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OSHA 1910.1001

Asbestos scope and application

Subpart Z

50 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.1001(a), does the OSHA asbestos standard for general industry apply to construction work?

No — under 1910.1001(a) the general industry asbestos standard does not apply to construction work. See 1910.1001(a)(2), which expressly excludes construction work and refers to the construction asbestos standard at 29 CFR 1926.1101. OSHA has also clarified that remediation activities involving asbestos-containing building materials are generally covered by the construction standard even when performed by companies that are not traditional construction contractors — see the OSHA letter, Asbestos remediation protocols.

Under 1910.1001(a), does the general industry asbestos standard cover ship repairing, shipbuilding and shipbreaking work?

No — the general industry asbestos standard excludes ship repairing, shipbuilding, and shipbreaking employments. See 1910.1001(a)(3), which states those shipyard activities are covered instead by the shipyard asbestos standard at 29 CFR 1915.1001 and the shipyard definitions in 29 CFR 1915.4.

Under 1910.1001(b), what is 'asbestos-containing material (ACM)' and how is it defined for compliance purposes?

Asbestos-containing material (ACM) is any material that contains more than 1% asbestos. See the definition in 1910.1001(b).

  • Practically, that means materials must be treated as ACM when testing shows asbestos content over 1% or when you otherwise know that threshold is exceeded.
  • For many compliance duties under this standard (monitoring, regulated areas, controls), materials meeting this definition trigger the standard's requirements.

Under 1910.1001(b) and 1910.1001(j)(8), what is 'presumed asbestos-containing material (PACM)' and can that presumption be rebutted?

PACM is thermal system insulation and surfacing material found in buildings constructed no later than 1980, and yes, the PACM designation may be rebutted. See the PACM definition in 1910.1001(b) and the provision that allows rebuttal under 1910.1001(j)(8).

  • To rebut PACM, employers must follow the procedures and record requirements described in paragraph (j)(8) of the standard — see the cited paragraph for details on acceptable testing and documentation.

Under 1910.1001(c)(1), what is the permissible exposure limit (PEL) time-weighted average (TWA) for asbestos?

The TWA PEL for asbestos is 0.1 fiber per cubic centimeter of air as an 8-hour TWA. See 1910.1001(c)(1).

  • Employers must ensure employee exposures do not exceed this limit as determined by the sampling method in Appendix A or an equivalent method.

Under 1910.1001, what is the asbestos short-term excursion limit and how is it measured?

The asbestos short-term excursion limit is 1.0 fiber per cubic centimeter of air averaged over a 30-minute sampling period. See the excursion limit requirement in 1910.1001 and the 30-minute averaging language in the standard's exposure sections (see 1910.1001(d)).

  • Employers must use the methods in Appendix A or an equivalent method to determine compliance.

Under 1910.1001(d)(1), where must air samples be taken to determine employee asbestos exposure?

Air samples must be taken from the employee's breathing zone and be representative of the employee's 8-hour TWA and 30-minute short-term exposures. See 1910.1001(d)(1)(i) and 1910.1001(d)(1)(ii).

  • Representative full-shift samples are required for each shift, job classification and work area; representative 30-minute samples are required for operations likely to exceed the excursion limit.

Under 1910.1001(d)(2), when is an employer required to perform initial asbestos monitoring and when may they rely on prior monitoring or objective data?

Employers must perform initial monitoring of employees who are or may reasonably be expected to be exposed at or above the TWA and/or excursion limit, except where they can rely on qualifying prior monitoring or objective data. See 1910.1001(d)(2)(i), the allowance to use monitoring performed after March 31, 1992 in 1910.1001(d)(2)(ii), and the objective-data exception in 1910.1001(d)(2)(iii).

  • If prior monitoring meets all the standard's requirements, the employer may rely on it instead of re-testing.
  • If objective data show asbestos cannot be released at or above the PELs under expected conditions, initial monitoring may not be required.

Under 1910.1001(d)(3)–(d)(5), how often must employers perform periodic monitoring and when can monitoring be discontinued or must be resumed?

