I work for an independently owned manufacturing facility in the state of Virginia.  My job is the Asbestos and Lead Coordinator for the site, with my main priorty being the awareness and protection of our site employees from exposure to asbestos and lead.  I hold a license as an asbestos supervisor, lead supervisor, lead project designer, and lead inspector.  I also have attended the accredited training as an asbestos inspector, asbestos project monitor, and lead risk assessor.  My comment is why is the regulation different in regard to me performing asbestos project monitor work on my site as long as I have the accredited training, and am only performing such work on our property?  Page 2 of the regulations has the following footnote:  *Employees who conduct asbestos response actions, inspections, prepare management plans or project designs for their employer, on property owned or leased by the employer, are exempt from Virginia asbestos licensure; however, they are required to meet all OSHA and EPA training requirements.  I was wondering if leaving project monitor work may have just been an oversight when this was written, and could possibly be included?  We employ an independent contractor to perform our abatement work, so I have no affiliation or interest in the company.  I would appreciate your consideration on this matter.