Asbestos bulk sampling of composite building materials

February 7, 1997

MEMORANDUM FOR: GERARD RYAN
ASSISTANT REGIONAL ADMINISTRATOR
FOR TECHNICAL SUPPORT REGION VIII

FROM: STEPHEN MALLINGER, ACTING DIRECTOR
OFFICE OF HEALTH COMPLIANCE ASSISTANCE

SUBJECT: Compliance with OSHA's Asbestos Standard - Composite
Bulk Samples

This is in response to your memorandum of November 5, 1996. The issues discussed are OSHA's presumptive rule, the definition of Presumed Asbestos Containing Material (PACM), and bulk sampling techniques under OSHA's Asbestos Standard (29 CFR 1926.1101).

As you are aware, building owners are responsible for locating the presence and quantity of PACM in buildings built before 1981. Technically this process does not require any special training since PACM is easily recognized. To clarify that point a closer look at the definition of PACM is necessary. PACM is thermal system insulation (TSI, such as pipe-wrap or duct insulation) and sprayed-on and troweled-on surfacing material (such as fireproofing material or acoustical material). OSHA limited the list to those asbestos-containing building materials that were installed most frequently and may present the greatest exposure hazard when the materials are disturbed.

The employer can rebut the designation of installed material as PACM by either having an inspection in accordance with AHERA or hiring an accredited inspector or a Certified Industrial Hygienist (CIH) to take bulk samples. This section of the standard, which is the only section that requires bulk sampling, does not include wallboard systems. PACM materials, specifically TSI and sprayed-on and troweled-on surfacing material are not typically multi-layered, unlike wallboard systems. Therefore, the issues you raised regarding multi-layered/composite testing do not pose a problem, nor are they in conflict with the EPA.

The important point to note is that wallboard and wallboard systems are not covered by the presumptive rule. Gaskets, siding, or roofing are likewise not covered. The example you provided in your memorandum describes the disparity between OSHA, AHERA and NESHAPS in the way wallboard systems are analyzed. First recall that building owners do not have to identify asbestos-containing wallboard systems under the presumptive rule. Other building materials such as wallboard and wallboard systems may contain asbestos but unless an employer has specific knowledge or should have known through the exercise of due diligence that these other materials contain asbestos, the standard does not compel the building owner to sample these materials.

Recall however, that the removal of wallboard systems that contain asbestos is covered by the standard as a Class II operation and the employer needs to comply with the appropriate sections of the standard. Class II operations require that the employer conduct only personal sampling, not bulk sampling. Any bulk sampling an employer performs, such as composite sampling on multilayered systems, is beyond what is required by the OSHA standard. Please bear in mind that during OSHA compliance activities it continues to remain OSHA's policy that single layer sampling is required for multilayered materials such as wallboard. When a compliance officer (CSHO) investigates a complaint alleging asbestos exposure during a renovation project where wallboards are being removed for example, any bulk samples taken by the CSHO would consists of the separate components of the wallboard. This sampling technique would accurately reveal the percentage of all parts of the wallboard system.

We hope you have found this information useful. If you have additional questions please contact [the Office of Health Enforcement at (202) 693-2190].

[Regional request memorandum and its attachments reproduced on OSHA page; omitted here.]