Asbestos scope and application

Yes. The construction asbestos standard applies to demolition or salvage work where asbestos is present. See 1926.1101(a)(1).

• Practical action: Treat demolition or salvage activities as asbestos work until materials are verified non‑asbestos, establish regulated areas and controls, and follow required work practices for the applicable class of asbestos work under 1926.1101.
• Key reference: 1926.1101(a) defines the standard’s scope and lists demolition as covered.

No. Asbestos-containing asphalt roof coatings, cements, and mastics are excluded from the construction asbestos standard. See 1926.1101(a)(8).

• Practical action: Even though these materials are excluded from this construction standard, employers should still check other federal, state, or local requirements and follow safe work practices when disturbing any asbestos-containing material.
• Reference: 1926.1101(a) outlines the exclusion.

ACM is any material containing more than 1% asbestos. See 1926.1101(b).

• Practical action: Treat materials with >1% asbestos as ACM for work planning, training, and controls required by the standard.
• Related: The standard also defines Presumed Asbestos Containing Material (PACM) for certain materials installed before 1980; see 1926.1101(b).

PACM (Presumed Asbestos Containing Material) means thermal system insulation and surfacing material found in buildings constructed no later than 1980 and is presumed to contain asbestos unless rebutted. See 1926.1101(b).

• Practical action: For buildings built no later than 1980, treat thermal system insulation and surfacing materials as PACM until sampling and analysis under 1926.1101(k)(5) demonstrate otherwise.
• Note: The standard explains the process to rebut PACM designation at 1926.1101(k)(5).

Class I–IV are categories of asbestos work defined by the standard and are used to determine required controls and training. See 1926.1101(b).

• Class I: Removal of thermal system insulation (TSI) and surfacing ACM/PACM (e.g., removing pipe insulation or sprayed fireproofing).

• Class II: Removal of ACM that is not TSI or surfacing (e.g., removing asbestos-containing floor tile, wallboard, roofing shingles).

• Class III: Repair and maintenance operations where ACM/ PACM is likely to be disturbed (e.g., cutting into asbestos-containing drywall for a repair).

• Class IV: Maintenance and custodial activities where employees contact but do not disturb ACM or clean up waste from Class I–III activities.

• Practical action: Identify the class before work starts so you can apply the correct work practices, PPE, and training requirements in [1926.1101].

The standard limits the amount of ACM disturbed by glove bags to what can be contained in one glove bag not exceeding 60 inches by 60 inches. See 1926.1101(b).

• Practical action: Use glove bags no larger than 60" × 60" when employing glovebag techniques and ensure the materials removed fit within a single bag.
• Reference: The glovebag definition and size limit are given in 1926.1101(b).

The PELs are 0.1 fiber per cubic centimeter (f/cc) as an 8‑hour TWA and 1.0 f/cc as a 30‑minute excursion limit. See 1926.1101(c)(1) and 1926.1101(c)(2).

• Practical action: Employers must assess exposures using the method in appendix A (or an equivalent) and implement engineering controls, work practices, and respiratory protection to keep exposures below these limits.
• Reference: See 1926.1101(c).

The employer establishing a regulated area must inform other employers on site about the nature of the asbestos work, the existence and requirements of the regulated area, and the measures taken to protect their employees. See 1926.1101(d)(1).

• Practical action: Provide clear written or verbal notices, post signs, and communicate controls (e.g., enclosure boundaries, decontamination routes) to other contractors and site employers.
• Reference: 1926.1101(d) covers multi‑employer responsibilities.

The contractor who created or controls the source of asbestos contamination must abate the asbestos hazards. See 1926.1101(d)(2).

• Practical action: If an enclosure breaches, the employer that erected or controls the enclosure must promptly repair it; other employers should ensure their employees are not exposed while repairs occur.
• Reference: See the example in 1926.1101(d)(2).

Employers must either remove adjacent employees from exposure until containment is fixed or perform an initial exposure assessment, and they must check daily that enclosures and controls remain effective. See 1926.1101(d)(3) and 1926.1101(d)(4).

• Practical action: On each shift verify enclosure integrity, keep employees clear of breaches, and document any exposure assessments and protective steps taken.
• Reference: 1926.1101(d) defines these multi‑employer protections.

For Class I and II work, a competent person must be able to identify asbestos hazards and must be specially trained in a course meeting EPA's Model Accreditation Plan (40 CFR part 763) for supervisors or an equivalent. See 1926.1101(b).

