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:
- The product is installed on a residential roof, and
- 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
