PPS Training Requirements: Asbestos

OSHA categorizes asbestos abatement into 4 classes of increasingly hazardous types of construction activity. Each classification is matched with increasingly stringent control requirements. Most abatement work at UWM involves Class III or IV work. Larger or more complex projects are Class I or II. Specialized training is required for these activities:

  • Class I/Class II Abatement:

    Large scale abatement work at UWM is currently performed by outside vendors. Forty-hour (40) training as defined under the EPA Model Accreditation Plan is required for this type of abatement. Annual refresher training is required thereafter. All workers must be licensed by the state.

    Examples of Class I or II work includes large scale insulation or surfacing removal (Class I), and large scale floor tile or roofing jobs (Class II). Class I projects are normally more complex than Class III projects and generally take longer than one day to complete. Workers performing all Class I abatement and most Class II abatement must wear a respirator and must be included in the employer's Respiratory Protection Program . This program involves specific training requirements, fit-testing, annual medical surveillance, periodic air/exposure monitoring, etc.)

  • Class III Abatement:

    Nearly all Class III abatement work at UWM is currently performed by outside vendors. Some Class III work, especially emergency abatement, is performed by trained and authorized UWM personnel.

    OSHA has determined that separate regulatory treatment of repair and maintenance operations will not be limited by arbitrary duration and amount-of-material-disturbed criteria. Instead, Class III projects, formerly known as operations and maintenance (O&M) projects, or small-scale/short duration projects, are defined as repair and maintenance operations which may involve intentional disturbance of ACM, including presumed asbestos containing material (PACM). The major difference between the newly revised repair and maintenance definitions is that the amount of material and/or the time the operation takes are no longer the criteria for inclusion in the class. More information regarding the interpretation of Class III work can be found in the August 10, 1994 Federal Register, page 41006.

    As a rule-of-thumb for UWM purposes, Class III work (rather than Class I or II work), shall be no more than the amount that can be contained in a standard size glove bag or waste bag. Moreover, Class III projects are normally simple projects performed in less than one day, resulting in minimal, if any, exposure. Projects not meeting this general criteria shall be considered Class I or II abatement.

    Physical Plant Services or outside vendors can provide the initial training for UWM employees performing Class III work. Annual refresher training is required thereafter. Workers performing Class III abatement must be able to wear a respirator and must be included in UWM's Respiratory Protection Program (e.g., training, fit-testing, annual medical surveillance, periodic air/exposure monitoring, etc.).

    For in-house maintenance, two Physical Plant Services Carpentry Shop staff members and one Mechanical Shop staff member perform select Class III work. This repair generally entails emergency abatement on critical mechanical systems or replacement of damaged vinyl asbestos floor tile (VAT) or transite board where minimal, if any, exposure is expected.

  • Class IV Work:

    Class IV abatement work is performed by trained and authorized UWM personnel or outside vendors. Two-hour awareness training is required for Class IV work. Examples of this work include floor maintenance, or maintenace work in areas with ACM. Physical Plant Services provides initial training about twice a year. Thereafter, refresher training is provided about once a year. Generally, respirators are not required for most anticipated Class IV projects.

  • Unclassified Operations:

    Work operations conducted in areas where the asbestos or asbestos product is below one percent. See Class I, II, III, and IV work categories. For additional information, see OSHA Interpretation: Materials Containing Less Than 1% Asbestos, 04/17/1997.

Milwaukee-area Asbestos/Lead Training Providers:

There are several DHFS approved asbestos/lead vendors in the Milwaukee area. Please see the Yellow Pages, under "Asbestos Consultants".

Return to Asbestos Management Program Home Page

Updated August 14, 2007