• Practical action: Ensure supervisors for Class I/II work complete supervisor-level training consistent with EPA MAP (40 CFR part 763) and are authorized to take corrective action on site.
• Reference: Competent person training requirements are in 1926.1101(b).

A Negative Initial Exposure Assessment is an employer's demonstration, meeting the criteria in [1926.1101(f)(2)(iii)], that employee exposure during an operation is expected to be consistently below the PELs. See 1926.1101(f)(2)(iii).

• Practical action: To rely on a negative assessment, document the basis (methods, workplace conditions, historical data) that exposures will remain below the TWA and excursion limits, and keep the documentation available.
• Reference: See definition of “Negative Initial Exposure Assessment” in the standard and the requirements in 1926.1101(f)(2)(iii).

A regulated area is an employer‑established zone that demarcates where Class I, II, and III asbestos work is done and any adjoining area where related debris accumulates; it also includes areas where asbestos airborne concentrations exceed or may exceed the PEL. See 1926.1101(b).

• Practical action: Establish and post regulated areas before starting Class I–III work or when monitoring shows exposures may exceed PELs; control access and ensure decontamination facilities are in place as required by 1926.1101(e).
• Reference: See the regulated area definition in 1926.1101(b) and requirements in 1926.1101(e).

Yes. The standard covers transportation, disposal, storage, containment, and housekeeping activities involving asbestos or asbestos-containing products at the site where construction activities are performed. See 1926.1101(a)(6).

• Practical action: Manage asbestos waste and contaminated materials using required containment, labeling, and disposal practices, and follow regulated‑area housekeeping procedures to prevent fiber release.
• Reference: 1926.1101(a)(6).

An ‘‘intact’’ ACM is material that has not crumbled, been pulverized, or otherwise deteriorated so that the asbestos is no longer likely to be bound within its matrix. See 1926.1101(b).

• Practical action: Intact ACM generally presents less immediate airborne fiber hazard than damaged ACM, but employers must still avoid disturbing it and follow assessment and control requirements whenever work may disturb it.
• Reference: See the definition in 1926.1101(b).

A homogeneous area is a surfacing material or thermal system insulation area that is uniform in color and texture. See 1926.1101(b).

• Practical action: Homogeneous areas are used when sampling and characterizing ACM—materials that look uniform can be treated as one sampling unit for analysis and work planning.
• Reference: Definition appears in 1926.1101(b).

A HEPA filter is defined as a filter capable of trapping and retaining at least 99.97% of all mono‑dispersed particles of 0.3 micrometers in diameter. See 1926.1101(b).

• Practical action: Use HEPA‑filtered vacuums and local exhaust systems when cleaning or during operations likely to generate asbestos fibers to meet control requirements.
• Reference: See HEPA definition in 1926.1101(b).

No. Omitting a procedure or reducing the stringency of a component of the control system is not considered a “modification” for purposes of paragraph (g)(6). See 1926.1101(g)(6) and the explanatory text that states this explicitly.

• Practical action: You cannot claim you made an acceptable ‘‘modification’’ to a control by simply removing or weakening required elements—the standard treats that differently and you must comply with all required components.
• Reference: See the statement about omissions not qualifying as modifications in the standard text and 1926.1101(g)(6).

General contractors on projects that include work covered by this asbestos standard are deemed to exercise general supervisory authority over the asbestos work even if they are not qualified to be the asbestos competent person. See 1926.1101(d)(5).

• Practical action: General contractors should coordinate subcontractors, confirm required controls and communications are in place, and ensure daily checks for enclosure integrity and worker protection are performed.
• Reference: See 1926.1101(d)(5).

Yes. Asbestos spill and emergency cleanup are covered under the construction asbestos standard. See 1926.1101(a)(5).

• Practical action: Treat spill/emergency cleanup as asbestos work—establish regulated areas, use appropriate PPE, follow cleanup and waste handling procedures, and notify affected employers on multi‑employer sites.
• Reference: See scope listing in 1926.1101(a).

Yes. The installation of products containing asbestos is within the scope of the construction asbestos standard. See 1926.1101(a)(4).

• Practical action: When installing asbestos‑containing products, follow the appropriate class‑based work practices, ensure competent person oversight, and control exposures to meet PELs.
• Reference: See 1926.1101(a).