After initial monitoring, employers must continue periodic monitoring at a frequency and pattern that accurately represent employee exposures; monitoring may be discontinued for employees whose representative monitoring shows exposures below the limits, but must be reinstated if changes or reasons to suspect increased exposures occur. See 1910.1001(d)(3), 1910.1001(d)(4), and 1910.1001(d)(5).

  • If monitoring statistically indicates exposures are below the PEL and excursion limit, monitoring may be discontinued for those employees.
  • Any change in production, process, controls, personnel, or work practices that could increase exposure requires the employer to institute monitoring again.

Under 1910.1001(d)(3), what is the maximum interval between periodic asbestos exposure samples for employees who may reasonably be expected to exceed the PEL or excursion limit?

Sampling intervals for employees who may reasonably be expected to exceed the PEL or excursion limit must not be greater than six months. See the sampling-interval requirement in 1910.1001(d)(3).

  • This is a minimum monitoring frequency for higher-risk employees; more frequent monitoring may be required to accurately represent exposures.

Under 1910.1001(d)(6), what monitoring methods must employers use to analyze asbestos samples and what are the requirements for equivalent methods and laboratories?

Employers must use the OSHA Reference Method (ORM) in Appendix A or an equivalent counting method that meets strict equivalency criteria, and must use laboratories with quality assurance programs as prescribed in Appendix A. See 1910.1001(d)(6)(ii), the equivalency criteria in 1910.1001(d)(6)(iii) (including subsections (A), (B) and (C)), and the laboratory QA program requirement in 1910.1001(d)(6)(iv).

  • Equivalent methods must be validated by side-by-side field and lab comparisons and meet the specified accuracy criteria.
  • Laboratories used for compliance must have a documented quality assurance program that satisfies Appendix A.

Under 1910.1001(d)(7), when and how must employers notify employees of asbestos monitoring results, and what must the notification include if limits were exceeded?

Employers must notify affected employees of monitoring results within 15 working days after receiving the results, either individually in writing or by posting the results in an accessible location; if the results show the TWA or excursion limit was exceeded, the notice must describe the corrective actions being taken. See 1910.1001(d)(7)(i) and 1910.1001(d)(7)(ii).

  • Keep records of the notifications and the corrective actions so you can demonstrate compliance.

Under 1910.1001(e), when must an employer establish a regulated area for asbestos, and what restrictions apply inside regulated areas?

An employer must establish a regulated area wherever airborne concentrations of asbestos or PACM exceed the TWA and/or excursion limit, and access must be limited to authorized persons, with respirators provided and rules prohibiting eating, drinking, smoking, chewing tobacco or gum, or applying cosmetics. See 1910.1001(e)(1) for establishment, 1910.1001(e)(2) for demarcation, 1910.1001(e)(3) for access limits, 1910.1001(e)(4) for respirator provision (see also 1910.1001(g)(2)), and 1910.1001(e)(5) for prohibited activities.

  • Regulated areas must be clearly demarcated to minimize the number of people exposed.

Under 1910.1001(f)(1)(i), what are employers required to do first to reduce employee asbestos exposures?

Employers are required to institute engineering controls and work practices to reduce and maintain employee asbestos exposures at or below the TWA and excursion limits, unless those controls are not feasible. See 1910.1001(f)(1)(i).

  • This means employers must evaluate and implement feasible ventilation, local exhaust, containment, and safe work practices before relying on personal protective equipment alone.

Under 1910.1001(b), how does OSHA define 'fiber' and 'HEPA filter' for asbestos monitoring and controls?

OSHA defines a 'fiber' as an asbestos particulate 5 micrometers or longer with a length-to-diameter ratio of at least 3:1, and a 'HEPA filter' as a filter capable of trapping at least 99.97% of 0.3 micrometer diameter mono-disperse particles. See the definitions in 1910.1001(b).

  • These definitions are important for counting fibers during monitoring and for specifying filtration for respirators and engineering controls.

Under 1910.1001(b), who is considered a 'building/facility owner' for recordkeeping and control responsibilities?

A 'building/facility owner' is the legal entity, including a lessee, which exercises control over management and record keeping functions relating to a building or facility where activities covered by this standard take place. See the definition in 1910.1001(b).

  • This designation matters because owners often have responsibilities for maintaining asbestos records and ensuring contractors follow required asbestos procedures.

