Standard Interpretations - Table of Contents|
| Standard Number:||1910.1001; 1926.1101; 1915.1001|
Another option OSHA considered was requiring a comprehensive AHERA-type (EPA's schools rule) building/facility inspection. AHERA (Asbestos Hazard Emergency Response Act, 40 CFR 735) requires that all school buildings be visually inspected for asbestos-containing building materials (ACBM) by an EPA-accredited inspector and that inventory of the locations of these materials be maintained...As you also pointed out in your letter, such "comprehensive" surveys are often incomplete and inaccurate. Instead of requiring building owners and/or employers to perform a comprehensive building survey for installed asbestos, OSHA designed its Asbestos Standards with a simpler approach, called the "presumptive rule." Under this rule, the standards require building owners and employers to presumptively identify certain widely prevalent and more risky building materials. These are thermal system insulation and sprayed-on and troweled-on surfacing materials installed in buildings built no later than 1980. Such materials may be easily recognized without any technical training. These materials are termed "presumed asbestos containing materials" (PACM) and are to be treated as asbestos-containing for all purposes of the standards. Additionally, the OSHA standards allow building/facility/vessel owners and employers to rebut these presumptions through bulk sampling, such as may be performed during an AHERA survey. For a complete discussion of this issue, please review the Final Rule, which we cited above.
Although there was substantial support for a comprehensive inspection requirement, OSHA believes that the regulatory approach in these [OSHA’s] final standards will achieve equivalent or superior protection to exposed workers at much reduced cost. The reasons are as follows. A comprehensive wall-to-wall inspection requirement is found to be unnecessary to protect employees against risks of exposure from asbestos-containing building material of which they are unaware. Such an inspection requirement would be very costly, may be overly broad, the results may not be correct or timely, would not necessarily focus on potential sources of asbestos exposure which present significant risks to employees, and its great expense may divert resources from active protection of workers who actually disturb asbestos. [59 FR 41015]
|Standard Interpretations - Table of Contents|