Yes. Though special provision 156 in column 7 of the Hazardous Materials Table excepts from regulation asbestos that is immersed or fixed in a natural or artificial binder material, i.e. non-friable, the shipper may still classify a non-friable asbestos and offer it for transportation as a Hazardous Material (HazMat).  [LOI 03-0262]

Special Provision 156:

Asbestos that is immersed or fixed in a natural or artificial binder material, such as cement, plastic, asphalt, resins or mineral ore, or contained in manufactured products is not subject to the requirements of this subchapter.

Interestingly, asbestos is identified as a hazardous substance in Table 1 to Appendix A of the Hazardous Materials Table. It has a low RQ (Reportable Quantity) of 1 lb (0.454 kg). However, a note to the entry reads as follows:

The RQ for asbestos is limited to friable forms only.

A non-friable asbestos can’t be an RQ of a hazardous substance.

So, it is acceptable to ship a non-friable asbestos as a hazardous material even though it – because of special provision 156 – is not subject to the regulations, a shipper will not be able to identify it as a Reportable Quantity of a hazardous substance.