August 10, 1990

Mr. William L. Clegg President
H.E.W. Inc.
126 N. Moore
P.O. Box 119
Algona, Iowa 50511

Dear Mr. Clegg:

This is in response to your letters of April 16, to the Occupational Safety and Health Administration (0SHA) regarding a trailer mounted vacuum system and bagging station used in asbestos abatement. Your letter to OSHA's regional office in Kansas City as well as a copy sent to OSHA's Docket Office in Washington, D.C. have been forwarded to our office for response. In accordance with a recent telephone conversation with our staff member Ms. Helen Li, we are providing a response to question 3 of your letter, as you indicated your other concerns were previously addressed by the Environmental Protection Agency.

Question 3 states: "If the bagging station is an extension of the work area, shall it have the same protective factors as the area from whence it came? That is, a secured area consisting of a ceiling, walls, floor, air and under negative pressure complete with a decon chamber."

Although the bagging station is an extension of the work area in the circumstances shown in your submission, bagging is separate from asbestos removal, demolition, or renovation; therefore, [29 CFR 1926.1101(e)] would not apply and a negative-pressure enclosure and decon chamber would not be required. This work area is to be considered as the type of regulated area where paragraphs (e)(1) - (e)(5) of the asbestos standard would apply, requiring demarcation of the area, limiting access to authorized persons, and prohibition of smoking, drinking, eating, chewing tobacco or gum, or applying cosmetics. Respirators are to be supplied and selected in accordance with paragraph (h)(2) based on employee exposure levels that exist in the work place.

We hope this information is helpful to you. If we can be of further assistance, please do not hesitate to contact us.

Sincerely,

Patricia K. Clark Director
Designate Directorate of Compliance Programs