May 15, 1997

Robert W. Weeks, Jr., Ph.D.
Director, FSI
Field Sciences Institute
2501 Baylor Drive, SE
Albuquerque, New Mexico 87106

Dear Mr. Weeks:

This is in response to your letter of March 28, addressed to the former Director of the Office of Health Compliance Assistance, Ms. Ruth McCully, concerning glove bag methods for control of exposure to airborne asbestos.

You requested that we clarify 29 CFR 1926.1101(g)(5)(B)(iii). You noted that this regulation states that negative pressure glove bag systems shall attach HEPA vacuum systems or other devices to prevent collapse during removal. You ask if there has been a modification or clarification of this regulation to allow the use of glove bags without attaching a HEPA vacuum system.

Please be advised that the control method given at 29 CFR 1926.1101(g)(5)(ii) is a glove bag procedure that does not require the attachment of a HEPA vacuum system. The regulation you specifically mentioned in your letter, 29 CFR 1926.1101(g)(5)(iii) is a procedure for using a negative pressure glove bag system. OSHA still requires that glove bag systems specifically designed to be used under negative pressure have a HEPA vacuum system attached. However, a glove bag system not designed to be used under a vacuum can be operated without a HEPA vacuum system attached.

We appreciate the opportunity to clarify this matter for you. If you have any additional questions, please call Gail Brinkerhoff at (202) 219-7380.

Sincerely,



Stephen Mallinger, Acting Director
Office of Health Compliance Assistance




March 28, 1997

Ruth McCully, Director
Office of Health Compliance Assistance
Occupational Safety and Health Administration
U.S. Department of Labor
Washington, D.C. 20210

Dear Ms McCully;

I am in need of clarification of 29 CFR 1926.1101(g)(5)(B)(iii), Methods of Compliance, Specific Control Methods for Class 1 Work, Work Practices, Negative Pressure Glove Bag Systems. Particularly, this regulation states, "....negative pressure glove bag systems shall attach HEPA vacuum systems or other devices to prevent collapse during removal..."

My question is simply, "Has there been a modification or clarification of this regulation to allow glove bag work to proceed and to NOT employ a HEPA vacuum system to the glove bag?"

I may be reached by FAX at (505)764-0117, or by mail at:

Robert Weeks
Field Sciences Institute
2501 Baylor Dr, SE
Albuquerque, NM 87106

Thank you very much for addressing this issue.

Sincerely,



Robert W. Weeks, Jr., Ph.D
Director, FSI