For property remediation companies doing fire or water damage clean-up, which asbestos standard usually applies: general industry 1910.1001 or construction 1926.1101?

Remediation work involving asbestos-containing building materials (ACBM), including many property remediation activities after fires or water damage, is typically covered by the construction asbestos standard, [29 CFR 1926.1101]. OSHA has explicitly said that such remediation activities are covered by the construction standard even when performed by remediation companies rather than traditional construction firms — see OSHA's letter Asbestos remediation protocols and note the exclusion for construction in 1910.1001(a)(2).

  • Employers performing demolition, removal, or cleanup of ACBM should follow 1926.1101 requirements (training, controls, notifications) rather than relying on the general industry standard.

Under 1910.1001(b), which building materials are considered PACM in buildings constructed no later than 1980?

Thermal system insulation (TSI) and surfacing material found in buildings constructed no later than 1980 are considered presumed asbestos-containing material (PACM). See the PACM definition in 1910.1001(b).

  • Employers should treat these materials as ACM until they have been properly tested and, if appropriate, rebutted according to 1910.1001(j)(8).

Under 1910.1001(d)(2)(iii), can an employer skip initial monitoring by relying on objective data, and what does that mean?

Yes — an employer may avoid initial monitoring if objective data demonstrate that asbestos cannot be released in airborne concentrations at or above the TWA and/or excursion limit under the expected conditions of processing, use, or handling. See 1910.1001(d)(2)(iii).

  • 'Objective data' can include scientific studies, product safety data, prior industrial hygiene data, or other reasonably relied-upon information showing no significant airborne release is expected.
  • Employers relying on objective data should document the basis and retain records supporting the determination.

Under 1910.1001(d)(2)(ii), may an employer rely on monitoring conducted before hiring or acquisition if that monitoring was done after March 31, 1992?

Yes — an employer may rely on prior monitoring results conducted after March 31, 1992, provided those earlier monitoring results satisfy all other requirements of the standard. See 1910.1001(d)(2)(ii).

  • The earlier monitoring must have been performed and documented in accordance with the standard's sampling, analysis, and representativeness requirements to be acceptable.

Under 1910.1001(f)(1)(iv), what must employers do when they use local exhaust ventilation for asbestos work?

Yes — employers must design, install, construct, and maintain local exhaust ventilation and dust collection systems according to recognized good practices. For asbestos operations, the employer must follow the requirements in 1910.1001(f)(1)(iv), which explicitly direct systems to be consistent with standards such as ANSI Z9.2-1979.

  • Ensure systems are properly designed and maintained so they effectively capture airborne asbestos fibers at the source.
  • Inspect and repair ventilation and dust collection equipment regularly so capture efficiency is not degraded.

Cited: 1910.1001(f)(1)(iv).

Under 1910.1001(f)(1)(v), do hand tools and power tools that generate asbestos fibers need local exhaust ventilation?

Yes — all hand-operated and power-operated tools that would produce or release asbestos fibers must be provided with local exhaust ventilation that complies with the ventilation design requirements. The standard states this requirement in 1910.1001(f)(1)(v) and cross-references the design and maintenance expectations in 1910.1001(f)(1)(iv).

  • Examples include saws, drills, abrasive wheels, and scorers.
  • Ensure HEPA-equipped capture or equivalent local exhaust to prevent exposures above the PEL.

Under 1910.1001(f)(1)(vi), when must employers use wet methods for asbestos work?

Use wet methods whenever practicable to prevent airborne fiber release. The standard requires that asbestos be handled, cut, mixed, removed, or otherwise worked "in a wet state sufficient to prevent the emission of airborne fibers" insofar as practicable, as set out in 1910.1001(f)(1)(vi).

  • Wet methods are a first-line work practice to control fiber release unless the wetting would make the product useless.
  • If wet methods cannot be used, employers must rely on other controls (local exhaust, respirators) to keep exposures at or below the PEL.

Under 1910.1001(f)(1)(viii), how must asbestos-containing powdered or packaged products be handled when removed from shipping containers?

You must prevent fiber release by wetting, enclosing, or ventilating the material before removing it from bags, cartons, or containers. The rule requires this control in 1910.1001(f)(1)(viii).

