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OSHA 1910.1043

Cotton dust exposure control

Subpart Z

50 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.1043(a)(1), to which workplaces does the cotton dust standard apply in full?

Yes — 1910.1043(a)(1) says the section in its entirety applies to workplaces where employees engage in yarn manufacturing, slashing and weaving operations, or work in waste houses for textile operations. Employers in those operations must follow the full standard, including exposure limits, monitoring, controls, medical surveillance, and recordkeeping.

Under 1910.1043(a)(3), do medical surveillance and medical recordkeeping apply to cottonseed processing or waste processing operations?

Yes — 1910.1043(a)(3) states that only paragraphs (h) Medical surveillance and (k)(2) through (4) Recordkeeping - Medical Records, plus certain appendices, apply in all workplaces where employees are exposed to cotton dust during cottonseed processing or waste processing operations. Employers in those operations must follow those specific requirements.

Under 1910.1043(a)(4) and (a)(5), how does the standard apply when using washed cotton in yarn manufacturing or during the preparation of washed cotton?

The standard applies differently depending on the stage: 1910.1043(a)(4) says yarn manufacturing and slashing/weaving operations that use only washed cotton are covered only as specified in paragraph (n); while 1910.1043(a)(5) makes the section apply in its entirety to all employees exposed to cotton dust generated during the preparation of washed cotton from opening until the cotton is thoroughly wetted. In short: preparation (opening → wetting) is fully covered; later processes may have limited application per paragraph (n).

Under 1910.1043(b), how is 'cotton dust' defined and is lubricating oil mist considered cotton dust?

Cotton dust is defined broadly as dust present during handling or processing of cotton that may include plant matter, fiber, bacteria, fungi, soil, pesticides and other contaminants; dust from handling/processing through weaving/knitting and in textile mill operations using raw or waste cotton are considered cotton dust, and lubricating oil mist associated with weaving operations is not considered cotton dust, per the definition in 1910.1043(b).

Under 1910.1043(c)(1)(i)-(iii), what are the permissible exposure limits (PELs) for lint-free respirable cotton dust in yarn manufacturing, waste house operations, and slashing/weaving?

Employers must ensure exposures do not exceed the following PELs (8-hour time-weighted mean) as measured by a vertical elutriator or equivalent: yarn manufacturing and cotton washing — 200 µg/m3 (1910.1043(c)(1)(i)); textile mill waste house operations or lower grade washed cotton in yarn manufacturing — 500 µg/m3 (1910.1043(c)(1)(ii)); and slashing and weaving — 750 µg/m3 (1910.1043(c)(1)(iii)).

Under 1910.1043(c)(2)(i)-(iii), what are the action level concentrations that trigger additional requirements for yarn manufacturing, waste houses, and slashing/weaving?

The action levels (8-hour mean) that trigger additional monitoring and possibly medical surveillance or other actions are: yarn manufacturing and cotton washing — 100 µg/m3 (1910.1043(c)(2)(i)); waste houses — 250 µg/m3 (1910.1043(c)(2)(ii)); and slashing/weaving — 375 µg/m3 (1910.1043(c)(2)(iii)).

Under 1910.1043(d)(1)(i), when determining employee exposure for monitoring, should an employer account for respirator use?

No — 1910.1043(d)(1)(i) states employee exposure for the purposes of this section is the exposure that would occur if the employee were not using a respirator, so monitoring must reflect unprotected exposure.

Under 1910.1043(d)(1)(ii) and (iii), what sampler must be used for cotton dust monitoring and how is equivalency to the vertical elutriator demonstrated?

You must use either a vertical elutriator cotton dust sampler or an equivalent instrument, per 1910.1043(d)(1)(ii). Equivalency is established by meeting the criteria in 1910.1043(d)(1)(iii): (A) it must collect respirable particulates in the same ~15 µm range; (B) replicate side-by-side field and lab comparisons must be done; and (C) at least 100 samples over 0.5–2× the PEL must be collected and 90% of samples must be within ±25% of the vertical elutriator reading with 95% confidence.

Under 1910.1043(d)(1)(iv), how can a manufacturer or employer obtain OSHA's written opinion that an alternative instrument is equivalent to a vertical elutriator?

Submit a written request and supporting information to OSHA — 1910.1043(d)(1)(iv) explains OSHA will issue a written opinion if a manufacturer or employer requests one in writing and supplies sufficient test data and other requested information per 1910.1043(d)(1)(iv)(A) and OSHA finds the instrument meets the equivalency requirements.

Under 1910.1043(d)(2) and the sampling program, how often and where must initial monitoring be conducted?

