Asbestos Awareness Training and the O&M Program: What Building Owners and Workers Need to Know

Asbestos didn’t disappear when the EPA started restricting it in the late 1970s. It’s still in tens of millions of buildings across the United States, and it stays there until someone disturbs it. That’s where most of the risk lives now, not in new construction but in maintenance, renovation, and demolition of buildings put up before 1980.

The approach to managing asbestos exposure depends almost entirely on what kind of work is happening and who’s doing it. Sweeping a hallway in a building with asbestos floor tiles is not the same risk as cutting into pipe insulation. The regulatory system reflects that distinction, and so does the training required for each type of worker.

Where Asbestos Still Shows Up

Asbestos was used in building materials for its fire resistance, durability, and insulating properties. Common asbestos-containing materials (ACM) in pre-1980 buildings include floor tiles and the adhesive under them, ceiling tiles, pipe and duct insulation, spray-applied fireproofing on structural steel, roofing felt and shingles, drywall joint compound, and textured paints.

The critical point: ACM that’s in good condition and not likely to be disturbed is generally safer left in place than removed. Removal itself releases fibers. An intact floor tile in a storage room poses little risk. That same tile being drilled into, broken apart, or abraded during a renovation is a different situation entirely.

Three Regulatory Programs

Three overlapping regulatory frameworks govern asbestos. Knowing which one applies to a given situation is the starting point for compliance.

OSHA’s standards cover occupational exposure during O&M activities and construction work. 29 CFR 1910.1001 applies to general industry operations and maintenance. 29 CFR 1926.1101 applies to construction, renovation, and demolition work involving asbestos.

EPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) for asbestos governs renovation and demolition of facilities that contain regulated ACM, regardless of whether workers are involved. NESHAP requires notification to the state or EPA before demolition and before renovation that would disturb more than certain threshold amounts of ACM. This applies to building owners and project operators, not just the workers on site.

State regulations add another layer. Many states have their own asbestos programs that go beyond federal minimums, covering licensing for asbestos inspectors and contractors, notification requirements, and training standards. States with OSHA-approved state plans administer their own asbestos regulations, which must be at least as protective as federal OSHA standards. Always check your state’s requirements in addition to federal rules.

The Four Classes of Asbestos Work

The construction standard, 29 CFR 1926.1101, defines four classes of asbestos work. The class determines the hazard level, required controls, and training.

Class I is the most hazardous. It involves removal of thermal system insulation (TSI), the insulation around pipes, boilers, tanks, and similar equipment, and surfacing ACM, which includes spray-applied materials and other materials applied to surfaces for fireproofing or acoustics. Class I work must be performed by accredited asbestos abatement contractors.

Class II covers removal of other types of ACM that aren’t thermal system insulation or surfacing material. Floor tiles, roofing materials, siding, and similar items fall here. It’s less hazardous than Class I but still requires accredited workers and specific controls.

Class III is repair and maintenance work that may disturb ACM or presumed asbestos-containing material (PACM). A maintenance worker cutting into a wall in a pre-1980 building to access plumbing, or replacing ceiling tiles in a building where the tiles haven’t been tested, is likely doing Class III work. Class III workers need at least 16 hours of O&M training.

Class IV is custodial work in areas where ACM or PACM is present. These workers don’t intentionally disturb asbestos but may clean up debris from ACM or work near it. Two hours of asbestos awareness training is the minimum for Class IV workers.

Operations and Maintenance Programs

The O&M program is the core management tool for building owners who have ACM in place. The underlying principle: managed ACM in good condition poses less risk than disturbed ACM, and removal creates hazards of its own. An O&M program formalizes the decision to keep asbestos in place while protecting workers who may encounter it.

A complete O&M program under 29 CFR 1910.1001 includes several elements.

An ACM inventory is the foundation. It lists every known or suspected asbestos-containing material in the building, its location, its condition (friable or non-friable, good condition or damaged), and whether it’s been sampled and analyzed. This inventory can’t be completed by guessing. It requires sampling by a qualified inspector and laboratory analysis, or a qualified inspector can designate materials as PACM without sampling, which means they’re treated as asbestos-containing until proven otherwise.

Periodic inspections check the condition of ACM at regular intervals. Damaged, deteriorating, or friable materials require a response action. The program must define what response actions look like, including repair with encapsulant, enclosure, or removal by an accredited contractor.

Record keeping ties the program together. Work orders for any activity near ACM, inspection records, training records, and air monitoring results all belong in the O&M file.

Worker training is an ongoing requirement. Everyone who may encounter ACM during normal duties needs training at a level appropriate for their class of work.

Training Requirements by Work Class

The 2-hour asbestos awareness training required for Class IV workers covers what asbestos is and where it’s found, the health effects of exposure, the difference between ACM and PACM, how to recognize damaged ACM, proper work practices to avoid disturbing ACM, and who to notify if they find potentially damaged material. This training is often delivered as part of a new employee safety orientation program for facilities staff.

The 16-hour O&M training required for Class III workers goes significantly deeper. It covers safe work practices for working in areas with ACM, how to use wet methods and HEPA vacuums, proper respirator selection and use under OSHA 1910.134, how to set up and use glove bags, and regulatory requirements. Workers handling O&M activities in older buildings should complete this before they start, not after an incident.

Class I and II workers need accredited training through state-approved or EPA-approved programs. The hours required vary by class and state, but they’re substantially more involved than O&M training.

OSHA Exposure Limits

The OSHA PEL for asbestos is 0.1 fibers per cubic centimeter (f/cc) as an 8-hour TWA. The action level is also 0.1 f/cc. Once workers are exposed at or above the action level for 30 or more days per year, exposure monitoring, respiratory protection, and medical surveillance requirements apply.

For Class I and II work, engineering controls and PPE requirements are defined by the standard and apply regardless of measured exposure levels. The hazard controls are mandatory, not triggered by monitoring results.

AHERA and Schools

Schools are covered by a separate EPA program, AHERA, the Asbestos Hazard Emergency Response Act. AHERA requires K-12 schools to have an initial inspection by an accredited asbestos inspector, a written management plan developed by an accredited management planner, periodic surveillance every six months, and a three-year re-inspection by an accredited inspector. Each school’s management plan must be on file and available to parents and staff.

AHERA does not cover commercial office buildings, apartments, or most other non-school facilities at the federal level. Some states have extended similar requirements more broadly. Check your state’s program.

Hiring a Licensed Contractor

For Class I and II work, including any pre-renovation or pre-demolition ACM removal, hire an accredited contractor. Don’t rely on a general contractor’s assurance that they can handle it. Ask for proof of state accreditation, evidence of an active asbestos liability insurance policy, and a copy of their written safety program.

Before any renovation or demolition in a pre-1980 building, have a qualified asbestos inspector conduct a thorough survey. The survey results determine whether NESHAP notification is required, whether Class I or II abatement must precede the work, and what controls are needed for the construction crew. Skipping this step doesn’t eliminate the hazard. It just means the workers and the building owner both face it blind.

If you manage a pre-1980 building and haven’t had a formal asbestos survey done, assume ACM is present until a qualified inspector says otherwise. That’s not overcaution. It’s the legally defensible starting point, and it protects your workers from hazards they can’t see.

Sources: OSHA - Asbestos Standards 29 CFR 1910.1001 and 1926.1101 and EPA - Asbestos