Reuse of contaminated uniforms during asbestos removal

June 21, 1993

Mr. Pasquale Navarro
Vice President of Operations
UNISERVE, Inc.
[Recipient address omitted]
Dear Mr. Navarro:

This is in response to your letter of March 16, concerning procedures for leaving from and returning to an asbestos removal area when recyclable protective uniforms are being used.

You requested that we advise you whether the procedures you recommended violate any provisions of Occupational Safety and Health Administration (OSHA) standards. The procedures you recommended are as follows:

The employee comes out of the asbestos containment area, removes his/her contaminated uniform in the equipment room while wearing proper respiratory protection, showers in the shower area, enters the clean room, removes his/her respiratory protection, dons clean clothes, and then goes to lunch or some other destination. When the employee returns, he/she removes his/her clean clothes, dons the proper respiratory protection, enters the equipment room and puts on the same uniform he/she wore in the morning, re-enters the containment area and continues working.

Your recommended practice of reusing a uniform that is contaminated with asbestos is prohibited by the standard. Provision [29 CFR 1926.1101(j)(1)(iii)(B)] requires the employer to ensure that employees remove their protective clothing in the equipment room upon leaving the containment area and deposit the clothing in labeled impermeable bags or containers; whereas provision [29 CFR 1926.1101(j)(1)(ii)(c)] requires the employer to ensure that employees put on protective clothing before leaving the clean room for the containment area. Since protective clothing must be put on in the clean room and cannot be taken beyond the equipment room after it has been worn in the asbestos containment area, the re-use of recyclable protective clothing until it has been properly laundered is prohibited.

In order to make your recommendations conform with the standard you must change them to indicate that when the employee returns, he/she is to don a clean uniform in the clean room before re-entering the containment area to continue working.

We appreciate the opportunity to clarify this matter for you.

Sincerely,

Ruth McCully, Director
Office of Health Compliance Assistance

[Requester letter reproduced on OSHA page; omitted here.]