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Power roof cutters and asbestos roofing supervisor training

Summary OSHA said use of a power roof cutter separates built-up roofing into pieces, but pieces can remain intact if the material stays bound in its matrix. It said the described operation required five-day EPA model supervisor training or an equivalent course. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-07-15-1
Date issued
July 15, 1996
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1926 Asbestos Training
Source
View the official document

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 15, 1996

Mary T. Giguere, CIH
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Epidemiology
[Recipient address omitted]
Dear Ms. Giguere:

Thank you for your letter of June 8, regarding the use of a power roof cutter on a built-up roof. More specifically, you asked does the use of a powered roof cutter constitute non-intact work; therefore, requiring the supervisory five-day class.

Corrections to the final rule (Federal Register, Volume 60, Number 125, June 29, 1995) on page 33979 addressed the issue of a powered roof cutter. Those worksites where powered roof cutters are used on built-up roofs has been deemed to be non-intact operations, solely because the roofing material has been separated into pieces. However, the pieces of the roof may be considered intact if they have not been crumbled, pulverized or otherwise deteriorated to the point that the material is no longer bound to the matrix. A copy of page 33979 of the Federal Register is being provided for your information.

The training requirement for the supervisor of the power roof cutting operation would be, as you stated in your letter, the five day EPA Model Accreditation Plan (40 CFR part 763) or a course equivalent in stringency, content, and length.

If you should have any additional questions regarding this matter please contact us at (202) 219-8036.

Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

Enclosure

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

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