  • Options are to wet the material, open containers inside an enclosure, or use local exhaust that effectively prevents airborne fibers.
  • This requirement applies to materials like asbestos cement, mortar, coatings, grouts, and plasters.

Under 1910.1001(f)(1)(ix), is compressed air allowed to clean asbestos dust?

Not by itself — compressed air must not be used to remove asbestos unless it is used together with a ventilation system that effectively captures the dust cloud. The prohibition and exception are stated in 1910.1001(f)(1)(ix).

  • Do not use compressed air to blow asbestos dust into the workplace air unless you have a local capture system that prevents escape of the dust.

Under 1910.1001(f)(1)(x), can asbestos-containing flooring be sanded?

No — sanding of asbestos-containing flooring material is prohibited. The standard plainly states this prohibition in 1910.1001(f)(1)(x).

  • Use non-sanding methods or removal procedures that comply with the asbestos standard to avoid releases.

Under 1910.1001(f)(2), what must an employer do if monitoring shows the TWA or excursion limit is exceeded?

The employer must establish and implement a written compliance program to reduce employee exposures using engineering and work-practice controls and, where required or permitted, respirators. This requirement is in 1910.1001(f)(2)(i).

  • The program must be written, kept current, and reviewed/updated to reflect significant changes as required by 1910.1001(f)(2)(ii).
  • Employers must make the written program available on request to the Assistant Secretary, the Director, affected employees, and employee representatives per 1910.1001(f)(2)(iii).
  • Employers may not use employee rotation to achieve compliance with the PELs (1910.1001(f)(2)(iv)).

Under 1910.1001(f)(3), what methods must be used for automotive brake and clutch repair to control asbestos exposures?

Employers must use either the negative pressure enclosure/HEPA vacuum method or the low-pressure/wet cleaning method described in Appendix F, or an equivalent method demonstrated to be as effective. This requirement is in 1910.1001(f)(3)(i) and 1910.1001(f)(3)(ii).

  • Employers may use an "equivalent method" only after documenting, via monitoring under workplace conditions or objective data, that it achieves exposure reductions equivalent to Method A in Appendix F.
  • Small-volume facilities (inspecting no more than five pairs of brakes or clutches per week) may use the method described in paragraph D of Appendix F (see 1910.1001(f)(3)(ii)).

Under 1910.1001(f)(1)(iii), what must employers do for listed primary manufacturing operations when engineering controls alone can’t meet the PEL?

When feasible engineering controls and work practices cannot reduce employee exposure to the PEL, employers must use those controls to reduce exposures to at least 0.5 fibers/cc TWA (or 2.5 fibers/cc for a 30-minute short-term) and supplement them with respirators and additional measures to reach the PEL. This requirement appears in 1910.1001(f)(1)(iii).

  • The paragraph lists operations (e.g., coupling cutoff in asbestos cement pipe manufacturing, sanding/grinding in certain manufacturing, dry textile carding/spinning) where the employer must implement engineering controls to get exposures down to 0.5 f/cc where possible and then supplement with respirators complying with paragraph (g).
  • Respirator selection and program requirements are in 1910.1001(g).

Under 1910.1001(g)(1), when must employers provide respirators for asbestos exposures?

Employers must provide respirators during periods needed to install or implement feasible engineering/work-practice controls, for tasks where those controls are not feasible or not yet sufficient, and during emergencies. Those obligations are set out in 1910.1001(g)(1) and its subparagraphs (i)–(iv).

  • Respirators are required while engineering controls are being installed, when controls cannot be used, when controls are inadequate, and for emergency response.
  • See 1910.1001(g)(1)(i)–(iv).

Under 1910.1001(g)(2)(i), what respiratory program requirements must employers meet for asbestos?

Employers must implement a respiratory protection program that complies with the specified portions of 29 CFR [1910.134(b) through (d) (except (d)(1)(iii)), and (f) through (m)] according to 1910.1001(g)(2)(i).

  • This means following the medical evaluation, fit-testing, training, respirator selection, and program administration requirements in 29 CFR 1910.134.
  • Maintain written procedures and records as required by 1910.134.

