What’s the Difference Between OSHA’s General Industry and Construction Standards on Asbestos?

What’s the Difference Between OSHA’s General Industry and Construction Standards on Asbestos?

With so many entities regulating asbestos – EPA to OSHA to State Governments to even City and County Governments – we see a lot of confusion.  These regulations cross over and intertwine with each other and it’s sometimes difficult to remember which rule is required by which agency.  In this article, we will tackle OSHA’s side.

OSHA has two separate regulations regarding asbestos.  The General Industry Standard is at 29 CFR 1910.1001 and the Construction Standard is at 29 CFR 1926.1101. Unlike other regulations that are shared between 1910 and 1926, these are NOT a carbon copy of each other.

Which One is For You?  Well….It Depends.

In many standards, a company follows either the standard in 1910 or the standard in 1926 based on what type of facility you are.  If you’re a manufacturer, fixed facility, traditionally the 1910 general industry standard applies to you.  If you’re a construction company who moves from site to site, the 1926 construction standards typically apply to you.  However, for asbestos regulations, the one that applies to you depends on what’s going on at your site and what your workers are doing.

A general rule of thumb is daily management of asbestos at your facility falls under the general industry standards.  When you are intentionally disturbing asbestos, then you follow the construction standards.  So a “general industry” facility could be subject to both the general industry and the construction standards if they have a renovation going on.  It’s important that you know the difference between the two distinctions.

The Similarities

We’ll first take a look at the similarities between the two standards.  Remember that OSHA’s goal is the safety of the worker so regulations are focused on worker protection.

Notifying Employees of the Hazards of Asbestos

Both regulations require that you notify workers of the hazards of asbestos and you can do this for everyone through your compliance activities for the hazard communication standard or you can do it through separate training.  This includes informing workers of the presence and location of asbestos in their workplace as well as the health hazards caused by asbestos.  Housekeeping personnel are required to be notified of asbestos-containing areas they could be cleaning.  Outside contractors and project bidders who could work in areas where asbestos could be disturbed are required to be notified where it is.  If asbestos is to be disturbed, such as a removal projects for a renovation, those people working in areas adjacent to those work areas are to be notified of the project.  Tenants of buildings are required to be notified by the owner of the building.


Warning signs are to be posted on regulated areas where removal is being conducted or asbestos is being disturbed.

Warning labels should be on raw materials, mixtures, scrap, waste, debris, bagged protective clothing, and other products containing asbestos fibers, or be placed on their containers. Entrances to mechanical rooms or mechanical areas where employees could be exposed should have labels attached where they will clearly be noticed by employees.

Exposure Limits and Medical Surveillance

Each standard sets limits for the amount of asbestos a worker can be exposed to.  If there’s the potential that a worker will be exposed past the limits in the standards, then respiratory protection is required and certain PPE is as well.  If that limit is exceeded, then the worker also needs to be placed in a medical surveillance program to monitor the health effects of their potential exposure.


Each standard lines out required training. The level of training required depends on what the worker will be doing and whether or not they’ll be disturbing asbestos.  Training could range from an awareness class to a full week of intense training.  Most asbestos training is required to be repeated annually.

The Differences

General industry standards have a section on suggested work practices for housekeeping personnel to follow, but the construction industry standard dives into detailed work practices for those personnel intentionally disturbing asbestos-containing materials to follow.

In the construction standard is where we find the terms Class I, Class II, Class III and Class IV work.  The specific practices that workers are to follow are spelled out in detail for each class of work.

Class I work is for workers at the highest risk of exposure.  These are the one who will be removing friable asbestos materials.  Friable asbestos materials are those that when dry, can be easily crumbled or pulverized to powder by hand, making the potential for its fibers to be released even greater.  Class I work is the large-scale abatements of thermal systems insulation from pipes, boilers, tanks and ducts as well as removal of sprayed-on insulation, “popcorn ceiling” texture or acoustical plaster and vinyl floor covering.   This work requires specialized asbestos removal/abatement training of up to 40 hours with annual refreshers.

Class II work is the removal of non-friable asbestos.  Non-friable asbestos cannot be easily crumbled or pulverized to powder by hand and its asbestos fibers are usually bonded into other materials. If a non-friable material remains in good condition, it poses little hazard. Because of its strength, incidental contact will not usually release a fiber.  Class II work includes removal of vinyl asbestos floor tile, lay-in ceiling tile, Transite roofing panels, window glazing, asbestos siding and any non-friable materials.  This work requires specialized asbestos removal training that can vary from full 40 hour courses to specialized training for the specific material to be removed.

Class III work is the intentional disturbing of asbestos for repair and maintenance of other items.  For instance, if one needed to cut away a small amount of asbestos to fix a leaky pipe or to potentially disturb some asbestos in order to access an electrical panel for repair, that would fall under this class of work.  This type of work can often be done by in-house maintenance personnel or even maintenance contractors.  However, it’s still an intentional disturbance and so the workers who do these activities are required to take specialized asbestos removal training as well.  Class III work only allows workers to remove a certain quantity of material before it crosses the line and become Class I or II abatement work.  Specialized training to remove these small quantities is required, typically a 16-hour initial class with annual refresher training.

