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- U.S. Department of Labor
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- Occupational Safety & Health Administration
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- www.osha.gov
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- Standard Interpretations
- 04/28/1997 - Sheetrock and joint compound.
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- Standard Interpretations - Table of Contents
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- • Standard Number:
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- 1910.1001; 1915; 1926.1101
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- OSHA requirements are set by statute, standards and
regulations. Our interpretation letters explain these requirements
and how they apply to particular circumstances, but they cannot
create additional employer obligations. This letter constitutes
OSHA's interpretation of the requirements discussed. Note that our
enforcement guidance may be affected by changes to OSHA rules.
Also, from time to time we update our guidance in response to new
information. To keep apprised of such developments, you can
consult OSHA's website at http://www.osha.gov.
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- April 28, 1997
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- Mr. Gary Thibodeaux
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- National Service Cleaning Corp.
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- 1201 Childers
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- Orange, Texas 77630
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- Dear Mr. Thibodeaux:
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- This is in response to your letter of March 31, concerning
sheetrock and joint compound.
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- You ask whether the Occupational Safety and Health
Administration (OSHA) considers sheetrock and joint compound to be
a composite material that may be analyzed for asbestos content by
collecting composite bulk samples. By interpretation of the
definition of asbestos containing material (ACM) presented at 29
CFR 1910.1001(b), [29 CFR 1915.1001], and 29 CFR
1926.1101(b); OSHA regards sheetrock and joint compound as
separate materials. Each of these materials that may contain
asbestos must be analyzed separately for their asbestos
content.
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- You also asked what class of asbestos work would be involved
if the only material containing greater than 1% asbestos is joint
compound. We presume you are referring to the removal of interior
wall shells constructed with sheetrock panels. If that is the
case, the removal operation is Class II asbestos work. OSHA does
not consider joint compound to be surfacing material. As indicated
on page 41032 of Federal Register, Vol. 59, No. 153, Wednesday,
August 10, 1994, joint compound is finishing material. Note that
if surfacing material containing more than 1% asbestos was applied
to the sheetrock panels, removal of the panels would be considered
Class I asbestos work.
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- We appreciate the opportunity to provide this clarifying
information. If you have further questions please contact the
[Office of Health Enforcement at (202) 693-2190].
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- Sincerely,
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- Stephen Mallinger, Acting Director
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- [Office of Health Enforcement]
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- [Corrected 6/2/2005]
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- March 31, 1997
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- U.S. Dept. Of Labor
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- Occupational Safety & Health
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- Office Of Technical Support, Rm N3653
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- Constitution Avenue NW
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- Washington, D.C. 20210
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- Re: Clarification Of Asbestos Standard 29 CFR 1926.1101
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- Question No. 1: Does OSHA consider sheetrock and joint
compound to be a composite material and recognize composite bulk
sample analysis of such material in rebutting the designation of
PACM?
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- Question No. 2: If the answer to question (1) is no, what
"class" of work would joint compound be categorized if it's the
only material containing asbestos in quantities greater than
1%?
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- Please send reply to my attention at the address below. Thank
you for your attention in this matter.
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- Sincerely, National Service Cleaning Corp.
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- Gary Thibodeaux
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- Regional Mgr. Safety and Health
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- Standard Interpretations - Table of Contents
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