OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 28, 1991

Kenneth A. Yager
Long Island Lighting Company
P.O. Box 426
Glenwood Landing, NY 11547

Dear Mr. Yager,

My apologies for the long response time for your letter of November 7, 1990. You asked if a person preparing slides for asbestos analysis need be 582 trained. This is not strictly required, so long as the proper preparation procedures are followed. It is required that the people reading the slides be 582 trained. Should you have any further questions, they will be handled much more expeditiously.


Daniel T. Crane
Supervisory Physical Scientist



November 7, 1990

Mr. Dan Crane
OSHA National Laboratory
P.O. Box 65200
Salt Lake City, Utah 84165-0200

Dear Mr. Crane:

This is in reference to your telephone conversation with Ms. Robin Knappe of my staff on October 17, 1990. To facilitate the asbestos analyses in our laboratory we are considering having one of our laboratory technicians prepare asbestos slides for fiber counting. Our intention, at the present time, is to train a technician in house solely to prepare slides. This technician, while a qualified laboratory technician for other analyses, will not have taken the NIOSH 582 course and therefore will not perform the actual counting. Since the purpose of our monitoring and analyses is for OSHA compliance, we are requesting guidance covering our scheme for preparing and reading the air filters. We believe it to be an efficient and cost effective alternative to meeting temporary increases in our asbestos workload. During normal load periods our NIOSH trained technician will prepare and read his own slides.

We also have scheduled another technician to take the NIOSH 582 course in December of this year. However, we are looking for alternate cost effective solutions to an increasing asbestos workload and/or peak demands.

Thank you for your consideration of this matter. If you have any questions, please contact me at (516) 671-6706.

Very truly yours,

Kenneth A. Yager
Laboratory Director