Document rBGy1L8bOEL2qND612aB0kNoJ

ELANESE January 20, 1987 TWS-02-87 PLAINTIFF'S EXHIBIT Hr. Leo Carey Director of the Directorate of Field Operations OSHA U.S. Department of Labor, Room N-3603 200 Constitution Avenue, N.V. Vashington, D. C. 20210 Reference: 29 CFR Part 1926.58 Asbestos ______ Dear Hr. Carey: Regarding 1926.58, much of our manufacturing facilities' work with asbestos will entail maintenance operations qualifying as small-scale and short-duration jobs. A compliance point we have discussed for these small-scale, short-duration operations is the need for showering. Paragraph (j)(l)(i) states that HEPA vacuuming may be permitted before leaving the area where maintenance was performed, and paragraph (j)(2)(i) indicates that the employer need not establish - decontamination area for small-scale, short-duration operations.- In my opinion, /hese exemptions exclude the need for showering. This position is further demonstrated in Part XI of the Preamble, entitled. Summary and Explanation for a Revised Standard for the Construction Industry, Paragraph (j) - Hygiene Facilities and Practices. On page 22723 (June 20, 1986 Fed. Reg.), top of the middle column. "For example, Hr. Darrell E. Anderson...", the showering exemption seems to be quite explicit. Vould very much appreciate your office's position on the showering requirement fcr small-scale, short-duration operations. Sincerely, CELANESE FIBERS PS cc: Hr. V. V. Ament - (ORC) Thomas V. Scott, P.E., C.I.H. CELANESE. BOX 32H. CHARLOTTE. N C 28232TELEPHONE 704-SS42000 ABS-060612 LAM 031188