Negative pressure glovebags for asbestos removal

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 27, 1990

Mr. A. M. Mickey Fine
Industrial Hygienist
Salt River Project
[Recipient address omitted]
Dear Mr. Fine:

This is in response to your letter of March 12, to the Occupational Safety and Health Administration (OSHA), regarding negative pressure glovebag issues. Your letter was transferred from our Phoenix Area Office to us for a reply. We apologize for the delay in response.

OSHA allows the use of glovebags for small-scale short-duration operations. Generally, these operations are maintenance type activities involving removal of small amount of asbestos. We require the establishment of negative pressure enclosures for large-scale jobs to prevent the spread of asbestos contamination beyond the work area and to protect bystanders from excessive asbestos exposures. The negative air bag was determined to meet the intent of a negative pressure enclosure.

The use of serial glovebagging or repeated use of one glovebag is discouraged because of the increased risk of breakage of these bags, which would cause gross contamination. Therefore, we cannot agree with your statement that if a glovebag is safe for three linear feet, this procedure repeated several times is still safe.

In our July 5, 1989, letter to Brand Company, OSHA reviewed Brand Company's work procedures and approved them under the condition that all other provisions of the asbestos standard are met including air monitoring, designation of a competent person, etc. We require a decontamination facility to be constructed near the work area so that the employees, if they are accidentally contaminated with asbestos wastes through breakage of the glove bag, malfunction of the vacuum, or electric failure, can quickly decontaminate themselves.

We appreciate your concerns and agree with you that there are difficulties associated with the use of negative-pressure glovebags. However, Brand Company has not sent us any updated work procedures; therefore, we cannot provide comments on any new methods they might have developed since July, 1989.

We recognize that there are inherent problems in any abatement procedures. We place emphasis on proper work practices and engineering controls as a means to reduce employees' exposures. Workers must be trained to be aware of health hazards of asbestos and to work safely, following proper work practices. We do not endorse the method of negative pressure glovebag or any other method, but merely have accepted its use as meeting the intent of a negative-pressure enclosure. We prefer a full containment under negative-pressure; however, the standard does not specifically require such containment. The use of a negative pressure glovebag is simply one acceptable alternative.

OSHA is proposing some changes to the asbestos regulations and will be addressing the issues of small-scale, short-duration operations and negative-pressure enclosures. The proposal was published in the Federal Register on July 20. A copy is enclosed. We welcome public comments and certainly will take your comments into consideration.

If we can provide you with further assistance, please do not hesitate to contact us.

Sincerely,

Patricia K. Clark Director
Designate Directorate of Compliance Programs

Enclosure

[Regional forwarding memorandum and requester letter reproduced on OSHA page; omitted here.]