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Installing -Containing Roofing Products


It is perfectly legal to install roofing products containing . In the roofing industry, the only -containing products still available in the United States are some roof coatings, cements and mastics.

The Environmental Protection Agency's requirements, including notification, only apply to projects involving friable -containing roofing materials (ACRM). These products are not considered friable.

As amended by the NRCA Settlement Agreement with the Occupational Safety and Health Administration (OSHA), the OSHA Standard specifically describes procedures for handling roof coatings, cements, mastics and flashings (which together have been called "incidental" roofing materials). As amended, the standard states that building owner notification is required only if:
  1. The product is installed on a residential roof, and
  2. The product is labeled according to the OSHA Standard (29 CFR 1926.1101. (g)(11)(v)).
The standard's labeling provision requires products containing one percent or more by weight to bear a label with a specific legend. However, the standard provides an exemption for products in which the " fibers have been modified by a bonding agent, coating, binder or other material, provided the manufacturer can demonstrate that, during any reasonable foreseeable use, handling, storage, disposal, processing or transportation, no airborne concentrations of fibers in excess of the permissible exposure limit and/or excursion limit be released." (Id. 1926.1101(k)(8)(vi)(A)). Representatives of the roof coatings manufacturing industry have assured NRCA that they are not aware of any manufacturer selling in the United States a roof coating, cement or mastic that is required to be labeled in accordance with the OSHA labeling requirements just described, and NRCA has no information to the contrary. In addition, NRCA is not aware of any manufacturer selling -containing membrane flashing material in the United States.

NRCA does recommend that even through notification may not be required, roofing contractors consider discussing with building owners the installation of any -containing products, as the most conservative and prudent course of action. Contractors with questions are encouraged to call NRCA or the manufacturer of the roof coating, cement or mastic they intend to use.

National Roofing Contractor's Association Information Article

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