Standard Interpretations - Table of Contents
• Standard Number: 1910.1001(k)(6); 1926.1101(l)(2)


OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.


April 26, 1994

Mr. Michael B. Sember
Account Executive
National Plastek, Inc.
7050 Dutton Industrial Park Drive
Dutton, Michigan 49316

Dear Mr. Sember:

This is in response to your letter of January 13, to Mr. Gail Brinkerhoff of my staff concerning bags for collecting and disposing of asbestos waste. Please accept our apology for the long delay in providing our response.

You requested that the Occupational Safety and Health Administration (OSHA) determine what specifications must be met, and what testing procedures should be conducted, to ensure that bags for collecting and disposing of asbestos waste are of the necessary quality and consistency. OSHA believes that its performance requirements for the bags at [29 CFR 1926.1101(l)(2)] in the Construction Asbestos Standard and at 29 CFR 1910.1001(k)(6) in the General Industry Asbestos Standard make bag specifications unnecessary and that procedures for testing the bags for quality and consistency is best left to the discretion of the manufacturers. Rule [29 CFR 1926.1101(l)(2)] in the Construction Asbestos Standard reads,
"Waste disposal. Asbestos waste, scrap, de