Initial monitoring must obtain measurements representative of employee exposures over an eight-hour period in all workplaces within the scope (e.g., those listed in 1910.1043(a)(1), (a)(4), or (a)(5)), and the sampling program must include at least one determination during each shift for each work area, as required by 1910.1043(d)(2) and the sampling program rule.

Under 1910.1043(d)(3), how often must an employer perform periodic monitoring when exposures are at or below the PEL, or above the PEL?

When exposures are at or below the PEL, repeat monitoring at least annually (1910.1043(d)(3)(i)); when exposures are above the PEL, repeat monitoring at least every six months (1910.1043(d)(3)(ii)). Also, monitor whenever a production, process, or control change may increase exposures or whenever you suspect increased exposure (1910.1043(d)(3)(iii)).

Under 1910.1043(d)(4), how and when must employers notify employees of monitoring results?

Within 15 working days of receiving monitoring results, the employer must notify each affected employee either individually in writing or by posting the results in an accessible location, per 1910.1043(d)(4)(i). If the results show the PEL was exceeded, the notice must state that fact and describe corrective actions taken to reduce exposure, as required by 1910.1043(d)(4)(ii).

Under 1910.1043(e)(1) and (e)(2), what controls must employers use to limit cotton dust exposure and when are respirators allowed?

Employers must implement engineering and work practice controls to reduce and maintain cotton dust exposure at or below the PEL unless they can establish those controls are not feasible, per 1910.1043(e)(1). If engineering and work practice controls alone cannot achieve the PEL, employers must still institute them to reduce exposure to the lowest feasible level and supplement them with respirators in accordance with the respirator provisions (1910.1043(e)(2)). See the respirator provisions at 1910.1043(f).

Under 1910.1043(e)(3), what must a written compliance program include if monitoring shows exposures above the PEL?

You must establish a written program to reduce exposures to or below the PEL by engineering controls and work practices; the written program must include at least: a description of each operation producing exposures, engineering plans and studies used to determine controls, a report of the technology considered, monitoring data, a detailed schedule for implementing controls (including projected exposure reductions), a work practice program, and other relevant information, per 1910.1043(e)(3)(i)-(ii).

Under 1910.1043(d)(1)(iii)(A)-(C), what performance criteria must an alternative sampler meet to be considered equivalent to a vertical elutriator?

An alternative sampler must: collect respirable particulates in the same ~15 µm range (1910.1043(d)(1)(iii)(A)); use replicate side-by-side field and lab comparisons (1910.1043(d)(1)(iii)(B)); and be validated with a minimum of 100 samples over 0.5–2× the PEL with 90% of samples within ±25% of the vertical elutriator reading at a 95% confidence level (1910.1043(d)(1)(iii)(C)).

Under 1910.1043(b) and related definitions, what is 'lint-free respirable cotton dust' and what is the vertical elutriator flow rate?

Lint-free respirable cotton dust refers to particles approximately 15 micrometers aerodynamic equivalent diameter or less, and a vertical elutriator cotton dust sampler has a particle-size cut-off at about 15 micrometers when operating at a flow rate of 7.4 ± 0.2 liters per minute, as defined in the standard and sampling definitions (see 1910.1043(b) and equivalency requirements at 1910.1043(d)(1)(iii).

Under 1910.1043(a)(6), are employers in knitting, classing, or warehousing operations covered by the cotton dust standard and must they cooperate with NIOSH sampling or exams?

The standard generally does not apply to knitting, classing, or warehousing operations, but employers in these operations must, if requested by NIOSH, grant NIOSH access to employees and workplaces for exposure monitoring and medical examinations for a health study on a sampling basis, per 1910.1043(a)(6).

Under 1910.1043(e)(1) and (f), if engineering controls cannot lower cotton dust to the PEL, what must an employer do about respiratory protection?

If engineering and work practice controls are not sufficient to reduce exposure to the PEL, the employer must still implement them to the lowest feasible level and supplement them with respirators that comply with the respirator provisions in the standard, as required by 1910.1043(e)(2) and 1910.1043(f).

Under 1910.1043(d)(4)(ii), what must the employer include in the written notice when monitoring shows the PEL was exceeded?

The written notice must state that the permissible exposure limit was exceeded and provide a description of the corrective action taken to reduce exposure below the PEL, as required by 1910.1043(d)(4)(ii).

Under 1910.1043(c)(1)(ii), what is meant by 'lower grade washed cotton' and where is that term located in the standard?

The term 'lower grade washed cotton' is defined in paragraph (n)(5) of the standard, and exposures to dust from that material in yarn manufacturing are subject to the higher PEL of 500 µg/m3, per 1910.1043(c)(1)(ii) and the cross-reference to paragraph (n)(5).