A competent person must be capable of identifying asbestos hazards and selecting appropriate control strategies and must have the authority to take prompt corrective measures to eliminate hazards, consistent with the definition in 29 CFR 1926.32(f) and 1926.1101(b). See 1926.1101(b) and 1926.32(f).

• Practical action: Ensure the competent person can stop work, require repairs to containment, and implement additional controls when exposures or enclosure failures occur.
• Reference: Competent person duties are in 1926.1101(b) and the cross‑reference to 1926.32(f).

The standard allows rebuttal of PACM designation pursuant to [1926.1101(k)(5)], which sets out procedures to demonstrate a material is not asbestos-containing. See 1926.1101(k)(5).

• Practical action: Follow the sampling, analysis, and documentation steps in 1926.1101(k)(5) to rebut a PACM designation and retain records showing the material does not contain asbestos.
• Reference: See the PACM rebuttal provision at 1926.1101(k)(5).

Coverage under the standard is determined by the nature of the work operation that involves asbestos exposure, not by the employer’s industry label. See 1926.1101(a)(7).

• Practical action: Evaluate the specific tasks (e.g., removal, repair, cleanup) being performed; if the task is covered by the listed activities in 1926.1101(a), the construction standard applies regardless of company classification.
• Reference: See 1926.1101(a)(7).

Yes. OSHA’s interpretation advises that property remediation activities involving asbestos-containing building materials (ACBM), even in residential homes, are covered by the construction asbestos standard, 29 CFR 1926.1101, rather than the general industry standard. See OSHA’s letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14.

• Practical action: Remediation firms should plan work under 1926.1101, ensure competent person oversight, appropriate training, regulated areas, and follow abatement work practices for residential cleanup when ACBM is present.
• Reference: OSHA’s Asbestos remediation protocols letter of interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 and the standard at 1926.1101.

TSI is asbestos-containing material applied to pipes, fittings, boilers, breeching, tanks, ducts, or other structural components to prevent heat loss or gain. See 1926.1101(b).

• Practical action: TSI is often regulated as Class I work; when removing or disturbing TSI, follow the more stringent controls, training, and competent person oversight required by the standard.
• Reference: Definition appears in 1926.1101(b).

Removal means all operations where ACM and/or PACM is taken out or stripped from structures or substrates and includes demolition operations. See 1926.1101(b).

• Practical action: Treat any stripping or taking out of ACM/PACM as removal work and apply the applicable control, work practice, and regulated‑area requirements of the standard.
• Reference: See the removal definition in 1926.1101(b).

The general contractor must ascertain whether the asbestos contractor is complying with the asbestos construction standard and require them to come into compliance when necessary. See 1926.1101 which states the general contractor, as supervisor of the entire project, has that duty. Employers should document checks and follow-up actions so they can show they took steps to verify compliance.

A regulated area must be established for all Class I, II, and III asbestos work, and for any other operations where airborne asbestos concentrations exceed, or there is a reasonable possibility they may exceed, a permissible exposure limit (PEL). See 1926.1101(e)(1). Employers should presume regulated-area requirements apply to Class I work until monitoring or a negative exposure assessment shows exposures are below the PELs.

The regulated area must be demarcated in a way that minimizes the number of people inside and protects those outside from asbestos exposure, and signs must be displayed as required by paragraph (k)(7). See 1926.1101(e)(2) and the sign requirement at 1926.1101(k)(7). Critical barriers or negative-pressure enclosures may serve as demarcation; choose methods that clearly stop unprotected entry and communicate hazard through required signage.

Access to a regulated area must be limited to authorized persons and those authorized by law or regulation. See 1926.1101(e)(3). Employers should implement procedures (badges, escorting, training) so only authorized, properly trained and protected people enter the regulated area.

Yes. Employers must supply a respirator to every person entering a regulated area where employees are required by 1926.1101(h)(1) to wear respirators, and the respirator must be selected per 1926.1101(h)(3). See 1926.1101(e)(4). Ensure respirators fit, are appropriate for the exposure, and that medical clearance and training requirements of paragraph (h) are met.

Employees are prohibited from eating, drinking, smoking, chewing tobacco or gum, or applying cosmetics in a regulated area. See 1926.1101(e)(5). Employers should clearly communicate and enforce these prohibitions (signs, training, supervision) and provide clean areas outside the regulated area for these activities.

All asbestos work performed within regulated areas must be supervised by a competent person as defined in paragraph (b), and the competent person's duties are set out in paragraph (o). See 1926.1101(e)(6) and the duties at 1926.1101(o). Employers must designate a competent person who can identify asbestos hazards and take corrective actions required by the standard.

