Asbestos signs, custodial tasks, and HEPA vacuuming

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

November 1, 1995

Gerald W. Lancour, Director
Safety, Health and Environmental Affairs
McDonnell Douglas
[Recipient address omitted]
Dear Mr. Lancour:

Thank you for your letter of March 28, concerning the Occupational Safety and Health Administration's (OSHA) Asbestos Standard (29 CFR 1910.1001). We regret the delay in this reply.

You requested specific clarification on three issues related to the asbestos standard, which will be addressed in the order in which they were presented.

Must warning signs be posted in each and every area identified by the building owner as containing previously installed asbestos containing material (ACM) or (PACM), regardless of the condition, accessibility, and/or the likelihood of disturbance of the ACM/PACM?

Your understanding of posting warning signs in regulated areas is correct. However, please note that on June 29, corrections to the final rule were published in the Federal Register (volume 60, number 125, pages 33985 and 33986) which will change your initial understanding of 1910.1001 as it relates to posting warning signs, and/or labels in a building. In summary, section (j)(4)(i) was expanded to require building owners or employers, to affix or post labels or signs on materials that have been identified as ACM and/or PACM, such as, but not limited to, the entrance to a mechanical room. The other changes to section (j) of the standard are general in nature, such as, but not limited to, a word, number, or letter. The above reference to pages in the Federal Register are being provided as an attachment to this correspondence.

Under what circumstances does custodial work constitute "pure Custodial work" regulated under the general industry standard, as opposed to custodial work undertaken as part of construction activities and subject to the construction standard?

Your understanding of the scope of custodial work in general industry is correct, in that the required activities by the custodial worker would normally be, but not limited to dusting, mopping, and vacuuming the carpeting. Any other activities, such as, but not limited to vacuuming a section of broken ceiling tile on the carpeting, should be evaluated as a possible task under the construction standard.

Do the housekeeping provisions contained in the general industry standard require the use of HEPA filters any time dust or debris is dry-vacuumed in an area containing ACM/PACM, even where the ACM/PACM is in good repair, is inaccessible, or has not been disturbed?

Your understanding is correct, in that HEPA-filtered vacuuming is only required to clean-up asbestos containing waste and debris.

We hope this information is helpful. If you have any further questions please contact the Office of Health Compliance Assistance at (202) 219-8036.

Sincerely,

Ruth McCully, Director
Office of Health Compliance Assistance

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