Standard Interpretations - Table of Contents|
| Standard Number:||1910.1001; 1915.1001; 1926.1101|
Q. If an employer has a variety of work activities, how does one decide which class to follow?Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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 http://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at 202-693-2190.
A. . . .If more than one "class" of work occurs simultaneously, the work must be performed according to the highest hazard classification.
Q. Under the [Asbestos] Construction Standard [1926.1101], what is the difference between Class III maintenance work and Class IV maintenance work?
A. Class III maintenance work involves "disturbances" of ACM. The clarified meaning of the term "disturbance" [is] an activity that disrupts the matrix of ACM or PACM, crumbles or pulverizes ACM or PACM, or generates visible debris from ACM or PACM. Class IV asbestos work means maintenance and custodial activities during which employees contact but do not disturb ACM or PACM. . .
Q. Is installing a smoke detector in a ceiling where asbestos products are present regulated by the Construction Standard?
A. Depending on the potential source of asbestos exposure, the installation of a smoke detector could be Class IV, Class III, or neither. If the ceiling material to which the detector is to be attached is asbestos, the competent person must assess whether the attachment will involve "contact" (Class IV) or actually "disturb" the ceiling ACM [(Class III)]. Where the source of asbestos exposure [is from] dust and debris above the ceiling, for example from friable sprayed on/troweled on surfacing [ACM], the competent person should direct a Class IV cleanup before installing the detector. Otherwise the installation may be a Class III job if it involves disturbing debris and dust containing asbestos.
Q. What must an employer do if one is not sure what class the asbestos activity belongs in?
A. If it is not clear in which category the work belongs, the employer is to assume the higher, more restrictive, category applies, and must comply with the listed work practices and controls for that category.
|Standard Interpretations - Table of Contents|