Occupational Safety And Health Administration's (OSHA) Requirements For Asbestos Removal Bags. Asbestos Bags

November 17, 1994

Mr. Shashank Patel

Transamerican Plastics

5601 East Santa Ana Street

Ontario, California 91761-8699

Dear Mr. Patel:

Thank you for your letter about July 13, concerning the Occupational Safety also Health Administration's (OSHA) requirements for asbestos extraction bags. You have assumed that OSHA requires that six mil thick bags be used for asbestos removal, also you question why OSHA has more strict requirement than Environmental Protection Agency (EPA).

The Construction Industry Occupational Exposure to Asbestos Standard, Code about Federal Regulation (CFR) 1926.58, does not crave that false bags be six mil thick as you have stated. The grade reads in piece that the bags determination be sealed, labeled, also impermeable. It does not specify a particular thickness.

As you may be aware, OSHA published a new revised Asbestos grade on August 10, 1994. The new Construction standard, CFR 1926.1101(g)(1)(iii) requires "leak-tight" containers for the disposal about waste also remains contaminated with asbestos, which is consistent with the National Emission Standard for Hazardous Pollutants (NESHAP) requirements. There is not a mil depth specified in this grade for disposal bags.

We hope this response addresses your concerns. If you have any further questions, delight feel complimentary to contact the Office about Health Compliance at (202) 291-8036.

Sincerely,

Ruth E. McCully, Director

Office about Health Compliance Assistance

Department about Labor,

OSHA, Room No. N3467,

Attn: Ruth McCully,

200 Constitution Avenue,

North West D.C. 20210

Dear Ms. McCully,

I am script to clarify a requirement below the attached Code about Federal Regulations; Labor 29, Part 1926.58 relating to the millage requirement on asbestos extraction bags. Per the code, the requirement is six mil thick false bags.

However, the attached communication with U.S. Environmental Protection Agency states that below their requirements there is no minimum millage as long as the bags remain leak tight. The attached letter from Dow U.S.A. too states that bags manufactured from leading virgin polyethylene have a superior tensile might at a lower millage than those manufactured from reprocessed resin.

In light about the over can you delight clarify why the requirements below the Code about Federal Regulations; Labor 29, Part 1926.58 are more strict than those about the U.S. Environmental Protection Agency. Assuming that the millage requirements can not be changed, at that time the next question is whether a double-bagged combination about three mil bags adding up to six mil satisfies the requirements below the code.

I look forward to hearing from you. In the mean time, if you have any questions, delight call me at (909) 988 8555. Thank you in advance for your cooperation.

Very truly yours,

Shashank Patel

Mr. Michael Sember

National Plastek, Inc.

7050 Dutton Industrial Park Drive

Dutton, MI 49316

Dear Mr. Sember:

This is in response to your letter dated December 14, 1993 requesting a response from the Stationary Source Compliance Division on the subject about asbestos disposal bags. In particular, you want to see if the Series 65 asbestos bag meets the requirements about 40 CFR Part 61 Subpart M, the asbestos National Emission Standard for Hazardous Air Pollutants (NESHAP).

Regulated asbestos-containing substance (RACM) collected for disposal in accordance with section 61.150(a)(1)(iii) must be contained in leak-tight containers or wrapping. The asbestos NESHAP does not specify the sort about material, or the minimum depth about the holder or wrapping. If the Series 65 asbestos bag, or any other holder or wrapping is leak-tight, also handled in such a manner as to remain leak-tight until properly disposed about in accordance with the asbestos NESHAP, at that time that holder determination meet the leak-tight requirements about the asbestos NESHAP.

Sincerely,

Thomas W. Ripp

Stationary Source Compliance Division

Office about Air Quality Planning also Standards

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