Class IV work is for those who will be conducting maintenance and custodial activities after a removal is completed, that is, cleaning up after Class I, II or III work.  This level has its own specific training requirements with specific content requirements.


Asbestos regulations can be hard to interpret and confusing as actually 4 entities can get involved in regulating it: EPA, OSHA, State Governments and City/County Governments.  If you have any questions regarding this article or asbestos in general, contact us.


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EPA Proposes Ban on Chrysotile Asbestos Still in Use Today

EPA Proposes Ban on Chrysotile Asbestos Still in Use Today

Asbestos is contained in thousands of products, from building materials and adhesives, fireproofing materials to consumer products.  The use of asbestos has dramatically declined since the 1980s, and more than 50 countries have banned its use.  However, one type of asbestos is still being used to make certain products in the U.S., and EPA is working to ban it.  It’s called chrysotile, or white asbestos.

Chrysotile is the most common type of asbestos.  Its soft, flexible fibers form a serpentine material that’s strong, heat resistant to 3000 degrees and non-conductive. 

Some chlor-alkali manufacturing plants that make chlorine and sodium hydroxide and some vehicle brake and sheet gasket manufacturers still import and use chrysotile asbestos in their products.

The EPA Ban on Chrysotile

EPA has issued a proposed rule to ban chrysotile asbestos in the following products:

  • Chrysotile asbestos used in bulk or in asbestos diaphragms in the chlor-alkali industry beginning two years after the effective date of the final rule;
  • Chrysotile asbestos-containing sheet gaskets in chemical production beginning two years after the effective date of the final rule;
  • Chrysotile asbestos-containing brake blocks used in the oil industry;
  • Chrysotile asbestos-containing aftermarket automotive brakes/linings and other friction products, including for consumer use; and
  • Chrysotile asbestos-containing gaskets, including for consumer use.

Asbestos diaphragms are used by chlor-alkali plants for the water treatment industry, but that use has been declining.  EPA estimates only 9 chlor-alkali plants in the U.S. still use asbestos diaphragms as there are other alternatives, accounting for only 33% of all chlor-alkali plants. 

EPA was not able to quantify the scope of asbestos use in the brake and gasket industries.

EPA’s rule would also include targeted disposal and recordkeeping requirements that would take effect 180 days after the effective date.

Other Upcoming Asbestos Studies by EPA

As part of the Toxic Substances Control Act (TSCA), asbestos was one of 10 chemical substances on a list to be studied and put through a risk evaluation.  EPA decided to do the evaluation in two parts. 

The first part was the risk evaluation for chrysotile, leading to this ruling on banning it. 

In Part 2, EPA will be looking at a number of other issues related to asbestos, including:

  • Different types of asbestos (amphibole-type asbestos such as crocidolite, amosite, tremolite)
  • Legacy uses of asbestos in commercial, industrial and consumer products
  • Disposal phases
  • Occupational exposure
  • Consumer and bystander exposure
  • General population exposure
  • Potential exposed or susceptible subpopulations (children, workers, smokers, others)

In addition, EPA will be evaluating asbestos-containing talc and vermiculite.  This does not apply to talc used in makeup, but talc that’s imported and used in industrial, commercial and consumer products such as filler/putty, crayons with talc-containing asbestos and toy crime scene kits with talc-containing asbestos. 

EPA will be looking at the import of this talc, distribution of it in commerce and its disposal.  Vermiculite was used in building materials, and 70% of all vermiculite sold in the U.S. was extracted from an open pit mine in Libby, Montana until it closed in 1990.

EPA is accepting public comments on the proposed rule for chrysotile asbestos  at https://www.regulations.gov/.

Facility Asbestos Operations & Maintenance Plans

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OSHA Updates 14 Standards

OSHA Updates 14 Standards

As part of the President’s Executive Order for agencies to improve regulations and conduct regulatory reviews, OSHA has been working on reviewing their standards to remove outdated, duplicate, and inconsistent parts of their standards.  The latest round of reviews and updates, called Standards Improvement Project – Phase IV, will go into effect on July 15, 2019 and it updates 14 different OSHA standards at a projected $6.1 million/year savings. 

Updates range from clarifications and deletions, to updates for current technology, to good news for cats.

Social Security Numbers
29 CFR Parts 1910, 1915, 1926

OSHA is eliminating the requirement to collect worker social security numbers in 19 of its standards.  Any social security numbers already collected on previous forms can remain on those forms, and if employers want to continue to collect numbers, they may do so.


Medical Services and First Aid
29 CFR 1926.50

Current standards require posting of physician, hospital and ambulance phone numbers where 911 service is not available.  At the time, 911 was a relatively new concept, but many of today’s 911 services for landlines can pinpoint the caller’s location.  If your area has landline auto-location for 911, you no longer have to post the additional information.

