Document 1gmd2bvDNKXEDED6Qk3VRMQpE

Federal Register / Vol. 51. No. 119 / Friday, June 20, 1986 / Rules and Regulations 22721 . participants were of the opinion that this 6/25, p. 57). One commenter from the "precautions need to be taken to prevent type of clothing provide sufficient ' N.Y.C. Board of Education, Office of contamination of workers' street clothes, 1 protection to the worker but eliminates Design Construction, cited the cars, and homes" (Ex. 92-011. p. 2). They the problems that may be involved in "Asbestos Abatcment/Control Guidance specified that body coveralls be worn, laundering and storing asbestos- Manual," which states that "no worker and "these coveralls must not be worn contaminated clothing (Ex. 123-A, 298. may use street clothes under home" (Ex. 92-011. p. 2). 330, Tr. 6/25). Several commenters disposable suits" (Ex. 92-26, p. 73). Several commenters discussed ***** 1 stated that disposable clothing was currently required and used in asbestos operations. Dr. R. F. Boggs, Vice i President of ORC. commented that International Paper requires disposable clothing for all asbestos demolition and ; removal operations (Ex, 123-A). M.K. O'Brien, Vice President of a-local of the i i United Steelworkers of America, stated i that Northern Indiana Public Service i. Company now uses full body overall); type paper disposable suits (Tr.7/3). Daniel F. Wilton of the Sheetmetal Workers International Association, bocal 28, said that the World Trade | . Center requires all contractors to wear ; disposable protective suits and boots during renovation work (Tr. 6/29). The Primary advantage that commenters cited for the use of disposable worksuits was that this type ! of clothing eliminated the need for laundering and storing asbestos- 1 contaminated articles. Dr. Boggs j | included in the ORC response to the 1 Notice of Proposed Rulemaking on Occupational Exposure to Asbestos ; . (49FR14118), the comments of T.E. Kupferer of the Standard Oil Company (Indiana). Mr. Kupferer stated that Standard Oil (Indiana) workers involved in asbestos removal wear disposable protective clothing "because of the problems involved in storing, . ' laundering, and handling of reusable \ clothing contaminated with asbestos . . . 2 (Ex. 123-A)." | Commenters from the BCTD also : emphasized that disposable clothing should be required, stating that "while disposable overalls may not be as durable and comfortable as cotton work - clothes, they ... do not require laundering which would expose another workforce or the worker's family to asbestos" (Ex. 330, p. 68). The BCTD stressed that ". . . it is ; essential and feasible to provide | personal protective equipment for. construction workers, who are exposed l to asbestos;. . . (and that] protective | clothing [must] be provided whenover | any person enters the; regulated area" l (Ex. 330, pp. 67-68). William L. Baker Although these commenters agreed that disposable worksuits are preferable for large-scale, asbestos removal operations, some rulemaking participants felt that disposable clothing was not necessary for other types of construction work. Connie Degrange of the Industrial Hygiene Croup at Lawrence Livermore National Laboratory commented that ordinary work clothes may be worn by employees who remove or install small sections of asbestos-containing materials or perform operations involving one-time penetration of existing asbestos coverings, provided that asbestos dust in.the work area is kept to a minimum (Ex. 341, p. 2. Attachment III), [oseph Jackson of the Association of Asbestos Cement Pipe Producers also felt that no special work clothes were needed during infrequent asbestos.cement cutting operations because exposure levels are "very close to ambient background levels" (Tr. 7/10, p. 138). OSHA finds that non-disposabie work clothes similar to those required in the revised general Industry standard will prpvide sufficient protection for employees engaged in construction activities, provided that such clothing is properly cleaned after work and then iaundered. Some respondents specified the articles that should be used by construction workers handling asbestoscontaining materials: full body coveralls, head coverings, fool coverings, and gloves (Exs. 92-26, 92-11, 92-25.123-A. Tr. 6/29). Therefore, the revised standard, like the existing rule, includes an enumeration of suitable articles of protective clothing. Although some commenters discussed particular types of disposable clothing, such as clothes . made of Tyvek (trademark of DuPont) and shoe coverings made of rubber, OSHA has not specified particular ' materials for protective clothing required by the final rule. William ]. Nicholson of the Mt. Sinai School of Medicine felt strongly that "no methods for cleaning and disposing of personal protective clothing. The Minnesota Department of Health, in "Guidelines for Developing an Effective Asbestos Removal Plan." recommended that "reusable clothing should be washed daily or weekly depending upon work conditions, with the launderer notified of their potential contamination" (Ex. 92-011, p. 2). The guidelines also specify that "proper precautions need to be followed when . handling contaminated clothing" (Ex. 92-011, p. 2). Mr. Kupferer explained that employees of Standard Oil (Indiana) are warned not to lake contaminated clothing home. Instead,, when the job is completed or workers leave a barricaded area, all contaminated articles are removed. . . . coveralls and gloves are routinely discarded along with the asbestos scrap, as arc disposable head and boot coverings, if used. Hard harts are cleaned, as arc boots, and any cleaning items used arc also discarded with the asbestos scrap. Where rain gear is worn over the disposable coveralls, it is also cleaned before removal from the site (Ex. 123-A. pp. 3-4 of Appendix D). Based on the weight of the evidence presented in the rulemaking record, OSHA has retained the requirements of the existing standard for laundering reusable work clothes in such a manner as to prevent the release of airborne asbestos fibers in excess of the PEL OSHA has assigned the responsibility for laundering asbestos-contaminated protective clothing to the employer in order to prevent exposure to workers' family members that may handle such clothing. Two concerns about personal protective clothing were expressed by. commenters: heat stress and worker comfort. David Kirby, Industrial Hygienist Chemist for the Alabama Safe State Program, felt that protective clothing is not necessary in all cases because it adds to the likelihood of heat stress (Tr. 6/20, p. 183). He explained that v of the National Association of | Demolition Contractors also cited a preference for paper uniforms because ) they can be disposed of (Tr. 6/25, p. i 57). Mr. Baker did not think that " durability was a problem because work clothes should ever be taken home" (Tf. 6/19, p. 1-92). He supported the final rule's laundering provision, stating that clothes "have to be laundered inspecially controlled laundry facilities" (Tr. 6/19, p. 1-93). by the end of the four-hour shift, the guy's halhvay out of the suit anyway. So unless asbestos exposure, to. the external area of the body is a definite threat. I feel like there may be some option involved with the use of external type protection. (Tr. 6/20, p. 183) workers would "only wear them when Minnesota Department of Health Dr. Boggs also included in the ORC . they do the asbestos removal . . ." (Tr. commenters also urged that response to the notice of rulemaking the 1 >:' GLEASON-000969