Under 1910.1043(e)(3)(ii), what specific documentation must be in the written program to reduce exposures above the PEL?

The written program must document at least: (A) a description of each operation/process causing exposures above the PEL; (B) engineering plans and studies used to determine controls; (C) a report of the technology considered to meet the PEL; (D) monitoring data obtained under paragraph (d); (E) a detailed schedule for development and implementation of controls and projected exposure levels; (F) the work practice program; and (G) other relevant information, per 1910.1043(e)(3)(ii).

Under 1910.1043(e)(3)(iii), what is the deadline for implementing the employer's cotton-dust compliance program?

The employer must complete implementation of the compliance program no later than March 27, 1984, or as soon as possible if monitoring after March 27, 1984 shows exposures over the PEL (except as provided in paragraph (m)(2)(ii)(B)). See 1910.1043(e)(3)(iii). Employers must also complete the steps in their schedule by the dates specified and revise the written program when necessary to reflect current status and exposure levels; see 1910.1043(e)(3)(iv) and 1910.1043(e)(3)(vi).

Under 1910.1043(e)(4), how often must an employer check that mechanical ventilation is actually controlling cotton-dust exposures?

You must make measurements that demonstrate a ventilation system's effectiveness at reasonable intervals (for example, capture velocity, duct velocity, or static pressure), and repeat them as needed to assure continued control. See 1910.1043(e)(4).

Under 1910.1043(f)(1), when are respirators required for employees exposed to cotton dust?

Respirators must be used during periods necessary to install or implement feasible controls; for maintenance/repair where controls are not feasible; for operations where controls are not yet sufficient to reduce exposure to or below the PEL; for operations specified under paragraph (g)(1); and whenever an employee requests a respirator. See 1910.1043(f)(1).

Under 1910.1043(f)(2)(ii), what must an employer do if a physician finds an employee cannot wear a respirator?

If a physician determines an employee cannot wear a respirator (including PAPRs), the employer must offer the employee a transfer to an available position with cotton-dust concentrations at or below the PEL, ensuring the employee keeps their current wage rate and other benefits. See 1910.1043(f)(2)(ii).

Under 1910.1043(f)(3)(i)(A) and (B), what respirator types are allowed at high cotton-dust concentrations?

Filtering facepieces (for example, disposable N95s) must not be selected or used for cotton-dust concentrations greater than five times the PEL, and HEPA filters must be provided for powered and non-powered air-purifying respirators used at cotton-dust concentrations greater than ten times the PEL. See 1910.1043(f)(3)(i)(A) and 1910.1043(f)(3)(i)(B).

Under 1910.1043(f)(3)(ii), can an employee choose to use a powered air-purifying respirator (PAPR)?

Yes — if a PAPR provides adequate protection as specified by the selection criteria, the employer must provide it when the employee chooses to use a PAPR instead of a non-powered respirator. See 1910.1043(f)(3)(ii).

Under 1910.1043(g), what work-practice rules must employers follow to minimize cotton-dust exposure?

Employers must establish and implement a written work-practice program to minimize cotton-dust exposure that includes prohibiting compressed-air "blow down" cleaning where alternatives are feasible; prohibiting cleaning clothing or floors with compressed air; performing floor sweeping with a vacuum or other methods that minimize dust dispersal; and using mechanical means to handle cotton and cotton waste in areas above the PEL unless infeasible (in which case use the method that minimizes exposure). See 1910.1043(g) and 1910.1043(g)(1)-(4).

Under 1910.1043(g)(1) and (g)(2), who must leave the area during a compressed-air "blow down" and what protection must the person doing the cleaning wear?

Employees whose presence is not required to perform the "blow down" must leave the affected area during the operation, and if compressed air is used for cleaning, the employees performing the blow down must wear suitable respirators. See 1910.1043(g)(1) and 1910.1043(g)(2).

Under 1910.1043(h)(1), who must be included in medical surveillance for cotton-dust exposure and who pays for the exams?

All employees who are or may be exposed to cotton dust must be included in the medical surveillance program, and the employer must ensure that all medical examinations and procedures are performed by or under the supervision of a licensed physician and provided at no cost to the employee. See 1910.1043(h)(1).

Under 1910.1043(h)(1)(iii), who may perform the pulmonary function (spirometry) testing required by the standard?

Pulmonary function testing may be performed by persons other than licensed physicians, but those persons must have completed a NIOSH-approved training course in spirometry. See 1910.1043(h)(1)(iii).

Under 1910.1043(h)(2), what must an employer provide in the initial medical examination for new employees exposed to cotton dust?