Under 1910.1001(g)(3), are filtering facepiece (disposable) respirators acceptable for asbestos?

No — employers must not select or use filtering facepiece respirators for protection against asbestos fibers, and they must provide HEPA filters for powered and non-powered air-purifying respirators. These rules are found in 1910.1001(g)(3)(i) and 1910.1001(g)(3)(ii).

  • Use only respirators specified in 1910.134(d)(3)(i)(A) (for example, elastomeric half or full face with appropriate cartridges, or PAPRs) with HEPA filtration.
  • Employees may elect to use a PAPR if it provides adequate protection (1910.1001(g)(2)(ii)).

Under 1910.1001(h), what protective clothing and equipment must employers provide for asbestos exposures above the PEL?

Employers must provide, at no cost, appropriate protective work clothing and equipment (for example, coveralls, gloves, head and foot coverings, and eye/face protection) when employee exposure is above the TWA and/or excursion limit or when eye irritation is possible. This obligation is stated in 1910.1001(h)(1).

  • Face shields or vented goggles must meet 1910.133 requirements.
  • Employers must clean, launder, repair, or replace protective clothing to maintain effectiveness and provide clean garments at least weekly per 1910.1001(h)(3)(i).

Under 1910.1001(h)(2) and (h)(3)(vi), how must contaminated protective clothing be stored and transported?

Contaminated work clothing must be removed only in change rooms, stored in closed containers that prevent dispersion, and transported in sealed impermeable bags or closed impermeable containers labeled per the standard. These requirements are in 1910.1001(h)(2)(i)–(iii) and 1910.1001(h)(3)(vi).

  • Only authorized persons (laundry/maintenance/disposal) may remove garments from the change room, per 1910.1001(h)(2)(ii).
  • Containers taken out for cleaning must be labeled in accordance with 1910.1001(j).

Under 1910.1001(h)(3), how must contaminated clothing be laundered and who must the employer notify?

Contaminated clothing must be laundered so as to prevent release of asbestos fibers above the PEL, employers must not remove asbestos by blowing or shaking, and if another person launders the clothing the employer must inform that person of the laundering requirement and of the potential hazards. These duties are in 1910.1001(h)(3)(ii)–(iv).

  • Employers must also ensure cleaning, repair or replacement maintains effectiveness and provide clean clothing at least weekly (1910.1001(h)(3)(i)).
  • Notify any laundry service given contaminated clothing about the requirement to prevent airborne fiber releases and the health hazards (1910.1001(h)(3)(iv)–(v)).

Under 1910.1001(i), what change room, shower, and lunchroom facilities must employers provide when exposures exceed the PEL?

Employers must provide clean change rooms with separate storage for street clothes and work clothes, ensure employees shower at the end of shifts, and provide lunchrooms with positive-pressure filtered air where required. These obligations are set out in 1910.1001(i)(1), 1910.1001(i)(2), and 1910.1001(i)(3).

Under 1910.1001(i)(3)(iii)–(iv), what hygiene practices must employees follow before eating and when entering lunchrooms?

Employees who work where airborne asbestos is above the PEL must wash hands and faces before eating and may not enter lunchrooms wearing protective clothing or equipment unless surface asbestos has been removed by vacuuming or equivalent non-dispersive methods. These hygiene rules appear in 1910.1001(i)(3)(iii)–(iv).

  • Use HEPA vacuums or other methods that do not re-entrain fibers to remove surface contamination before entering eating areas.

Under 1910.1001(h)(2)(iv) and 1910.1001(j), how must containers of contaminated clothing be labeled?

Containers of contaminated protective devices or work clothing that are to be taken out of change rooms or the workplace for cleaning, maintenance, or disposal must bear labels in accordance with the communication requirements of the asbestos standard. This labeling requirement is set out in 1910.1001(h)(2)(iv) and relates to the hazard communication provisions in 1910.1001(j).

  • Labels must communicate that the contents are contaminated with asbestos and the hazards and precautions for handling.

For property remediation work (e.g., water-damaged homes), which OSHA asbestos standard generally applies — construction or general industry? (cite OSHA interpretation)

OSHA says asbestos remediation activities in buildings (including many property remediation tasks described) are generally covered by the construction asbestos standard, not the general industry standard. That guidance is provided in OSHA's interpretation "Asbestos remediation protocols" (Nov. 14, 2024).

