At a glance
- Construction: 29 CFR 1926.1101, including the owner's determination (k)(2)(i), the exposure limit (c)(1) and training (k)(9)(i). General industry: 29 CFR 1910.1001.
- About 5 minutes: read the script out loud, then ask the three questions.
- FY2025 citations: 29 CFR 1926.1101, 778 (407 at construction sites); 29 CFR 1910.1001, 188 (12 at construction sites).
- Free PDF: the script, the questions, the rule and a 20-line sign-in sheet. No account, no email.
Read this to your crew
Today's talk is about asbestos, a hazard you cannot see while you are making it. Intact in a wall or a pipe wrap, it stays put. Cut it, drill it, sand it or tear it out, and it sends fibers into the air that lodge in the lungs. The diseases it causes, asbestosis, lung cancer and mesothelioma, can show up many years later, long after the job is forgotten.
Where does it hide? Older buildings, mostly: pipe and boiler insulation, sprayed or troweled ceiling and wall coatings, floor tiles and the mastic under them, roofing, siding and some joint compounds. Thermal system insulation and surfacing material in buildings constructed no later than 1980 is presumed asbestos-containing material (29 CFR 1926.1101(b)).
So before we cut into an old building, we ask: has it been checked? The building owner determines what is there, where, and how much (29 CFR 1926.1101(k)(2)(i)), and we look at that information before work starts. If something looks like insulation, a sprayed coating or old flooring and it is not covered, we treat it as asbestos until we know otherwise.
If you find suspect material you did not expect, stop. Do not break it to get a better look. Keep people out of the area, tell me, and we get it sampled. Stopping costs us an hour; breathing it costs far more.
Removing or repairing asbestos material is work for trained people with the right controls: wet methods, enclosures, HEPA vacuums and respirators. Each employee who does that work, or who is likely to be exposed above the limit, is trained at no cost to them (29 CFR 1926.1101(k)(9)(i)). If you have not had that training, the material is not yours to touch.
Small jobs count. Drilling through a ceiling that contains asbestos, pulling up a few asbestos floor tiles or cleaning up debris from asbestos work all fall under the standard; cleanup of dust and debris from removal work is Class IV work (29 CFR 1926.1101(b)). Do not dry sweep it or blow it off with compressed air; that is how fibers spread.
Three questions for the crew
- Which materials on this job could contain asbestos, and has the owner's information covered them?
Listen for: Pipe insulation, ceilings, flooring, roofing, siding. Know where the owner's information is kept. - What do you do if you uncover material that might be asbestos and is not covered?
Listen for: Stop, leave it intact, keep people out, tell the supervisor, get it sampled. - Who on this crew is trained for asbestos work, and what is off limits to everyone else?
Listen for: The names of trained workers, if any. Everyone else leaves suspect material alone.
What are OSHA's rules before asbestos work starts?
Before work subject to the construction asbestos standard begins, building and facility owners determine the presence, location and quantity of asbestos-containing material (ACM) and presumed asbestos-containing material (PACM) at the work site (29 CFR 1926.1101(k)(2)(i)).
PACM is thermal system insulation and surfacing material found in buildings constructed no later than 1980 (29 CFR 1926.1101(b)).
No employee is exposed to an airborne concentration of asbestos above 0.1 fiber per cubic centimeter of air as an 8-hour time-weighted average (29 CFR 1926.1101(c)(1)); general industry has the same limit (29 CFR 1910.1001(c)(1)).
Each employee likely to be exposed above a permissible exposure limit, and each employee who performs Class I through IV asbestos work, is trained at no cost to the employee (29 CFR 1926.1101(k)(9)(i)).
The paragraphs, word for word:
“(2) Duties of building and facility owners. (i) Before work subject to this standard is begun, building and facility owners shall determine the presence, location, and quantity of ACM and/or PACM at the work site pursuant to paragraph (k)(1)(i) of this section.”
“Presumed Asbestos Containing Material means thermal system insulation and surfacing material found in buildings constructed no later than 1980.”
“(c) Permissible exposure limits (PELS)—(1) Time-weighted average limit (TWA). The employer shall ensure that no employee is exposed to an airborne concentration of asbestos in excess of 0.1 fiber per cubic centimeter of air as an eight (8) hour time-weighted average (TWA), as determined by the method prescribed in appendix A to this section, or by an equivalent method.”
“(9) Employee Information and Training. (i) The employer shall train each employee who is likely to be exposed in excess of a PEL, and each employee who performs Class I through IV asbestos operations, in accordance with the requirements of this section. Such training shall be conducted at no cost to the employee. The employer shall institute a training program and ensure employee participation in the program.”
How often did OSHA cite these rules in FY2025?
| Standard | Construction sites | Other industries | All FY2025 citations |
|---|---|---|---|
| 29 CFR 1926.1101Asbestos, construction | 407 | 371 | 778 |
| 29 CFR 1910.1001Asbestos, general industry | 12 | 176 | 188 |
Citation items under 29 CFR issued Oct 1, 2024 to Sep 30, 2025, at federal and State Plan inspections, counted by HazComFast on U.S. Department of Labor enforcement data (extracted Oct 13, 2026). Construction means an inspection whose NAICS code starts with 23. The counts describe inspected establishments, not every employer.
Which asbestos work class is it?
The construction standard sorts asbestos work into four classes (29 CFR 1926.1101(b)).
| Class | What it covers | Jobsite example |
|---|---|---|
| Class I | Removal of thermal system insulation and surfacing ACM and PACM | Stripping old pipe insulation |
| Class II | Removal of ACM that is not thermal system insulation or surfacing material | Taking out asbestos floor tile or roofing |
| Class III | Repair and maintenance where ACM, including TSI and surfacing ACM and PACM, is likely to be disturbed | Cutting into an asbestos ceiling to run a pipe |
| Class IV | Maintenance and custodial work that contacts but does not disturb ACM or PACM, and cleanup of dust, waste and debris from Class I, II and III work | Cleaning up debris after removal work |