Do my roofers need training?

So we are discussing employee training. Then we'll set aside the NESHAP standard and all of its distinctions between Catagory1, and Catagory 2, as well as the difference between demolition and renovation and when, how and to whom notify. Oh yea, and NESHAP's "no visible emission" rule.

That aside OSHA regulates Asbestos training for the roofing worker under OSHA's 29 CRF 1926.1101 (1101) The requirement for training depends on whether the roofing material becomes friable or is rendered non-intact (same difference) as a result of the forces expected to act upon the asbestos containing material (ACM) while removing it.

Let's look at it closer. OSHA/101 Categorizes roofing work (when regulated RACM) as Class II. (¶ 1926.1101 (b)).

OSHA/1101 establishes the requirement of a regulated area (¶ 1926.1101 (e)) and exposure assessment and monitoring (¶ 1926.1101 (f)). That is unless you have a negative exposure assessment (NEA) (¶ 1926.1101 (f) (2)(iii)).

Periodic monitoring is required under (¶ 1926.1101 (f) (3)(i)).

Methods of compliance include: HEPA vacuuming. For roofing just when a roof cutter is used. Wet methods during all phases of removal except where electrical hazard is created, in roofing wet unless it is not feasable or will create a safety hazard. (¶ 1926.1101 (g) ((1)).

Prompt clean-up of debris in leak tight containers, except in roofing where removed ACM can not b dropped or thrown to the ground but must be carried or passed to the ground by hand or transfered to the ground via covered dust tight chute , crane of hoist.(¶ 1926.1101 (g) (8)(ii)). Non-intact ACM must be ;owered to the ground as soon as practical but no later than the end of the shft. ACM remaining in wait till shift end must be kept wet OR placed in an impermeable wastebag OR wrapped in plastic sheeting.(¶ 1926.1101 (g) (8)(ii) (E)).

Once on the ground, any unwrapped ACM must be transfered to a closed receptacle in a manner that no dust is dispersed (¶ 1926.1101 (g) (8)(ii) (F)).