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 https://www.osha.gov.

April 16, 1986

Mr. Karl Spilhaus
Northern Textile Association
211 Congress Street
Boston, Massachusetts 02110

Dear Mr. Spilhaus:

This is an update to our response of March 5 to your letter of February 4, concerning braided and woven elastic fabrics.

We wish to thank you for the videotape Mr. Stig Bolgen of your Association sent demonstrating two different types of looms producing narrow fabrics. After having reviewed the tape, we now provide the clarification you requested.

The Occupational Safety and Health Administration (OSHA) is unaware of any reason why the dust from unwashed cotton yarn used in weaving operations in the elastic fabric industry would be any different from the dust from unwashed cotton yarn used in other weaving operations. Also, the Agency is unaware of any reason why the dust from unwashed cotton used in braiding operations would be any different from dust from unwashed cotton used in weaving. If, as you believe, there is less cotton-dust-related occupational disease associated with weaving and braiding in the elastic fabric industry, OSHA must assume that it is due to the lower levels of cotton dust exposure that you noted to exist.

OSHA concludes that the cotton dust standard, 29 CFR 1910.1043, applies to elastic fabric industry weaving and braiding operations using any unwashed cotton yarn. Exemptions apply, however, if washed cotton only is used. We refer you to 29 CFR 1910.1043(n) of the standard for details. Also, please observe that if exposures are below the 375 microgram per cubic meter action level for slashing and weaving given at 29 CFR 1910.1043(c)(2)(iii) of the standard, only a few provisions of the standard will pertain.

I appreciate the opportunity to address your concerns. Please do not hesitate to contact me again if you have further questions.


Patrick R. Tyson
Acting Assistant Secretary