Separate asbestos analysis of sheetrock and joint compound

April 28, 1997
Mr. Gary Thibodeaux
National Service Cleaning Corp.
[Recipient address omitted]
Dear Mr. Thibodeaux:
This is in response to your letter of March 31, concerning sheetrock and joint compound.
You ask whether the Occupational Safety and Health Administration (OSHA) considers sheetrock and joint compound to be a composite material that may be analyzed for asbestos content by collecting composite bulk samples. By interpretation of the definition of asbestos containing material (ACM) presented at 29 CFR 1910.1001(b), [29 CFR 1915.1001], and 29 CFR 1926.1101(b); OSHA regards sheetrock and joint compound as separate materials. Each of these materials that may contain asbestos must be analyzed separately for their asbestos content.
You also asked what class of asbestos work would be involved if the only material containing greater than 1% asbestos is joint compound. We presume you are referring to the removal of interior wall shells constructed with sheetrock panels. If that is the case, the removal operation is Class II asbestos work. OSHA does not consider joint compound to be surfacing material. As indicated on page 41032 of Federal Register, Vol. 59, No. 153, Wednesday, August 10, 1994, joint compound is finishing material. Note that if surfacing material containing more than 1% asbestos was applied to the sheetrock panels, removal of the panels would be considered Class I asbestos work.
We appreciate the opportunity to provide this clarifying information. If you have further questions please contact the [Office of Health Enforcement at (202) 693-2190].
Sincerely,
Stephen Mallinger, Acting Director
[Office of Health Enforcement]
[Corrected 6/2/2005]

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