Comment submitted by Masek Consulting Services, Inc.

First, thank you for this action! I am an asbestos expert, author of an asbestos text book, long-time owner of an environmental consulting company, and teacher of asbestos training classes. My book is Illustrated Practical Asbestos For Consultants, Contractors, Property Managers & Regulators or (same book, different cover) Asbestos For Consultants Owners & Managers. Kindly contact me for more information or assistance with any of these comments, organized as in your request: (A) Demolitions and renovations disturbing asbestos-containing materials 3) How does the prevalence and quantity of asbestos-containing materials in single-family residences and multi-family residences with four or fewer dwelling units compare with that in residences with more than four dwelling units and non-residential buildings? There are no differences. My company has inspected thousands and thousands of buildings of all types and we see no differences. I’ve also communicated with other consultants at conventions and while teaching asbestos refresher training classes, and have heard nothing to indicate that differences exist. (B) Individuals disturbing asbestos-containing materials not covered by OSHA 6) How likely is it that self-employed contractors have taken training in dealing with asbestos-containing materials? What type of asbestos training (awareness training, operations and maintenance training, abatement worker training, etc.) may they have taken? It is highly unlikely. The number of people who attend asbestos training classes taught by accredited training providers is a tiny fraction of the number of people performing repair, renovation, anddemolition work. Data on the number of people who attend asbestos classes is readily available from the relatively small number of training providers which exist. All asbestos training has annual refresher requirements. Essentially all of those attending the worker and supervisor training classes are employed by asbestos abatement contractors, except for people such as water utility company employees who attend just the asbestos-cement pipe classes. There is far less demand for the two hour asbestos awareness training classes. Recommendations: 1)We should require that all freshman high school students have two hour asbestos awareness training. Two hours out of four years is a trivial amount of time, but it would make a world of difference in our ability to avoid asbestos diseases and deaths. 2)Residences with four or fewer units should not be excluded from the requirements which apply to residential buildings with more than four units, as there is are no differences in the materials used to build and finish them. 3)City and County departments which issue building permits should be required to demand that asbestos surveys be provided with the applications for work on all buildings built before 1990.