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.


May 9, 1995

Mr. David E. LeGrande
Occupational Health and Safety Coordinator
Communications Workers of America
501 Third Street, N.W.
Washington, D.C. 20001-2797

Dear Mr. LeGrande:

This letter is in response to your February 2, correspondence concerning the Occupational Safety and Health Administration's (OSHA) regulation on OSHA's Occupational Exposure to Asbestos. You have asked which standard, the General Industry standard, 29 CFR 1910.1001 or the Construction standard, 29 CFR 1926.1101 apply for workers engaged in telecommunications work.

In general, telecommunication workers are employed in a wide variety of work sites where asbestos-containing products may be encountered. The Construction standard would apply to not only removal of asbestos, but also, alteration, repair, maintenance, or renovation of structures that contain asbestos. The Construction standard describes four classes of work that regulate activities which trigger different provisions of the standard. The classification, as determined by the competent person, will differ, depending on what asbestos materials are involved and what activities are being performed. The employer would be required to comply with all the provisions specified by each class of work. For example, the pulling of cable in areas containing installed asbestos building materials or presumed asbestos-containing materials, would be considered a Class III activity, due to the likelihood of "disturbance" as defined in the standard.

Thank you for your interest in safety and health. If we can be of any further assistance, please do not hesitate to call the [Office of Health Enforcement at (202) 693-2190].


Ruth McCully, Director
Office of Health Compliance Assistance

[Corrected 9/18/2007]