Asbestos Control Program
This domain tests how Montana’s asbestos control program is structured and how a project moves through it: who must be accredited, when a state permit and notification are required, which work-practice and clearance rules apply, and how the department enforces them. Expect questions that mix state program requirements with federal NESHAP thresholds and OSHA worker-protection duties.
Program scope and authority
- The Montana Department of Public Health and Human Services (DPHHS) administers the Asbestos Control Program under MCA Title 50, chapter 78, and ARM Title 37, chapter 68. The program accredits individuals and contractors and authorizes abatement projects.
- “Asbestos-related work” covers abatement, inspection, management planning, project design, and air monitoring; each discipline has its own accreditation.
- Accreditation requires an EPA/AHERA-approved initial course, an application and fee to the department, and annual refresher training. A worker with expired accreditation cannot be counted on the crew.
Permit, notification, and project duties
- A state abatement permit/notification is required before regulated abatement begins; the owner/operator and contractor share duties to file accurately and to update the department if dates or scope change.
- Emergency abatement has a shortened process but still requires notice and documentation.
- Federal NESHAP thresholds-260 linear feet on pipes, 160 square feet on other components, or 35 cubic feet where length or area is not measurable-determine whether NESHAP notification and work standards apply. They do not replace Montana’s permit.
Work practices and closeout
- Negative-pressure containment, HEPA filtration, wet methods, regulated-area signage, and worker protection under OSHA 29 CFR 1926.1101 are core controls.
- Clearance requires visual inspection plus air monitoring by an accredited air monitoring technician; waste must be wetted, bagged, labeled, and manifested to an approved landfill.
Worked example
A contractor will remove 300 square feet of friable ceiling tile in a Montana school. Because 300 exceeds 160 square feet, NESHAP applies, so the project needs NESHAP notification and a Montana permit/notification. The crew must include an accredited supervisor and accredited workers; containment and clearance are required; the owner must have the state authorization before start. Treating it as a “small project” and skipping the state process is wrong.
Traps that cost marks
- Assuming a project below the NESHAP threshold is automatically exempt from Montana accreditation and work-practice rules; check the state definition of abatement.
- Confusing owner/operator duties with contractor duties.
- Letting accreditation or annual refresher training lapse.
- Assuming a local building permit substitutes for the state asbestos permit.