1926.1101(g)(4): Class I Asbestos Work Requirements
All Class I asbestos work, including the control system, must be supervised by a competent person. For larger removals of thermal system insulation or surfacing material, jobs without a negative exposure assessment, or when employees work next to the regulated area, employers must use critical barriers over openings, or another barrier method verified by perimeter surveillance and monitoring, to keep airborne asbestos from leaving the regulated area.
Key takeaways
- 1926.1101(g)(4) is part of OSHA's construction standards (29 CFR Part 1926, Subpart Z).
- OSHA cited it 15 times in the last 3 years, in 14 inspections, with $13,140 in current penalties.
- Most citations: IL (4), MI (4), NY (2).
- Related part: 1926.1101(g) Methods of compliance (297 citations).
- Free 5-minute toolbox talk for your crew below.
In this article
What this rule covers
29 CFR 1926.1101(g)(4) ("Class I Requirements") is one requirement inside 1926.1101 Asbestos, an OSHA construction standard (Part 1926, Subpart Z). It includes 8 sub-paragraphs. The official text below is copied word for word from the Electronic Code of Federal Regulations (eCFR). The numbers, injury cases and training on this page show how OSHA enforces it on real job sites.
Official text
(4) Class I Requirements. In addition to the provisions of paragraphs (g) (1) and (2) of this section, the following engineering controls and work practices and procedures shall be used. 15 citations
(i) All Class I work, including the installation and operation of the control system shall be supervised by a competent person as defined in paragraph (b) of this section; 7 citations
(ii) For all Class I jobs involving the removal of more than 25 linear or 10 square feet of thermal system insulation or surfacing material; for all other Class I jobs, where the employer cannot produce a negative exposure assessment pursuant to paragraph (f)(2)(iii) of this section, or where employees are working in areas adjacent to the regulated area, while the Class I work is being performed, the employer shall use one of the following methods to ensure that airborne asbestos does not migrate from the regulated area: Open (g)(4)(ii) 6 citations
(A) Critical barriers shall be placed over all the openings to the regulated area, except where activities are performed outdoors; or Open (g)(4)(ii)(a)
(B) The employer shall use another barrier or isolation method which prevents the migration of airborne asbestos from the regulated area, as verified by perimeter area surveillance during each work shift at each boundary of the regulated area, showing no visible asbestos dust; and perimeter area monitoring showing that clearance levels contained in 40 CFR part 763, subpt. E, of the EPA Asbestos in Schools Rule are met, or that perimeter area levels, measured by Phase Contrast Microscopy (PCM) are no more than background levels representing the same area before the asbestos work began. The results of such monitoring shall be made known to the employer no later than 24 hours from the end of the work shift represented by such monitoring. Exception: For work completed outdoors where employees are not working in areas adjacent to the regulated areas, this paragraph (g)(4)(ii) is satisfied when the specific control methods in paragraph (g)(5) of this section are used. Open (g)(4)(ii)(b)
(iii) For all Class I jobs, HVAC systems shall be isolated in the regulated area by sealing with a double layer of 6 mil plastic or the equivalent;
(iv) For all Class I jobs, impermeable dropcloths shall be placed on surfaces beneath all removal activity; 1 citations
(v) For all Class I jobs, all objects within the regulated area shall be covered with impermeable dropcloths or plastic sheeting which is secured by duct tape or an equivalent. 1 citations
(vi) For all Class I jobs where the employer cannot produce a negative exposure assessment, or where exposure monitoring shows that a PEL is exceeded, the employer shall ventilate the regulated area to move contaminated air away from the breathing zone of employees toward a HEPA filtration or collection device.
Source: eCFR, text current as of 2026-10-15. Read all of 1926.1101.
Where and how often it was cited
| Year | Citations |
|---|---|
| 2024 | 3 |
| 2025 | 8 |
| 2026 | 4 |
Top states: IL (4), MI (4), NY (2), MO (2), NV (1)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| EDGE RESTORATION LAS VEGAS, LLC | LAS VEGAS, NV | $4,839 |
| B & R INSULATION, INC. | KANSAS CITY, MO | $3,547 |
| CONCRETE CONSTRUCTION COMPANY | GLEN ELLYN, IL | $2,400 |
| GRAYCO CORPORATION | ROCHESTER, NY | $1,500 |
| 109277 - PREMIERE RESTORATION LLC | MANKATO, MN | $854 |
Free toolbox talk
A 5-minute crew talk on 1926.1101(g)(4), plus alerts when this rule changes. Free.
OSHA interpretation letters
- Glove bag requirements for outdoor removal of intact and non-intact asbestos-containing gaskets under 1926.1101. (2007-11-09)
Related parts of this rule
- 1926.1101(g) Methods of compliance 297 citations
- 1926.1101(g)(1) 105 citations
- 1926.1101(g)(8) Additional Controls for Class II work 71 citations
- 1926.1101(g)(7) Work practices and engineering controls for Class II work 40 citations
- 1926.1101(g)(5) Specific control methods for Class I work 29 citations
- 1926.1101(g)(8)(i) 28 citations
- 1926.1101(g)(7)(i) 25 citations
- 1926.1101(g)(8)(ii) 18 citations
- 1926.1101(g)(1)(ii) 16 citations
- 1926.1101(g)(5)(i) 15 citations
- 1926.1101(g)(8)(iii) 15 citations
- 1926.1101(g)(1)(iii) 13 citations
Get your crew competent
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Frequently asked questions
Who must supervise Class I asbestos work?
A competent person as defined in paragraph (b).
When are critical barriers or other isolation methods required?
For Class I removal of more than 25 linear or 10 square feet of thermal system insulation or surfacing material, for other Class I jobs without a negative exposure assessment, or when employees work in areas adjacent to the regulated area.
How fast must perimeter monitoring results be reported?
No later than 24 hours from the end of the work shift represented by the monitoring.
About this page
Sources
- 29 CFR 1926.1101 (eCFR), text current as of 2026-10-15
- U.S. Department of Labor enforcement data: OSHA inspections, citations and accident records, copied nightly; data as of 2026-10-20
3-year window. Federal OSHA only; state-plan rules are not counted. Plain-language text is a summary, not legal advice; the official text controls. Black Belt Safety is not part of OSHA or the Department of Labor.
