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.

June 4, 1986

Mr. Richard N. Hopper
Director of Governmental Affairs
The Carpet and Rug Institute
Suite 1000
1100 17th Street, N.W.
Washington, D.C. 20036

Dear Mr. Hopper:

This is in response to your letter of March 27 to Dr. Susan Harwood, concerning the tufting of undyed and (we presume) unwashed cotton. Please excuse the delay in our response.

This operation is not included in the scope of the revised cotton dust standard of December 13, 1985, nor is it included in the scope of the permissible exposure limit for cotton dust contained in Table Z-1 of 29 CFR 1910.1000. But it is also not in the list of excluded operations, processes and industries listed in the standard.

The operation is not covered because it slipped past the attention of the Occupational Safety and Health Administration (OSHA) and was not considered during the rulemaking procedures. Therefore, no inferences should be drawn about the nature of the health hazard from the fact that it is not covered by OSHA's standard.

We appreciate the opportunity to clarify this matter for you. If you have further questions, please do not hesitate to contact us.


John B. Miles, Jr., Director
Directorate of Field Operations

March 27, 1986

Dr. Susan Harwood
Health Scientist
Room 3718 North
Occupational Safety and
Health Administration
200 Constitution Avenue, N.W.
Washington, D.C. 20210

Dear Dr. Harwood:

The Carpet and Rug Institute is the national trade association of American carpet and rug manufacturers. Included in the members are small rug manufacturers who makes throw rugs for bathrooms, children's rooms, etc.

These rugs are made by tufting or inserting a face yarn into a performed back and anchoring these yarns into the back with some type of latex backing compound. The manufacturers purchase undyed yarns and dye the small rugs after the tufting operation.

Since these small rug manufacturers are not engaged in yarn manufacturing, slashing, weaving or involved with waste for textiles, it would appear they would be exempted from the Occupational Exposure to Cotton Dust Rule. Would appreciate your confirming this.


Richard N. Hopper
Director of Governmental Affairs