Document VjoOwd37wVDG7Gy0B6Og2Mx6w

Organization Resources Counselors, Inc. January 28, 1992 1910 Sunderland Place, N.W. Washington, D.C. 20036 Tel: 202-293-2980 Fax: 202-293-2915 Patricia K. Clark Director Directorate of Compliance Programs U.S. Department of Labor - OSHA 200 Constitution Avenue Washington D.C. 20210 Dear Ms. Clark: In the last several months ORC has received a number of questions regarding the necessity to label asbestos containing materials (ACM). ORC's understanding of the labeling requirements of OSHA's Asbestos Standard are as follow: 1. Material that has been installed after July 21, 1986 must be labeled if it is known to contain asbestos; 2. Material installed prior to July 21, 1986 where the employer has knowledge that asbestos is present, must be labeled; 3. Where repairs or renovation of more than a minor nature are planned, and it is possible that ACM may be present, the employer must determine the presence or absence of asbestos, prior to the date the work is started, and if asbestos is present, label in accordance with the Asbestos Standard; 4. The employer is not required to determine the presence or absence of asbestos in undisturbed materials that were installed prior to July 21, 1986. Question l: Are the four above assumptions stated correctly? In many facilities constructed prior to July 21, 1986, some asbestos is known, or assumed to be present, but the employer is not aware of all its exact locations. To pro-actively determine HWCPI0000302 Patricia K. Clark January 28, 1992 Page Two the presence or absence of asbestos in all potential locations in a facility would be prohibitively expensive. In such circumstances, many companies have adopted policies similar to the following: A. All insulation and gaskets in the facility are considered to contain asbestos; B. All employees are trained that they must treat all insulation and gaskets as ACM, and that they are not to be disturbed; C. Maintenance and production personnel who must handle ACM are trained to recognize it, and work safely around it; D. Specific standard operating procedures are developed for working around ACM and their use required; E. Work that may disturb potential ACM, may only be performed by those employees who have received appropriate training and have a permit; F. Signs are posted at the entrance and throughout the facility warning that all insulation etc. is presumed to contain asbestos, and only those with appropriate training and a permit may disturb it. Question 2: Would OSHA consider a facility following the procedures described above to be in compliance with the labeling requirements of its Asbestos Standard? Question 3: May an employer use a system, such as a blue colored band around a pipe, to indicate the presence of ACM rather than a sign, so long as its meaning is taught in training and safety meetings? We would appreciate your assistance in finding answers to these questions. Cordially, Darrell K. Mattheis DKM:mv