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.

February 3, 1980

Mary-Win O'Brien
Assistant General
Counsel United Steelworkers of America
Five Gateway Center
Pittsburgh, Pennsylvania 15222

Dear Ms. O'Brien:

This letter responds to your request concerning the interpretation of the clothing locker provision of the Coke Oven Emissions Standard, 29 CFR 1910.1029. Paragraph (i)(1) states that the employer shall provide clean change rooms equipped with storage facilities for street clothes and separate storage facilities for protective clothing and equipment. We interpret this standard to require any type of facilities that are separate as long as the employee's street clothes are not contaminated.

It is our opinion, that a locker which does not prevent cross contamination of clothing does not meet the requirements of the standard. It would appear that the lockers being installed as described by you, offer a high percentage risk of cross contamination. OSHA has cited several employers for violation of 1910.1029(i)(1) who have lockers similar to those you described in your letter. I would, therefore, suggest that an employer who installs that type of locker is taking a considerable risk.

We will keep in close touch with the OSHA enforcement efforts to gather information on cross contamination of protective clothing to street clothing. We would appreciate learning any experiences that the United Steelworkers may have to aid us in this effort.

Thank you for bringing this matter to our attention. Your interest in occupational safety and health is appreciated.


Eula Bingham
Assistant Secretary