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.

December 15, 1995

Gary Thibodeaux
Regional Safety Manager
National Service Cleaning Corporation
1201 Childers
Orange, Texas 77630

Dear Mr. Thibodeaux:

Thank you for you letter of November 8, proposing the use of "pipe cases" manufactured by Therm-Equip, Inc., in lieu of standard glove bags. You stated that "pipe cases" have the same characteristics of a glove bag but are designed for the removal of asbestos from high-temperature (up to 700 degrees F) pipes and ducts.

After reviewing the information you submitted we have concluded that the use of "pipe cases" complies with [29 CFR 1926.1101(g)(2)(ii)]. In addition, paragraph [1926.1101(g)(5)(ii)(B)(4)] prohibiting the use of glove bags where surface temperatures exceed 150 degrees does not take into account recent innovations in glove bag technology which has spawned new products such as the "pipe case" that can be used on pipes and ducts operating at elevated temperatures.

Your interest in occupational safety and health is appreciated. If we can be of further assistance, please feel free to contact [the Directorate of Science, Technology, and Medicine at (202)693-2300].


Stephen Mallinger
Acting Director
[Directorate of Science, Technology, and Medicine]

[Corrected 9/17/03]