  • The interpretation explains that even if a company is not a traditional construction firm, remediation activities involving ACBM are likely covered by [29 CFR 1926.1101], and it cites the relationship between [29 CFR 1910.1001] and the construction standard for such work.
  • Employers performing remediation in homes should evaluate coverage under [29 CFR 1926.1101] and follow the construction standard requirements when applicable (see OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14).

Under 1910.1001, which workers are covered by the general industry asbestos standard and who is not?

Employees in general industry who manufacture asbestos-containing products, repair/replace automotive brakes and clutches, or perform housekeeping in industrial facilities or public/commercial buildings with installed asbestos-containing materials are covered by the general industry asbestos standard; however, state or local government employees in non-state-plan states are generally not covered by the Federal general industry standard. See 29 CFR 1910.1001 for the general coverage language, and note OSHA’s interpretation that activities like remediation that are construction-related (for example, many property remediation jobs) are covered by the construction asbestos standard, not the general industry standard, in the Asbestos remediation protocols letter of interpretation.

Under 1910.1001(j)(2), when must building materials be treated as "presumed asbestos-containing material (PACM)"?

You must treat thermal system insulation (TSI) and sprayed-on and troweled-on surfacing materials in buildings constructed no later than 1980 as presumed asbestos-containing material (PACM); asphalt and vinyl flooring materials installed no later than 1980 must also be treated as asbestos-containing. See the specific requirement in 1910.1001(j)(2).

Under 1910.1001(j)(8), how can a building owner demonstrate that PACM does not contain asbestos so they don't have to treat it as PACM?

A building owner or employer may demonstrate that PACM does not contain asbestos by following the procedures and criteria in 1910.1001(j)(8), including the testing and documentation requirements in the subsection; if they successfully rebut the PACM designation they are not required to communicate that material as PACM, but they must retain the information, data, and analysis supporting that determination in accordance with 1910.1001(m).

Under 1910.1001(j)(3), what specific duties do building and facility owners have to inform employers and employees about ACM and PACM?

Building and facility owners must determine the presence, location, and quantity of ACM and/or PACM at the work site, maintain records of that information for the duration of ownership (and transfer them to successive owners), and inform employers and employees—especially those who perform housekeeping—about the presence and location of ACM and PACM in areas they may contact during their work. See 1910.1001(j)(3)(i)-(iii).

Under 1910.1001(j)(4), what must warning signs for regulated asbestos areas say and where must they be posted?

Warning signs must be posted at each regulated area and at all approaches so employees can read them and take protective steps before entering; the signs must bear the legend shown in 1910.1001(j)(4)(ii)(A) (e.g., "DANGER ASBESTOS MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS AUTHORIZED PERSONNEL ONLY") and, where respirators and protective clothing are required, must include the additional legend in 1910.1001(j)(4)(ii)(B); employers must also ensure employees working in and adjacent to regulated areas comprehend the signs per 1910.1001(j)(4)(iii).

Under 1910.1001(j)(5) and (j)(6), what labeling is required for asbestos-containing materials and when do labeling provisions not apply?

Labels must be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers (or to their containers), and labels for bags/containers of protective clothing, scrap, waste, and debris must include the specified legend such as "DANGER CONTAINS ASBESTOS FIBERS MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS DO NOT BREATHE DUST AVOID CREATING DUST" as described in 1910.1001(j)(5)(i) and (j)(5)(ii). The labeling (and SDS) requirements do not apply where asbestos fibers have been bonded/coated such that no airborne fibers above the TWA or excursion limit will be released during any reasonably foreseeable use, or where asbestos is present at concentrations less than 1.0%, per 1910.1001(j)(6)(i)-(ii).

Under 1910.1001(j)(7), what training and information must employers provide to employees exposed at or above the PEL and to housekeeping employees in areas with ACM/PACM?

