OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

April 15, 1975

R. E. Workman,
Vice President
The Goodyear Tire & Rubber Co.
Akron, Ohio 44316

Dear Mr. Workman:

Assistant Secretary John H. Stender has asked me to respond to your letter of March 28, 1975, requesting a variance from Section [1910.1017(h)(1)(ii)] Vinyl Chloride - Hazardous Operations, of the Occupational Safety and Health Standards.

The standard requires the use of protective clothing to prevent skin contact with polyvinyl chloride residue on vessel walls. Although there is minimal residue in your situation, employees would still be exposed to skin contact with polyvinyl chloride containing vinyl chloride monomer. Therefore, protective clothing would be required.

The standard does not specify the type of protective clothing, simply stating that it shall be selected for the operation and its possible exposure conditions. For your low-exposure conditions an appropriate selection might be a disposable suit with gloves and head and neck covering and, of course, an appropriate respirator. Other types of garments would also be appropriate such as laundered coveralls. Whatever is selected should completely cover the employee's own clothing and should include gloves and head and neck covering to prevent the residue from getting in the hair. The employee should wash any dust from his face after working in the vessel.

No further action will be taken on your request for a variance.

Sincerely,

Barry J. White
Associate Assistant Secretary for
Regional Programs