However, the auto-location feature isn’t always available for cell phones in remote locations.  The new rule requires employers, in areas where 911 auto-location for wireless phones is not available, to post the latitude and longitude of the current location in a conspicuous place so that emergency services may locate the worksite.  Employers are also to ensure that the communication system they are relying on to use to report an emergency is working and is effective.  


Medical Surveillance Requirements
29 CFR part 1910, subpart Z

Employers will no longer be required to conduct periodic chest x-rays of their employees for lung cancer purposes.  This is a requirement in asbestos, cadmium, coke emissions, inorganic arsenic, and acrylonitrile standards.  Medical data has been found that periodic x-rays don’t make much of a difference in reducing lung cancer.  However, periodic x-rays are still required for asbestosis determinations, and initial baseline x-rays are still required as well.  Digital radiographs will be allowed as well as different sizes of x-ray films.


Occupational Hearing Loss
29 CFR 1904.10

The recordkeeping rule now clarifies physicians must use the standards of 29 CFR 1904.05 to make the determination if a hearing loss is work-related.  Previously, employers have been able to not record hearing loss as an injury when a physician determines the loss was NOT work related. However, no guidance was given for physicians in that determination.  A cross-reference from 1904.05 will be added to 1904.10 to help make that determination.  Get more info on iSi’s work area noise surveys & sampling.


Cotton Dust
29 CFR 1910.1043

The technology of pulmonary function testing has come a long way since 1978. OSHA will be updating the pulmonary function testing guidelines.  More info on iSi’s worker sampling protocol development.


29 CFR 1926.104

OSHA is changing the minimum breaking strength of lifelines from 5,400 lbs. to 5,000 lbs. to align with the most recent ANSI/ASSE standards.


Process Safety Management (PSM)
29 CFR 1926.64

Rather than having a separate PSM standard for construction, this standard will now reference the general industry standard 1910.119.


Coke Oven Emissions
29 CFR 1926.1129

OSHA has determined coke oven emissions does pertain to construction work, and will be deleting the standard.  Any construction worker exposures to coke oven emissions will fall under the General Duty Clause.


Signs, Signals and Barriers
29 CFR 1926, Subpart G

Employers will now be required to comply with the 2009 version of the Manual on Uniform Traffic Control Devices to better align with DOT’s requirements.  OSHA feels the newest version adds better safety controls. These included high visibility safety apparel, stop/slow signage (not just hand signals), the use of automated flagger assistance devices, and crashworthy temporary traffic barriers and lane channelization. Confusing language will be removed from the traffic signs section, and the barricades and definitions sections will be deleted because they’re duplicates.


Materials Handling and Storage
29 CFR 1926.250

Currently, posting of maximum safe load limits of floors in storage areas is required.  However, in residential buildings, heavy materials are not placed in areas above floor or slab on grade.  Thus, this requirement no longer applies to construction of “single-family residential structures and wood-framed multi-family residential structures.”  iSi’s safety assistance services


Underground Construction
29 CFR 1926.800

Mobile diesel-powered equipment used in “other than gassy operations” must now meet the most current MSHA requirements of 30 CFR Part 7, Subpart E.


Occupational Health and Environmental Controls, Gases, Vapors, Fumes, Dusts and Mists
29 CFR 1926.55

“Threshold limit values” will change to “permissible exposure limits” and references to ACGIH standards will be removed.  OSHA is also cleaning up phrases such as “shall be avoided”, deleting the terms “inhalation, ingestion, skin absorption, or contact”, will change Appendix A to Tables 1 and 2, and will correct inconsistent and errant table headings, footnotes, cross references and asterisks.  iSi’s workplace sampling program development services


29 CFR 1915.80

Feral cats will no longer be considered vermin and thus, no longer a health and safety hazard.


Rollover Protective Structures, Overhead Protection
29 CFR 1926, Subpart W

OSHA is removing test procedures and performance requirements and replacing them with the current standards of ISO 3471: 2008.  They will also be making some other technical error revisions.


 For more details about each change, read the Federal Register notice here.

iSi can help you determine which of these safety and industrial hygiene issues will affect you — Contact us today!

Frequently Asked Asbestos Questions – A Free Webinar

Frequently Asked Asbestos Questions – A Free Webinar

asbestos frequently asked questions

As a long-time asbestos abatement, survey, inspection, sampling and training firm, we get a lot of questions about asbestos.

In this webinar we will be covering the questions we are asked the most, from who regulates asbestos to where it can be found, to training and licensing requirements, how the NESHAP regulations affects rules and more!

What questions do you have? Join us on Tuesday, December 11 at 1:30 pm CST.  There is no charge to attend, but space is limited!  Register Here

Register Today!

Register here for our free asbestos webinar on December 11!

iSi’s Industrial Services team can help you with your asbestos questions and issues — Contact us today!

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