The initial examination (to be provided prior to assignment) must include at least a medical history, the standardized questionnaire in appendix B, and pulmonary function measurements (FVC, FEV1, and FEV1/FVC) compared to race/ethnicity-specific LLN and predicted values from the NHANES III reference data set (incorporated by reference). See 1910.1043(h)(2)(i)-(iii) and 1910.6.

Under 1910.1043(h)(2)(iii), what are the timing and exposure conditions for the spirometry tests used in the initial exam?

Spirometry reference determinations must be made for each employee before the employee enters the workplace on the first day of the work week after at least 35 hours with no exposure to cotton dust; the tests must be repeated during the shift no less than 4 and no more than 10 hours after the beginning of the shift (and in any event no more than 1 hour after cessation of exposure), using exposure typical of the employee's usual workplace. See 1910.1043(h)(2)(iii).

Under 1910.1043(h)(2)(iv), how should employers grade employees for byssinosis?

Employers must grade each employee according to Schilling's byssinosis classification system based on the standardized questionnaire results. See 1910.1043(h)(2)(iv).

Under 1910.1043(h)(3), how often must periodic medical surveillance be provided?

At a minimum, employers must provide annual medical surveillance for employees exposed above the action level in yarn manufacturing, slashing and weaving, cotton washing and waste-house operations; provide medical surveillance at least every two years for employees exposed at or below the action level, employees exposed to cotton dust from washed cotton (with some exceptions), and employees in cottonseed/waste processing; and provide surveillance every six months for employees in categories specified (for example, those with certain FEV1 decrements or FEV1 below LLN). See 1910.1043(h)(3)(i) and 1910.1043(h)(3)(ii).

Under 1910.1043(h)(3)(ii)(A)-(C) and (h)(3)(iii)-(iv), which employees need six‑month follow-up, and when must an employee be referred for a detailed pulmonary exam?

Employees must be examined every six months if they are in specified categories such as those with an FEV1 decrement of 5% or 200 ml (even if >LLN), those with an FEV1 less than the LLN, or when the physician believes there has been a significant change in findings; an employee with an FEV1 less than 60% of predicted must be referred for a detailed pulmonary examination. The physician must compare current and prior results to determine significant change. See 1910.1043(h)(3)(ii) and 1910.1043(h)(3)(iii)-(iv).

Under 1910.1043(h)(4), what information must the employer give to the examining physician?

The employer must provide the examining physician a copy of the cotton-dust regulation and appendices, a description of the employee's duties as they relate to exposure, the employee's exposure level or anticipated exposure, a description of any PPE used or to be used, and relevant information from previous medical exams not readily available to the physician. See 1910.1043(h)(4).

Under 1910.1043(h)(5), what must the physician's written opinion include and what privacy limits apply?

The employer must obtain and give the employee a written opinion from the examining physician that includes the results of the medical exam and tests (FEV1, FVC, and FEV1/FVC), the physician's opinion on whether the employee has medical conditions that increase risk from cotton dust, any recommended exposure or respirator limitations and whether the employee can wear negative-pressure respirators (and if not, ability to wear a PAPR), and a statement that the employee was informed of results and follow-up needs; the written opinion must not reveal medical findings unrelated to occupational exposure. See 1910.1043(h)(5)(i)-(ii).

Under 1910.1043(i), when must employers provide cotton‑dust training and what access to materials is required?

Employers must train each employee exposed to cotton dust before initial assignment and then annually, when job assignments or processes change, and when retraining is needed based on performance; employers must post a copy of this section and appendices in a public workplace location and make training materials available to employees and, upon request, to the Assistant Secretary and the Director. See 1910.1043(i)(1)(ii) and 1910.1043(i)(2).

Under 1910.1043(e)(3)(v) and (vi), what are the employer's obligations for the written compliance program document?

The written compliance program must be available at the worksite for examination and copying by the Assistant Secretary, the Director, any affected employee or their designated representative and must be submitted to the Assistant Secretary and the Director upon request; the written program must also be revised and updated when necessary to reflect the program's current status and exposure levels. See 1910.1043(e)(3)(v) and 1910.1043(e)(3)(vi).

Under 1910.1043(j)(1), what warning sign must I post where the permissible exposure limit (PEL) for cotton dust is exceeded?

You must post a sign that reads: “DANGER COTTON DUST CAUSES DAMAGE TO LUNGS (BYSSINOSIS) WEAR RESPIRATORY PROTECTION IN THIS AREA.” This is required by 1910.1043(j)(1).

