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Asbestos-containing paint removal work classes

Summary OSHA says removal of asbestos-containing paint of ordinary film thickness is Class II asbestos work. Thick, textured paint that resembles troweled or sprayed surfacing material is Class I work.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-08-26
Date issued
August 26, 1996
Status
Active
Status last verified October 9, 2026

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

August 26, 1996

Mr. Edward M. Monaco, President
Karl R. Rohrer Associates, Inc
[Recipient address omitted]
Dear Mr. Monaco:

This is in response to your letter dated July 16, 1996, to William Q. Wiehrdt in the Occupational Safety and Health Administration's (OSHA) Chicago Regional Office requesting clarification of OSHA's Asbestos standard (29 CFR 1926.1101) for the construction industry. You requested that OSHA specify the class of asbestos work (Class I, II, III, or IV) to which the removal of asbestos-containing paint would belong.

The removal of asbestos-containing paint of ordinary film thickness is Class II asbestos work. The removal of thick-film, textured, asbestos-containing paint would be Class I work if the material resembles troweled or sprayed on surfacing material.

We appreciate the opportunity to clarify this matter for you. If you have further questions please contact [the Office of Health Enforcement at (202) 693-2190].

Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

[Corrected 12/6/2024]

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