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OSHA 1915.1001AppH

Asbestos substance technical info

Subpart Z

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.1001 App H, what minerals are included in the term “asbestos”?

Asbestos is the name for a group of fibrous magnesium‑silicate minerals that includes chrysotile, crocidolite, amosite, anthophyllite asbestos, tremolite asbestos, and actinolite asbestos, and those are the minerals treated as asbestos under the appendix. See Appendix H to 1915.1001 for the list and identification.

Under 1915.1001 App H, what is the permissible exposure limit (PEL) for airborne asbestos fibers?

The PEL for asbestos is 0.1 fibers per cubic centimeter (f/cc) as an 8‑hour time‑weighted average, and 1.0 f/cc averaged over any 30‑minute period. These limits are stated in Appendix H to 1915.1001. Employers must evaluate and control exposures to meet these limits.

Under 1915.1001 App H, how does appendix H define “friable” asbestos material and why does it matter?

Friable asbestos material is defined as material that can be crumbled by hand pressure and therefore is likely to release breathable fibers; it matters because friable materials readily release airborne asbestos when disturbed and pose a higher exposure risk. This definition and the explanation of why friability increases fiber release are in Appendix H to 1915.1001.

Under 1915.1001 App H, when must employees wear respirators for asbestos work and what types are allowed?

Employees must wear respirators when asbestos exposure exceeds the PEL or during certain designated operations, and the type depends on concentration: air‑purifying respirators with HEPA filters are allowed where concentrations do not exceed 1.0 f/cc, while higher concentrations require more protective, supplied‑air positive‑pressure respirators. These respirator requirements are described in Appendix H to 1915.1001.

Under 1915.1001 App H, are disposable respirators or dust masks acceptable for asbestos work?

No — disposable respirators and ordinary dust masks are not permitted for asbestos work. Appendix H explicitly states these are not allowed and explains that respirators must provide effective particulate filtration for asbestos; see Appendix H to 1915.1001.

Under 1915.1001 App H, how often must employers fit‑test employees' respirators for asbestos work?

Employers must perform a respirator fit test when an employee is first assigned a respirator and then at least every 6 months thereafter to ensure an effective, snug fit. This fit‑test frequency and requirement are stated in Appendix H to 1915.1001.

Under 1915.1001 App H, when is protective clothing required for asbestos exposure?

Protective clothing is required in work areas where airborne asbestos fiber concentrations exceed the PEL of 0.1 f/cc. Appendix H explains that clothing must be used to prevent contamination of workers' street clothes and reduce secondary exposure; see Appendix H to 1915.1001.

Under 1915.1001 App H, what are the recommended procedures for handling and packaging asbestos waste removed from buildings?

Asbestos removed from buildings should be kept wet during removal, sealed in leak‑tight 6‑mil plastic bags or plastic‑lined containers, and sealed before they dry out to minimize fiber release during handling. Appendix H gives these disposal and packaging recommendations; see Appendix H to 1915.1001.

Under 1915.1001 App H, how should asbestos process waste and housekeeping waste be prepared for disposal?

Process waste and housekeeping waste should be wetted with water or a water‑surfactant mixture before packaging in disposable containers to reduce airborne fiber release during handling and disposal. These cleanup and packaging steps are recommended in Appendix H to 1915.1001.

Under 1915.1001 App H, what should be done with vacuum bags or disposable filters that captured asbestos?

Vacuum bags or disposable paper filters that have captured asbestos should not be cleaned; they should be sprayed with a fine water mist and placed into a labeled waste container for disposal. Appendix H states this practice to minimize fiber release during handling; see Appendix H to 1915.1001.

Under 1915.1001 App H, what training and information must employers give employees about asbestos each year?

Employers must annually inform employees of the information contained in the asbestos standard and appendices, instruct them in proper work practices for handling asbestos‑containing materials, and teach correct use of protective equipment. Appendix H sets this annual information and training requirement; see Appendix H to 1915.1001.

Under 1915.1001 App H, when must an employer treat thermal system insulation and sprayed‑on surfacing as asbestos?

An employer must treat thermal system insulation and sprayed‑on or troweled‑on surfacing material as asbestos unless laboratory analysis shows the material does not contain asbestos. This presumption and the need for testing to rebut it are explained in Appendix H to 1915.1001.

Under 1915.1001 App H, do employees have the right to observe and record exposure measurements?

Yes — employees or their designated representatives have the right to observe exposure monitoring and to record the results obtained during asbestos exposure measurements. Appendix H affirms this right to observation and recording; see Appendix H to 1915.1001.

Under 1915.1001 App H, what records must an employer keep about asbestos exposures and for how long?

Employers must keep exposure records for at least 30 years and medical records for the duration of employment plus 30 years. Appendix H specifies these retention periods and the requirement to maintain these records; see Appendix H to 1915.1001.

Under 1915.1001 App H, can an employee's exposure and medical records be released to their physician or representative?

Yes — an employer must release an employee's exposure and medical records to the employee's physician or designated representative upon written request by the employee. Appendix H states this right of access to records; see Appendix H to 1915.1001.

Under 1915.1001 App H, what must an employer do if testing shows an employee is exposed above the asbestos PEL?

If an employee is exposed above the PEL, the employer must inform the employee of their exposure and inform them of the actions being taken to reduce exposure to within the permissible limit. Appendix H requires employers to notify employees of exposures above the PEL and corrective actions; see Appendix H to 1915.1001.

Under 1915.1001 App H and OSHA interpretations, is an EPA school clearance level of 0.01 f/cc considered sufficient objective data for OSHA asbestos exposure assessments?

No — OSHA does not accept an EPA school clearance level of 0.01 f/cc (from 40 CFR Part 763) as sufficient "objective data" to satisfy OSHA's employer exposure assessment requirements for occupational asbestos exposures. OSHA explained this position in its interpretation about asbestos sampling protocols, which states that EPA clearance criteria are not equivalent to OSHA exposure assessment requirements; see OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2015-10-07 and Appendix H to 1915.1001.

Under 1915.1001 App H and OSHA guidance, does a bulk asbestos content of less than 1% mean the material is safe and not regulated?

No — OSHA does not consider a bulk asbestos content below 1% to be a "safe" level of asbestos; the 1% threshold only triggers certain regulatory procedures and enhanced requirements, but does not indicate safety. OSHA clarified that its regulations have not changed regarding bulk analysis and that a 1% bulk threshold is used for some regulatory triggers, not as a safety cutoff in a 2014 interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-05-1 and see Appendix H to 1915.1001.

Under 1915.1001 App H and OSHA interpretations, who may perform bulk sampling to rebut presumed asbestos in thermal system insulation and surfacing materials?

Bulk sampling to rebut presumptions of asbestos must be performed by an accredited inspector or a certified industrial hygienist (CIH) using approved analytical methods and laboratories that demonstrate proficiency (for example NVLAP or AIHA accreditation); OSHA discusses these requirements in its interpretation about asbestos sampling and point counting, see https://www.osha.gov/laws-regs/standardinterpretations/2014-11-05-1 and Appendix H to 1915.1001.

Under 1915.1001 App H, do employees have the right to be informed annually about asbestos hazards even if they are not currently exposed above the PEL?

Yes — employers are required to inform employees each year of the information in the asbestos standard and appendices and to instruct them in proper work practices and protective equipment use regardless of whether current exposures exceed the PEL. Appendix H states this annual information requirement; see Appendix H to 1915.1001.