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• Standard Number: 1910.1018(k)(2); 1910.1025(h)(2)

March 18, 1993

MEMORANDUM FOR:     GABRIEL J. GILLOTTI
                   ASSISTANT REGIONAL ADMINISTRATOR 
                   OFFICE OF TECHNICAL SUPPORT

FROM:               ROGER A. CLARK 
                   DIRECTOR 
                   DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT:            Use of compressed air when cleaning Arsenic and lead
                   contaminated surfaces
This memorandum is in response to your memorandum of December 14, 1992 requesting interpretation of the provisions in the inorganic arsenic standard, 29 CFR 1910.1018 and the lead standard, 29 CFR 1910.1025 that prohibit the use of compressed air for cleaning floors and other surfaces. We apologize for the delay in our response.

You stated that the employer is concerned with the use of compressed air while cleaning the flash furnaces that are typically covered with lead and arsenic. The inorganic arsenic standard under Section 1910.1018(k)(2) states that "[f]loors and other accessible surfaces . . . may not be cleaned by the use of compressed air . . ." The lead standard under Section 1910.1025(h)(2) states that "[f]loors and other surfaces . . . may not be cleaned by the use of compressed air." The employer feels that the areas that need cleaning are not "accessible" and therefore the use of compressed air would be acceptable under Section 1910.1018(k)(2).

Because of the presence of both inorganic arsenic and lead in the area of the flash furnaces, the employer must comply with the housekeeping requirements of both standards. Since the lead standard prohibits the use of compressed air for cleaning under any circumstances, the employer must comply with the housekeeping requirements under Section 1910.1025(h)(2)(i). An employer complying with this provision of the lead standard will, of course, also be in compliance with Section 1910.1018(k)(2) of the inorganic arsenic standard.

Thank you for requesting an interpretation of this issue.



DATE:               December 14, 1992

MEMORANDUM FOR:     ROGER CLARK, DIRECTOR
                   Directorate of Compliance Programs

ATTENTION:          Office of Health Compliance

FROM:               GABRIEL J. GILLOTTI 
                   Assistant Regional Administrator
                   Office of Technical Support

SUBJECT:            Use of Compressed Air When Cleaning Arsenic and Lead
                   Sources
The Attached request from Magma Copper is concerned with the use of compressed air while cleaning flash furnaces that are typically covered with lead and arsenic dust. The employer has determined that these areas are not "accessible", therefore, use of compressed air is allowable. Our Arsenic standard says that air may not be used in "accessible" areas, the Lead standard indicates that compressed air may not be used under any circumstance.

Have we ever addressed the use of air for cleaning purposes when lead or arsenic are involved?

I would appreciate it if you would provide an interpretation that I can share with the Magma Company.


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