpful in answering your question. Thank you for your interest in worker safety and health.

Sincerely,
Ruth McCully, Director
Office of Health Compliance

Enclosures

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