In reading the changes regarding project monitors, one thing is not absolutely clear.  What are the duties of the contractor and the individual asbestos license holders when the owner has been properly notified in writing that a project monitor (pm) is required and the owner does not hire a project monitor.  The regulations should be clear in the requirements and results that the Board anticipates.  For example if the contractor starts and the owner does not hire the project monitor, are the licenses of all in peril?  Should the contractor notify an appropriate agency and what is that agency?  What does the contractor do if the owner says they hired a pm and none shows on the job?  Is it the responsibility of the contractor to confirm the license and training of the pm on each job?  Before these situations happen (and they will), the Board should address them either in the regulation or in a directive to all people holding a license.

My suggestion is that all notices submitted for abatement should be required to include the name and particulars of each pm or at least the information on the company that has been retained and a list of the pm's that may show on the job.  It should NOT be the contractors job to confirm license numbers.