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Conductivity of asbestos-sampling cassette cowls

Summary A sampling-equipment maker asked for a numeric conductivity specification for asbestos cassette cowls. OSHA said its cited standards require the cowl to be conductive but specify neither a resistivity value nor a black color; conductivity is the enforceable requirement. The posted letter carries a 2005 correction.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-08-28-1
Date issued
August 28, 1991
Status
Active
OSHA marks the posted letter corrected June 2, 2005.
Status last verified October 9, 2026

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

August 28, 1991
Michael A. Sirbola
Air Monitoring Equipment, Inc.
[Recipient address omitted]

Dear Michael,

I have tried over the course of the past year to find time to make a simple determination that would answer the question you posed about the resistivity of the cowl. I appreciate your patience with me. I still have not absolutely determined a suitable response to your question. I have raised considerable questions of my own about what is going on in the cassette. The situation is far from simple. The intent of the requirement for the cassette cowl to be conductive was to eliminate electric fields in the interior and give charges a path out of the cassette.

Therefore, we require that the resistivity of the cowl be sufficient that the material be considered a conductor. The standards do not specify a particular resistivity, nor do they require the cowl to be black. Both 29 CFR 1910.1001 and [29 CFR 1926.1101] simply require that the cowl be "conductive". This is the aspect of the standard that is enforceable.

We will continue to study the issue in greater detail. Should you require further assistance, feel free to call.
Sincerely,
Daniel T. Crane, Supervisory Physical Scientist
[Directorate of Science, Technology, and Medicine
Salt Lake Technical Center]
(Correction 6/2/2005)

[The requester’s July 9, 1990 letter reproduced on the OSHA page is omitted here.]

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