Employers must perform exposure monitoring whenever monitoring is required under the standard and must base exposure determinations on breathing-zone air samples representative of employees' 8-hour TWA and 30-minute short-term exposures. See 1926.1101(f)(1)(i) and 1926.1101(f)(1)(ii). Collect full-shift samples for TWA and 30-minute samples for tasks likely to exceed the excursion limit.

Representative 8-hour TWA samples must be one or more full-shift samples for employees in each work area, and representative 30-minute short-term samples must cover 30-minute exposures associated with operations most likely to exceed the excursion limit. See 1926.1101(f)(1)(iii). Design sampling to capture the worst reasonably expected exposure periods for each job/task.

A competent person must conduct an initial exposure assessment immediately before or at the start of the operation to ascertain expected exposures and to ensure planned controls will work; unless a negative exposure assessment exists, the initial assessment should, if feasible, be based on monitoring as described in [1926.1101(f)(1)(iii)]. See 1926.1101(f)(2)(i) and 1926.1101(f)(2)(ii). The competent person should consider existing data, observed conditions, and prior monitoring when planning controls.

A negative exposure assessment can be demonstrated by objective data showing the material or activity cannot release asbestos fibers above the TWA and excursion limit; or by monitoring from prior similar jobs within 12 months that conforms to the standard and closely resembles the current work; or by initial exposure monitoring of the current job with breathing-zone samples representative of full-shift and 30-minute exposures. See 1926.1101(f)(2)(iii)(A), 1926.1101(f)(2)(iii)(B), and 1926.1101(f)(2)(iii)(C). Employers using an NEA must ensure the data closely match current conditions, worker training/skill levels, and control methods.

For Class I and II operations, employers must conduct daily monitoring representative of each employee's exposure unless a negative exposure assessment covers the entire operation; for other operations expected to exceed the PEL, periodic monitoring must be done at intervals sufficient to validate the exposure prediction. See 1926.1101(f)(3)(i) and 1926.1101(f)(3)(ii).

The employer may dispense with daily monitoring required by paragraph (f)(3) only when all employees required to be monitored daily are equipped with supplied-air respirators operated in the pressure-demand mode or another positive-pressure mode. See 1926.1101(f)(3)(iii). Note: employees performing Class I work using control methods not listed in 1926.1101(g)(4)(i)-(iii) must still be monitored daily even if using supplied-air respirators.

An employer may stop monitoring for employees whose exposures are shown by statistically reliable periodic monitoring to be below the PEL and excursion limit, but must institute monitoring whenever changes in process, controls, personnel or work practices could result in new or additional exposures above the PEL or when the employer has reason to suspect such increases. See 1926.1101(f)(4)(i) and 1926.1101(f)(4)(ii).

Employers must notify each affected employee of monitoring results as soon as possible but no later than 5 working days after receiving results, either individually in writing or by posting in an accessible location, and must allow affected employees or their representatives to observe any monitoring; observers must be provided and use required protective clothing and equipment if entry into protected areas is necessary. See 1926.1101(f)(5) and 1926.1101(f)(6).

Employers must use HEPA-filtered vacuum cleaners to collect asbestos debris except where specific roofing exceptions apply, wet methods or wetting agents for handling, removal, cutting, application and cleanup (unless infeasible for reasons such as electrical hazards), and prompt cleanup and disposal of asbestos wastes in leak-tight containers (with roofing exceptions noted). See 1926.1101(g)(1)(i), 1926.1101(g)(1)(ii), and 1926.1101(g)(1)(iii). Employers must document and justify any infeasibility of wet methods.

When feasible engineering and work-practice controls cannot reduce employee exposures to or below the TWA and excursion limits, employers must use those controls to lower exposure as much as possible and supplement them with respiratory protection that meets paragraph (h). Employers should also use local exhaust with HEPA filters, enclosure/isolation, and ventilation directing contaminated air toward HEPA filtration where practicable. See 1926.1101(g)(2) and the respiratory requirements at 1926.1101(h).

HEPA-filtered vacuums are required to collect asbestos debris and dust except as provided in paragraph (g)(8)(ii) for roofing operations; that roofing paragraph contains specific alternate procedures. See 1926.1101(g)(1)(i) and 1926.1101(g)(8)(ii). Employers performing roofing work should follow the special roofing procedures in (g)(8)(ii) when applicable.

