March 1, 2007

Mr. James P. Burnham, President
Insulation Contractors Association of Pittsburgh
c/o Burnham Industrial Contractors, Inc.
3229 Babcock Boulevard
Pittsburgh, PA 15237

Dear Mr. Burnham:

Thank you for your May 12, 2006, letter to the Occupational Safety and Health Administration (OSHA), concerning the construction asbestos standard, 29 CFR 1926.1101. Our Regional Administrator in Philadelphia, PA, forwarded your letter for further response concerning procedures for employee decontamination upon leaving a regulated area. This reply letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not detailed in your original correspondence. Your paraphrased question and our reply are below.

Question: You requested our review of the following procedures for compliance purposes. You describe typical work practices for Class I asbestos removal activity at major utility work sites. We assume that the removal involves over 25 linear or 10 square feet of thermal system insulation (TSI) or surfacing asbestos-containing material (ACM) or presumed ACM (PACM) (see 29 CFR 1926.1101(j)(1)). A mobile decontamination shower is at a remote location because it is infeasible to construct a shower adjacent to the regulated area, such as an elevated platform by a multi-story boiler.

In this situation, the employer has constructed an equipment room and change room adjacent to the regulated area, but the shower is remote. Upon exiting the work area, employees step into the equipment room after they have been vacuumed using a high-efficiency particulate air (HEPA) filter, remove their contaminated work suits, step into a clean change room to don clean work suits, use a garden sprayer to spray off their respirators, exit the clean room, remove their respirators, and proceed to a mobile shower unit which is located down on the ground level. The mobile shower unit also includes another equipment room and another clean room.

The asbestos workers shower at lunch and quitting time. When workers take their two 15-minute breaks in the earlier and latter halves of their work shifts, these same decontamination procedures are followed, except the workers do not proceed to the shower. Instead, they exit the first clean room with their clean work suit on and then proceed to the designated break area, which is usually as close to the work area as possible.

Reply: The provisions in the construction asbestos standard in paragraph 1926.1101(j) describe the required facilities and decontamination procedures for those situations where an employer can demonstrate that it is not feasible to locate the shower between the equipment room and the clean room. The facilities and work practices paraphrased in the question above for your Class I asbestos removal activities at elevated work areas generally comply with these provisions. For compliance with these provisions, employers shall ensure, in accordance with 1926.1101(j)(1)(i)(B)(1) and 1926.1101(j)(1)(i)(B)(2), that employees:

(1) Remove asbestos contamination from their worksuits in the equipment room using a HEPA vacuum before proceeding to a shower that is not adjacent to the work area; or

(2) Remove their contaminated worksuits in the equipment room, then don clean worksuits, and proceed to a shower that is not adjacent to the work area.

Another compliance question is whether employees may proceed to a break area without showering, as long as they shower at the end of the work shift. As a matter of enforcement policy, OSHA will not cite an employer for not requiring employees leaving regulated areas to shower as long as the employer makes sure that these employees perform the following measures for interim decontamination:

• Remove asbestos contamination from their donned worksuits and respirators in the equipment room using a HEPA vacuum, then doff their respirators in the clean room; or
   
• Remove their contaminated worksuits and HEPA-vacuum their donned respirators in the equipment room, then doff their respirators and don clean worksuits in the clean room; and
   
• Wash their hands and faces prior to eating, drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet.
   

You should note that OSHA's construction sanitation standard in paragraph 1926.51(f)(1) requires employers to provide adequate washing facilities where, among other things, contaminants may be harmful to employees. OSHA has interpreted that provision to require soap and water (Letter of Interpretation to Mr. James Banford, July 20, 2005). If employees are not going to make another entry into a regulated area before the end of the work shift, employees must proceed to a remote shower for complete decontamination.¹

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs

¹It is also noted that the general industry asbestos standard, which also addresses asbestos decontamination, provides that employers shall ensure that employees who work in areas where their airborne exposure is above the 8-hour time weighted average permissible exposure limit and/or excursion limit, shower at the end of the work shift (29 CFR 1910.1001(i)(2)(1)). [ back to text ]