Employers must train each employee exposed at or above the PEL and/or excursion limit before or at initial assignment and at least annually thereafter, covering items such as health effects, smoking relationship, locations and uses of asbestos, engineering controls and work practices, protective procedures and equipment, respirator purpose/limits, medical surveillance, and the content of the standard, as listed in 1910.1001(j)(7)(i)-(iii) and (j)(7)(iii)(A)-(I). Additionally, employers must provide asbestos awareness training at no cost to housekeeping employees who perform work in areas containing ACM/PACM at least once a year that covers health effects, locations of ACM/PACM, recognition of damage, housekeeping requirements in the standard, and proper response to fiber releases per 1910.1001(j)(7)(iv)-(v).

Under 1910.1001(j)(1), how does the Hazard Communication Standard apply to asbestos and what hazards must be communicated?

Asbestos must be included in the employer’s Hazard Communication program and chemical manufacturers, importers, distributors, and employers must comply with the Hazard Communication Standard for asbestos; employers must ensure employees have access to container labels and safety data sheets and are trained as required by 1910.1200 and by 1910.1001(j)(1). When classifying asbestos hazards employers must address at least cancer and lung effects per 1910.1001(j)(1)(ii).

Under 1910.1001(j)(5), may employers post signs instead of affixing labels to asbestos-containing materials and what information must those signs include?

Yes—signs that contain the same information required for labeling may be posted in lieu of labels, provided they contain the required labeling information; when building owners or employers identify previously installed ACM/PACM they must affix labels or post signs so employees are notified of what materials contain ACM/PACM and place them where employees likely to be exposed will notice (for example, at mechanical room entrances) as described in 1910.1001(j)(5)(i) and the signage/label specifications in 1910.1001(j)(5)(ii).

Under the asbestos standards, if my company performs remediation work in residential homes, which OSHA asbestos standard applies: general industry 1910.1001 or construction 1926.1101?

Work that is remediation-like (for example, cleanup, repair, removal, or similar activities involving asbestos-containing building materials) is generally covered by OSHA’s construction asbestos standard, 29 CFR 1926.1101, rather than the general industry standard; OSHA explained this point in the Asbestos remediation protocols letter of interpretation, which clarifies that many property remediation activities involving ACBM fall under the construction standard.

Under 1910.1001(j)(8)(ii) and 1910.1001(j)(8)(iii), how can an employer show that presumed asbestos-containing material (PACM) — including flooring with mastic/backing — does NOT contain asbestos, who may perform the work, and what records should be kept?

You can show PACM does not contain asbestos either by an AHERA inspection that finds no ACM or by laboratory testing of bulk samples collected and analyzed to the required standards; for flooring (including mastic/backing) an industrial hygienist may make a determination based on recognized analytical techniques.

  • If you rely on an AHERA inspection, follow the option in 1910.1001(j)(8)(ii)(A), i.e., have a completed inspection conducted under AHERA (40 CFR 763, Subpart E) that shows no ACM in the material.

  • If you rely on testing, follow 1910.1001(j)(8)(ii)(B):

    • Have bulk samples collected in the manner described in 40 CFR 763.86.
    • Use an accredited inspector or a certified industrial hygienist (CIH) to collect/evaluate samples.
    • Ensure analysis is done by persons or labs with demonstrated proficiency (for example, participation in NVLAP, NIST, or the AIHA Round Robin) as required by the rule.
  • For flooring (including mastic and backing) you may also meet the rule by obtaining a determination from an industrial hygienist based on recognized analytical techniques as set out in 1910.1001(j)(8)(iii).

  • Keep documentation of whatever method you use. If you rely on objective data or test results, maintain records showing the product, source of data, testing protocol and results, and how the data support any exemption or conclusion, as required by 1910.1001(m)(2).

Note: if your work is remediation of asbestos-containing building materials in structures (for example post-fire or water-damaged homes), OSHA has clarified that many remediation activities are covered by the construction asbestos standard (29 CFR 1926.1101) rather than the general industry standard; consult OSHA’s Asbestos remediation protocols interpretation and a qualified industrial hygienist to determine which standard applies before you start work.

Practical tips: use a qualified inspector/CIH, follow 40 CFR 763.86 for sampling, send samples to a certified lab with current proficiency, and keep the documentation with your asbestos records so you can demonstrate compliance to OSHA inspectors.