If the remediation activities involve ACBM, those operations are covered by the construction asbestos standard, 29 CFR 1926.1101, not the general industry standard. OSHA's Asbestos remediation protocols interpretation clarifies that remediation activities involving asbestos-containing building materials fall under 1926.1101. See OSHA's letter "Asbestos remediation protocols" (Nov. 14, 2024) at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 for additional guidance about remediation in residential settings.

These four practices are prohibited for any work related to asbestos or that disturbs asbestos-containing material (ACM) or presumed ACM (PACM):

• High-speed abrasive disc saws that are not equipped with a point-of-cut ventilator or enclosures with HEPA-filtered exhaust air (1926.1101(g)(3)(i)).
• Compressed air to remove asbestos or asbestos-containing materials, unless the compressed air is used with an enclosed ventilation system designed to capture the dust cloud (1926.1101(g)(3)(ii)).
• Dry sweeping, shoveling, or other dry cleanup of dust and debris containing ACM or PACM (1926.1101(g)(3)(iii)).
• Rotating employees (employee rotation) as a method to reduce individual asbestos exposure (1926.1101(g)(3)(iv)).

Follow these prohibitions regardless of measured asbestos levels or prior exposure assessments; they are absolute bans under the construction asbestos standard (1926.1101).

An employer must use critical barriers or another effective isolation method when the Class I job: (1) removes more than 25 linear feet or 10 square feet of thermal system insulation or surfacing material; (2) cannot document a negative exposure assessment under 1926.1101(f)(2)(iii); or (3) has employees working in areas adjacent to the regulated area while the Class I work is being done (1926.1101(g)(4)(ii)).

• Option A: Place critical barriers over all openings to the regulated area (except outdoor activities) (1926.1101(g)(4)(ii)(A)).
• Option B: Use another barrier or isolation method that prevents migration, and verify effectiveness with perimeter area surveillance each shift (no visible asbestos dust) and perimeter area monitoring meeting the clearance levels in 40 CFR part 763, subpart E (1926.1101(g)(4)(ii)(B)).

If you cannot produce the negative exposure assessment required by 1926.1101(f)(2)(iii), plan for barriers or equivalent isolation and document the perimeter surveillance/monitoring results as required by the standard (1926.1101(g)(4)(ii)).

Yes — when you use a Negative Pressure Enclosure (NPE) for Class I asbestos work you must meet both the specification and the work-practice requirements in the standard.

Specifications required for NPEs:

• Maintain at least 4 air changes per hour inside the enclosure (1926.1101(g)(5)(i)(A)(2)).
• Maintain a minimum negative pressure of −0.02 column inches of water relative to outside pressure, documented by manometric measurements (1926.1101(g)(5)(i)(A)(3)).
• Keep the NPE under negative pressure for the entire use period and direct air movement away from workers toward a HEPA filtration or collection device (1926.1101(g)(5)(i)(A)(4)-(5)).

Required pre-shift and shift work practices:

• Inspect the enclosure for breaches and smoke-test for leaks before beginning work and at the start of each shift; seal any leaks found (1926.1101(g)(5)(i)(B)(1)).
• Deactivate electrical circuits in the enclosure unless they are equipped with ground-fault circuit interrupters (GFCIs) (1926.1101(g)(5)(i)(B)(2)).

Follow these specifications and checks exactly to maintain the containment and protect workers during Class I removal operations (1926.1101(g)(5)(i)).

If the remediation work involves asbestos-containing building materials (ACBM) or activities that disturb ACM/PACM, OSHA treats that work as construction and the employer must follow the construction asbestos standard, 29 CFR 1926.1101, not the general industry standard (Asbestos remediation protocols, OSHA letter of interpretation, Nov. 14, 2024).

Practical points from OSHA's interpretation:

• Property remediation companies that perform cleanup after fires, floods, or other damage can be covered by the construction standard when their activities disturb ACBM even if they are not traditionally "construction" firms (Asbestos remediation protocols, Nov. 14, 2024).
• ACBM is more likely in buildings constructed before about 1980, so assume potential ACM in older homes and evaluate accordingly (Asbestos remediation protocols, Nov. 14, 2024).

When in doubt, treat the work as subject to 1926.1101: perform proper surveys or presume ACM where applicable, apply the required Class I–IV work practices and controls, and document actions to comply with the construction asbestos standard.