RECORD ID D00-05-011

STANDARD NUMBER

INFORMATION DATE 06-06-2000

SUBJECT Use Of Modesty Clothing With Asbestos

QUESTION

These questions are concerning 29 CFR 1926.1101(i)(2).

  1. When modesty clothing (or any clothing) is worn under disposable coveralls, are they considered contaminated when leaving a regulated area?

  2. Does a laundry need to be informed of this?

  3. Does the modesty clothing need to be transported in sealed impermeable bags (or equivalent) and labeled?

  4. Can the modesty clothing be worn into the shower and be considered decontaminated?

REGULATORY REVIEW

  1. A search of DOE's Response Line and OSHA's interpretations did not find an explicit answer to the question of whether modesty clothing (or any clothing) worn under disposable coveralls is considered contaminated when leaving a regulated area. It is appropriate therefore, for a competent person, as defined in 29 CFR 1960.1101(b)--"Definitions", to make that determination for each individual work situation.

  2. A laundry needs to be informed that the modesty or other under clothing is contaminated if the competent person determines that this clothing is contaminated. (29 CFR 1926.1101(I)(2)(ii)--"Any employer who gives contaminated clothing to another person for laundering shall inform such person of the requirement in paragraph (i)(2)(i) of this section to effectively prevent the release of airborne asbestos in excess of the TWA and excursion limit prescribed in paragraph (c) of this section.").

  3. The modesty or other under clothing must be transported in sealed impermeable bags (or equivalent) and labeled contaminated if the competent person determines that this clothing is contaminated. (29 CFR 1926.1101(i)(3)--"Contaminated clothing. Contaminated clothing shall be transported in sealed impermeable bags, or other closed, impermeable containers, and be labeled in accordance with paragraph (k) of this section.").

  4. Title 29 CFR 1926(j)(1)(iii)(B) states--"Employees shall remove their protective clothing in the equipment room and deposit the clothing in labeled impermeable bags or containers." Therefore modesty or other under clothing that has been determined by a competent person to be contaminated must be deposited in labeled impermeable bags or containers rather than worn into the shower.