Brake and clutch asbestos controls

The employer may use the Negative Pressure Enclosure/HEPA Vacuum Method, the Low Pressure/Wet Cleaning Method, the Wet Method, or a demonstrated equivalent method; for shops doing no more than five pairs of brakes or clutches per week, the limited-method in paragraph [D] may be used. See Appendix F to 1910.1001 for the required methods and conditions, and the main asbestos standard at 1910.1001 for overall asbestos requirements.

You must enclose the brake or clutch operation to cover and contain the assembly so asbestos fibers cannot escape into the worker’s breathing zone; the enclosure must be sealed, inspected for leaks before work, allow clear visibility, provide impermeable sleeves for the worker, and be kept under negative pressure with a HEPA-filtered vacuum. See Appendix F to 1910.1001 for these specific enclosure and HEPA vacuum requirements.

Yes — compressed air may be used to remove asbestos fibers or particles from inside the enclosure provided the enclosure and HEPA vacuum system are used as required. Appendix F explicitly allows compressed-air use inside the enclosure and requires that a HEPA vacuum be used first to loosen and then remove asbestos-containing residue. See Appendix F to 1910.1001 and the asbestos standard at 1910.1001.

You must first wet the full HEPA vacuum filter with a fine mist of water, then remove it and immediately place it in an impermeable container that is labeled and disposed of in accordance with paragraph (k) of 1910.1001. See the handling and disposal steps in Appendix F to 1910.1001 and the disposal requirements at 1910.1001(k).

Any spills or releases of asbestos-containing waste inside the enclosure, vacuum hose, or vacuum filter must be cleaned up immediately and disposed of according to paragraph (k) of 1910.1001. Appendix F requires immediate cleanup and points to the standard’s disposal procedures at 1910.1001(k), see Appendix F.

You must place a catch basin under the brake assembly, gently flood the assembly with an aqueous solution containing an organic solvent or wetting agent to suppress dust, allow the solution to flow between drum and support before removing the drum, thoroughly wet the hub and back of the assembly after drum removal, and wash brake components before removing old shoes; filters when full must be misted, labeled, and disposed per paragraph (k). See Appendix F to 1910.1001 for the full Low Pressure/Wet Cleaning steps and 1910.1001(k) for disposal.

The flow of liquid must be controlled so the brake assembly is gently flooded rather than splashed, ensuring brake dust is suppressed and does not become airborne. Appendix F requires controlled, gentle flooding and specifies allowing the solution to flow between the drum and support before drum removal to suppress dust; see Appendix F to 1910.1001.

No — the use of dry brushing during both Low Pressure/Wet Cleaning and the Wet Method operations is prohibited. Appendix F explicitly bans dry brushing in paragraphs describing both the Low Pressure/Wet Cleaning Method and the Wet Method; see Appendix F to 1910.1001.

Cloths used to wipe wetted brake and clutch parts must either be placed in an impermeable container labeled per paragraph (j)(4) and disposed of under paragraph (k), or be laundered in a way that prevents the release of asbestos fibers exceeding 0.1 f/cc. See the Wet Method rules and laundering/disposal requirements in Appendix F to 1910.1001 and the labeling provision at 1910.1001(j)(4).

The limited Wet Method in paragraph [D] may be used only at facilities where no more than five pairs of brakes or five clutches are inspected, disassembled, reassembled, and/or repaired per week. Appendix F sets this weekly activity limit for using paragraph [D]; see Appendix F to 1910.1001.

An equivalent method is one documented in sufficient written detail to be reproducible and demonstrated to produce employee exposures equal to or lower than those from the Negative Pressure Enclosure/HEPA Vacuum Method; the employer must show exposure results are equal to or less than the Appendix A method and meet the criteria in paragraph [C]. See Appendix F to 1910.1001 for the definition and demonstration requirements and 1910.1001 for overall asbestos obligations.

For the comparison, the employer must assume exposures from the Negative Pressure Enclosure/HEPA Vacuum Method do not exceed 0.016 fibers per cubic centimeter (f/cc) as measured by the OSHA reference method, averaged over at least 18 personal samples. Appendix F provides this exposure benchmark for equivalence testing; see Appendix F to 1910.1001.

Items wetted and removed that contain asbestos residue must be placed in impermeable containers and labeled as required by paragraph (j)(4) of 1910.1001 before disposal under paragraph (k). Appendix F references the labeling requirement at 1910.1001(j)(4) and the disposal rule at 1910.1001(k).

No — Appendix F is specific to automotive brake and clutch inspection, disassembly, repair, and assembly; large-scale building remediation is generally covered by OSHA’s construction asbestos standard [29 CFR 1926.1101] rather than the general-industry Appendix F procedures. OSHA’s interpretation on asbestos remediation protocols explains that many remediation activities are covered by the construction standard; see Appendix F to 1910.1001 and the relevant OSHA letter of interpretation, Asbestos remediation protocols.

You must seal the enclosure tightly and thoroughly inspect it for leaks, and examine the integrity of sleeves and ports so the worker can clearly see and manipulate parts before work begins. Appendix F requires these pre-work checks to ensure the enclosure contains asbestos fibers and provides visibility and intact sleeves; see Appendix F to 1910.1001.

The HEPA vacuum must be used first to loosen asbestos-containing residue from parts and then used to evacuate the loosened material from the enclosure so the material is captured in the vacuum filter. Appendix F specifies the vacuum-first loosening and then evacuation sequence to control fiber release; see Appendix F to 1910.1001.

Yes — the enclosure must let the worker clearly see the operation and must provide impermeable sleeves through which the worker can handle the brake or clutch parts; sleeves and ports must be examined before work begins to ensure integrity. See these visibility and sleeve requirements in Appendix F to 1910.1001.

Any spills of asbestos-containing aqueous solution must be cleaned up immediately and the waste disposed of according to paragraph (k) of 1910.1001. Appendix F directs immediate cleanup and refers to disposal procedures at 1910.1001(k); see Appendix F.

No — an employer’s equivalent method must be written in enough detail to be reproducible and must be demonstrated to produce employee exposures equal to or less than the Negative Pressure Enclosure/HEPA Vacuum Method, which requires exposure testing comparing to the 0.016 f/cc benchmark; Appendix F requires a demonstration of equivalence. See Appendix F to 1910.1001.

The employer must label impermeable containers holding asbestos-containing waste and filters in accordance with the labeling provisions in paragraph (j)(4) (or (j)(5) where applicable) of 1910.1001 and then dispose of the waste according to paragraph (k). Appendix F references those labeling and disposal rules; see 1910.1001(j)(4), 1910.1001(j)(5), and 1910.1001(k).

For wet-cleaning systems that use filters, the full filters must be first wetted with a fine mist of water, then removed and immediately placed in an impermeable container, labeled per paragraph (j)(4) and disposed according to paragraph (k) of 1910.1001. Appendix F describes this handling for full filters; see Appendix F to 1910.1001 and 1910.1001(k).

Yes — employers may use other methods if they can demonstrate the method is equivalent in reducing asbestos exposure and meets the requirements in paragraph [C]; the method must be reproducible and shown to keep exposures at or below the Appendix A benchmark (0.016 f/cc). See the equivalent-method provisions in Appendix F to 1910.1001.

Yes — the Wet Method requires a spray bottle, hose nozzle, or other low-pressure implement capable of delivering a fine mist to thoroughly wet parts first, so dust is suppressed and fibers are not released when parts are wiped with a cloth. Appendix F specifies fine-mist, low-pressure wetting to control dust during the Wet Method; see Appendix F to 1910.1001.