Class III asbestos work during inspections and bulk sampling

April 28, 1997

Mr. Clifford Frey
Project Scientist
Malcolm Pirnie, Inc.
[Recipient address omitted]
Dear Mr. Frey:

This is in response to your letter of December 30, 1996, that was addressed to the Office of Health Compliance of the Occupational Safety and Health Administration (OSHA). We apologize for the delay in providing you a response. Your questions concern the classification of asbestos work for employees performing asbestos inspections and obtaining bulk samples. Your second question asks, is Class III training required for asbestos inspectors if they have already received the EPA approved asbestos inspector training?

Bulk sampling for asbestos is a Class III operation as defined by the asbestos standard in construction, 29 CFR 1926.1101. It is a disturbance that entails activities that disrupt the matrix of asbestos-containing material (ACM), or presumed asbestos containing material (PACM). The employee performing the task of collecting bulk samples shall conduct the work in accordance with the work practices and engineering controls as required in paragraphs (g)(9)(i)-(v) of the standard. In summary, these paragraphs require the use of wet methods, local exhaust ventilation where feasible, dropcloths or barriers, and the use of a respirator. Once a negative exposure assessment has been determined, the use of barriers and respirators can be discontinued. These requirements are commonly practiced and easily accomplished. Professional asbestos inspectors, consultants, industrial hygienist and assistants observed taking precautions, serve as a good role model as well as protecting their own health.

The second issue is the question of training. You ask if an individual who received the Environmental Protection Agency (EPA) approved asbestos inspector training is required to take the training required of workers performing Class III work. Be advised that additional training is not required. It is reasoned that a higher level of training such as you describe would indicate an individual is competent in asbestos operations.

Thank you for your interest in safety and health. If you have further questions, please feel free to contact [the Office of Health Enforcement at (202) 693-2190].

Sincerely,
Stephen Mallinger, Acting Director
Office of Health Compliance Assistance

[Corrected 12/6/2024]

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