August 7, 1996

Clint Van Arsdall
Safety and Health Manager
City of Portland Bureau of Water Works
1900 N. Interstate
Portland, OR 97227

Dear Mr. Van Arsdall,

This is in response to your letter requesting clarifications on 1926.1101, “Asbestos.” 1926.1101(l)(2) requires that asbestos waste, scrap, debris, bags, containers, equipment, and contaminated clothing that is to be disposed of must be placed in sealed, labeled, impermeable bags or other closed, labeled, and impermeable containers.

Although Oregon OSHA’s rules do address asbestos waste collection, the Department of Environmental Quality is the agency that governs the disposal of all regulated waste.

The pamphlet from the American Water Works Association Pacific Northwest Section, “Recommended Standard Asbestos-Cement Pipe Work Practice Procedures and Training Requirements,” was also reviewed. The work practices and training requirements listed in this pamphlet may be outdated as 1926.1101 has been revised several times since the pamphlet’s publication date of 1989. The AWWA Pacific Northwest section was also contacted, and it was found that this pamphlet is no longer printed or distributed by them.

Although the State of Washington Department of Labor and Industries’ rules do allow exemptions for the work practices outlined in the AWWA pamphlet, Oregon OSHA does not provide for similar exemptions from the asbestos standard.

We hope this answers your question regarding asbestos. If you have any questions or if we can be of further assistance, please contact David McLaughlin at (503) 378-3272.

Sincerely,

Marilyn K. Schuster, Manager
Standards and Technical Resources Section
Oregon Occupational Safety and Health Division