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.

July 15, 1996

Mr. Daniel B. Walker, Jr.
Vice President
Marketing UNI-SERVE, INC.
55th Street & V.R.R.
Pittsburgh, Pennsylvania 15201

Dear Mr. Walker:

This letter is to confirm the discussion at the May 1 meeting attended by staff from the Occupational Safety and Health Administration (OSHA) and the Solicitor of Labor (SOL). The meeting was attended by Carol Jones from OSHA's Directorate of Health Standards Programs (DHSP), Doug Ray from OSHA's Directorate of Compliance Programs (DCP) and Edith Nash from SOL.

The meeting's discussion concerned the application of OSHA's health standards and, in particular the requirements of the interim final rule for lead in construction, 1926.62. OSHA's standards are applied to those workplaces that are covered by the scope of the standard (expanded standards, e.g., asbestos) or by the nature of the work (e.g., construction).

Regarding the laundering of contaminated personal protective equipment, the final interim rule for lead in construction, 29 CFR 1926.62(g)(2)(vi), requires the employer to notify the laundry service in writing that the personal protective equipment may be contaminated with lead. This downstream flow of information is necessary so that the laundry employer can take necessary precautions to protect his/her employees. Therefore, any employer that contracts with a laundry service to clean contaminated clothing (e.g., lead) must be in compliance with the applicable sections of that standard.

In a recent conference call between the Office of Health Compliance Assistance and our Regional Offices, the issue of laundering of contaminated clothing was addressed. The Regions were asked to remind staff about the importance of the standard's requirements.

Thank you for your interest in safety and health.


Ruth McCully, Director
Office of Health Compliance Assistance