Standard Interpretations - (Archived) Table of Contents|
| Standard Number:||1926.58(e)(6)|
Mr. Alfred I. Greenfeld
Occupational Safety and Health
The Brand Companies, Inc.
1420 Renaissance Drive
Park Ridge, Illinois 60068
Dear Mr. Greenfeld:
This is in response to your letter of May 3, regarding the use of a "Negative Air Bag" in the removal of asbestos pipe insulation. It is the opinion of the Occupational Safety and Health Administration (OSHA) that the use of "Negative Air Bags" as described in your letter meets the requirement for establishing a negative-pressure enclosure pursuant to 29 CFR 1926.58(e)(6), provided that all of the other provisions of the construction asbestos standard are met.
If we may be of further assistance concerning this matter, please feel free to contact us.
Alan C. McMillan
Acting Assistant Secretary
November 17, 1989
MEMORANDUM FOR: ALL REGIONAL ADMINISTRATORS FROM: THOMAS J. SHEPICH, DIRECTOR DIRECTORATE OF COMPLIANCE PROGRAMS THROUGH: LEO CAREY, DIRECTOR OFFICE OF FIELD PROGRAMS SUBJ: The Use of Glove Bags Pursuant to 29 CFR 1926.58
Recent asbestos abatement industry trade journals and newsletters have reported that OSHA has "banned" the use of glove bags. These stories are the result of several cases where employers were cited for performing large-scale asbestos removal operations via glove bagging, without establishing a negative-pressure enclosure in accordance with 29 CFR 1926.58(e)(6).
This memorandum is not a change in policy but a reiteration of OSHA's position. As you know, OSHA's position is that the requirements to establish negative-pressure enclosures pursuant to 29 CFR 1926.58 (e)(6) is a specification standard which is predicated upon the type of job being performed and not the employee exposure levels. Thus, for large-scale removal of asbestos from pipes the employer must first establish a negative-pressure enclosure. Once the containment is established, the employer has an obligation to ensure that his/her employees' exposures remain below the PEL of 0.2 fiber/cc. Glove bags are one method specified in 29 CFR 1926.58 (g)(1) for controlling exposures within the negative pressure enclosure.
A recent study of glove bag methods of asbestos removal conducted by the National Institute for Occupational Safety and Health (NIOSH) in conjunction with the Environmental Protection Agency (EPA) showed that 58% of the employees tested were exposed above the OSHA's action level of 0.1 f/cc when engaged in multiple glove bag operations. To reduce worker exposure, proper glove bag procedures are essential, as outlined in appendix G.
Glove bags are permitted for use in small-scale, short duration jobs, which OSHA Instruction CPL 2-2.40 defined in paragraph H.3.c [(1)-(4)] as follows:
(1) Maintenance or renovation tasks, where the removal of asbestos-containing materials is not the primary goal of the job (e.g., repairing a valve which entails the removal of asbestos, installing electrical conduit which must be fastened to asbestos-cement siding, etc.)
(2) Activities where employees' exposures to asbestos can be kept below the action level via worker isolation techniques, such as glove bags or other methods described in Appendix G.
(3) An operation which has been included in the employer's asbestos maintenance program (as required in Appendix G) of all employers who are claiming an exemption from the requirements of 29 CFR 1925.58 (e)(6)).
(4) Nonrepetitive operations (viz.: not a series of small-scale jobs, which if performed at one time would have resulted in a large-scale removal).
All of the requirements in paragraphs (1) through (4) above must be met in order for a job to be considered a small-scale, short duration operation. If the small-scale, short duration exemption is claimed, Appendix G of the standard must be followed.
OSHA has also considered EPA's interpretation in Appendix B to subpart E of their standard, 40 CFR Part 763 in which small-scale, short duration is defined as:
-removal of asbestos-containing thermal system insulation not to exceed amounts greater than those which can be contained in a single glove bag, or
-repairs, involving encapsulation, enclosure or removal, to small amounts of friable asbestos-containing material only if required in the performance of emergency or routine maintenance activity and not intended solely as asbestos abatement. Such work may not exceed amounts greater than those which can be contained in a single prefabricated minienclosure.
An example of where glove bags may be used is in a building with several rooms, each room having a few feet of asbestos pipe insulation to be removed. Negative-pressure enclosures are not required if each room needs only a single glove bag (fixed location) to contain the removed asbestos-containing materials (ACM).
OSHA has considered one type of glove bag known as the Negative Air Bag and also rigid glove bags to meet the intent of the standard with regard to large-scale removal practices and procedures, when used in the following manner:
1. Glove bags are modified in such a way as to maintain continuous negative pressure inside the bags. The integrity of the negative pressure system shall be demonstrated by smoke testing.
2. The area to be worked on must be established as a regulated area with barrier tape and appropriate warning signs, and all employers within the immediate vicinity must have been notified of the abatement project. Respirators and protective clothing shall be provided and worn.
3. The area of insulation to be removed shall be wet-wiped and encapsuled prior to removal.
4. The bag shall be attached to the pipe using approved methods. If the size of the pipe warrants it, a small, rigid plastic collar is inserted into the bag to insure that the bag does not collapse when negative pressure is created. All of the necessary tools and equipment shall be inserted into the bag prior to its being sealed.
5. The worker shall begin the removal process, using all of the normal engineering controls, including amended water. During the removal process, personal sampling shall be conducted in accordance to air monitoring requirements.
6. When the removal of the insulation has been completed, the glove bag shall be removed by the approved method and then treated as asbestos waste. The removal process must be thorough and shall include encapsulant being sprayed onto the open ends of the pipe.
7. When the removal of the asbestos-containing materials has been completed, the workers are required to undergo complete decontamination in the decontamination unit set up nearby.
Using glove bags to remove pipe insulation in this manner, under continuous negative pressure and with all other provisions of the standard in operation, meets both the letter and the intent of the standard with regard to removal practices and procedures.
OSHA is presently under court order to clarify the definition of
small-scale, short duration operations. The asbestos directive, CPL 2-2.40,
published on September 1, 1987, will be updated to include current
interpretations. Please contact Helen Li of the Office of Health Compliance
for comments or questions at 202-523-8036 or FTS-523-8036.
|Standard Interpretations - (Archived) Table of Contents|