November 17, 1994

Mr. Daniel Fousek
Woodward-Clyde Consultants
30775 Bainbridge Road, Suite 200
Solon, OH 44139

Dear Mr. Fousek:

This is in response to your letter dated August 12, 1994 to Mr. Rob Medlock, the Area Director in the Cleveland Area Office. You requested clarification on the use of negative pressure glovebags for the removal of asbestos-containing materials (ACM) and you asked if there is a maximum amount that can be removed using glovebags.

As you may be aware, on August 10, 1994, the Occupational Safety and Health Administration (OSHA) published in the Federal Register final standards for Occupational Exposure to Asbestos. The new standard includes major revisions that are germane to the issues you have concerning glovebags.

In light of the considerable comment and evidence OSHA received on glovebag effectiveness, the decision was made to allow increased glovebag use for the removal of asbestos containing materials (ACM) and Thermal system Insulation (TSI) without quantity limitation. The term "small--scale, short duration" is no longer used in the standard. In the Construction standard, CFR 29 1926.1101, OSHA has added four classes of activity which triggers provisions of the standard. The removal of ACM as described by your letter appears to be Class I work although that would need to be evaluated by the competent person. The specific control methods are explained in 1926.1101(g)(5). Each method is a system which consists of tangible material, devices, procedures and practices and an employer must comply with each element. A copy of the standard is provided for your review.

Depending on the class of work being done and the method of compliance chosen, the employer may use ambient or "regular" glovebags or negative pressure glovebags. Prior to disposal, glovebag shall be collapsed by removing air within the bag by using a HEPA vacuum. Under the new standard, the issue of whether to use low-volume pump or a high-volume pump, is not pertinent.

The methods of compliance described above shall be implemented as soon as possible, but no later than April 10, 1995.

We hope this information is responsive to your concerns.

Sincerely,



Ruth McCully, Director
Office of Health Compliance Assistance