  • Note: Employers who used the older wording prior to June 1, 2016 were allowed to use the alternate legend specified in 1910.1043(j)(2).

Under 1910.1043(k)(1)(iii), how long must I keep cotton dust exposure measurement records?

You must keep exposure measurement records for at least 20 years. 1910.1043(k)(1)(iii) explicitly requires a 20-year retention period for these records.

  • Keep records in a way that they remain accessible and legible for the full 20 years.

Under 1910.1043(k)(1)(ii), what specific information must exposure measurement records include?

Exposure measurement records must include: (A) a log with the items listed in paragraph IV(a) of Appendix A plus dates, number, duration, and results of each sample taken and a description of how representative employee exposure was determined; (B) the type of protective devices worn and how long they were worn; and (C) the names, job classifications, and exposure levels of the employees the measurements represent. See 1910.1043(k)(1)(ii)(A)-(C).

  • If you use sampling protocols or a particular sampling device, document the procedure so the measurements can be interpreted and audited.

Under 1910.1043(k)(2)(ii) and (k)(2)(iii), what must medical surveillance records for cotton-dust‑exposed employees contain and how long must I keep them?

Medical surveillance records must include the employee's name and job duties; a copy of the medical exam results including history, questionnaires, tests, and the physician's recommendation; a copy of the physician's written opinion; any employee medical complaints related to cotton dust; a copy (or referenced copy) of the standard and appendices; and the information given to the physician under [1910.1043(h)(4)]. These records must be kept for at least 20 years. See 1910.1043(k)(2)(ii)(A)-(F) and 1910.1043(k)(2)(iii).

  • Employers may keep a single copy of the standard and its appendices for reference and simply note the reference in each employee’s medical record as allowed by [1910.1043(k)(2)(ii)(E)].

Under 1910.1043(k)(3)(ii) and 29 CFR 1910.1020, what access do employees and their representatives have to cotton dust exposure and medical records?

Employees, their designated representatives, and OSHA (the Assistant Secretary) are entitled to access exposure measurement and medical records on request in accordance with the access provisions of 29 CFR 1910.1020. See 1910.1043(k)(3)(ii) and the employee access rules at 1910.1020(a) through 1910.1020(e) and 1910.1020(g) through 1910.1020(i).

  • If access requires special arrangements (for privacy or confidentiality), follow the procedures in [1910.1020] to provide timely copies or inspection.
  • Provide records promptly when requested by the employee or their representative, consistent with [1910.1020].

Under 1910.1043(k)(4)(i) and 1910.1020(h), who must retain cotton-dust records when the employer goes out of business, and what steps must be taken?

When an employer ceases to do business, the successor employer must receive and retain all records required by the cotton dust standard, and the transfer must also comply with any additional transfer-of-records requirements in [29 CFR 1910.1020(h)]. See 1910.1043(k)(4)(i) and 1910.1043(k)(4)(ii).

  • Document the transfer so records remain retrievable for required retention periods and notify employees or their representatives how to access the transferred records, per [1910.1020(h)].

Under 1910.1043(l)(1)-(2), can employees or their representatives observe cotton-dust exposure monitoring, and what must the employer provide if observation requires entry into a PPE area?

Yes—affected employees or their designated representatives must be given an opportunity to observe any measuring or monitoring of employee exposure to cotton dust. If observation requires entering an area where personal protective equipment (PPE) is required, the employer must provide the observer with the necessary PPE and ensure they follow all applicable safety procedures. See 1910.1043(l)(1)-(2).

  • Ensure observers understand and comply with site safety rules; document that observers were offered and used PPE when required.

Under 1910.1043(m)(2) and (m)(4), what documentation do I need to claim a washed-cotton exemption and what washing conditions are required for exemption?

To claim an exemption or partial exemption for washed cotton, you must demonstrate the cotton was washed in a facility open to inspection by OSHA and provide accurate documentary evidence that the washer’s methods meet the standard’s requirements. If the cotton was washed by a third-party washer, you must obtain and make available at the worksite a certification of cotton grade and washing process, documentation of the grades and process, and an authorization for OSHA to inspect the washer’s facility and records. See 1910.1043(m)(2).

  • For certain grades ("low middling light spotted or better"), washed cotton is exempt from most provisions only if washed on approved systems that meet the conditions in 1910.1043(m)(4)(i) (continuous batt or rayon rinse systems at ≥60 °C, water-to-fiber ratio ≥40:1, bacterial control) or 1910.1043(m)(4)(ii) (batch kier systems with specified temperature, water ratios, wash/rinse cycles, and bacterial control).
  • If you mix grades, follow the requirements for the grade with the most stringent limits per 1910.1043(m)(6).