Thickness of asbestos waste disposal bags

November 17, 1994

Mr. Shashank Patel
Transamerican Plastics
[Recipient address omitted]
Dear Mr. Patel:

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

The Construction Industry Occupational Exposure to Asbestos Standard, Code of Federal Regulation (CFR) 1926.58, does not require that plastic bags be six mil thick as you have stated. The standard reads in part that the bags will be sealed, labeled, and impermeable. It does not specify a particular thickness.

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

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

Sincerely,
Ruth E. McCully, Director
Office of Health Compliance Assistance

[Requester correspondence and EPA response reproduced on OSHA page; omitted here.]