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LSPA Soliciting Comments on Revised Asbestos Regulations

The Massachusetts Department of Labor Standards (DLS) has issued a revised final version of 454 CMR 28.00: The Removal, Containment, Maintenance, or Encapsulation of Asbestos, and will hold a second live video/telephone access public hearing on February 4, 2021 at 1:00 PM. 

This notice of public hearing provides more detailed information including the Webex link for connecting to the hearing and details about how to submit written comments.  All written testimony must be received by Monday, February 8, 2021 at 5:00 PM. 

A redline version of the revised final regulations can be downloaded here.

The LSPA's Regulations Committee is reviewing these regulations on a quick turnaround, and comparing them to the comments previously submitted by the LSPA in October 2020.  
 
If you have comments to contribute, please send them to [email protected] by no later than 5:00 PM Tuesday, February 2, 2021.  We suggest that you also submit your comments to DLS separately since we cannot guarantee that they will be included in the LSPA's submittal.
 
Thank you.
 
Regulations Committee Co-Chairs
Kate Dilawari, LSP, Haley & Aldrich
Denise Kmetzo, DABT, Collaborative Risk Solutions LLC

LSPA Comments on Asbestos Regulation 454 CMR 28.00

On very short turnaround, the LSPA learned of and submitted comments to the MA Department of Labor Standards on their Draft Asbestos Regulation 454 CMR 28.00 regarding the removal, containment, maintenance, or encapsulation of asbestos. Our main concern related to ensuring that LSPs do not also have to be licensed Asbestos Project Designers in order to carry out their MCP work, including signing "Soil Characterization and Management Plans," and conducting "asbestos risk assessment and asbestos management planning."  Read the LSPA's letter

Many thanks to the LSPA's Regulations Committee for spearheading this effort!