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OSHA 1915.1001AppL

Brake and clutch work practices

Subpart Z

21 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.1001AppL, what work methods can an employer use for automotive brake and clutch inspection, disassembly, repair, and assembly?

The employer must use either the Negative Pressure Enclosure/HEPA Vacuum method, the Low Pressure/Wet Cleaning method, an employer-demonstrated equivalent method, or — for facilities doing no more than 5 pairs of brakes or 5 clutches per week — the Wet Method. See Appendix L to 1915.1001 for the full list and conditions.

Under 1915.1001AppL [A], what are the key requirements for a negative-pressure enclosure/HEPA vacuum system when working on brakes or clutches?

You must fully enclose the operation so asbestos fibers cannot reach the worker’s breathing zone, seal and inspect the enclosure for leaks before starting, provide clear view and impermeable sleeves for handling parts, and operate a HEPA-filtered vacuum to keep the enclosure under negative pressure throughout the job. See the Negative Pressure Enclosure/HEPA Vacuum System Method in Appendix L for the specific elements.

Under 1915.1001AppL, can compressed air be used when using a negative-pressure enclosure or HEPA vacuum?

Yes — compressed air may be used to remove asbestos fibers or particles from inside the enclosure, but it must be used with the enclosure and HEPA vacuum controls in place so fibers are contained and captured. See the Negative Pressure method in Appendix L to 1915.1001.

Under 1915.1001AppL [A], what sequence must be followed when using the HEPA vacuum on brake or clutch parts?

You must first use the HEPA vacuum to loosen asbestos-containing residue from parts and then use it to remove and capture the loosened material in the vacuum filter. See the HEPA vacuum sequence in Appendix L to 1915.1001.

Under 1915.1001AppL [A](6) and (k)(8)/(l), how must a full HEPA vacuum filter be handled and disposed?

A full HEPA vacuum filter must first be wetted with a fine mist of water, then removed and immediately placed into an impermeable container that is labeled per paragraph 1915.1001(k)(8) and disposed according to paragraph 1915.1001(l). See Appendix L for the vacuum filter steps.

Under 1915.1001AppL [A](7) and [B](7), how must spills or releases of asbestos-containing waste from the enclosure or vacuum be handled?

Any spills or releases inside the enclosure or from the vacuum system must be cleaned up immediately and the waste disposed of in accordance with paragraph 1915.1001(l). See these cleanup requirements in Appendix L to 1915.1001.

Under 1915.1001AppL [B], what are the main steps for the Low Pressure/Wet Cleaning method on brakes and clutches?

You must place a catch basin under the brake assembly to avoid splashes, use water with an organic solvent or wetting agent in the reservoir, control flow to gently flood the assembly so dust is suppressed, allow the solution to flow between drum and support before removing the drum, and thoroughly wet and wash the hub, assembly back, support plate, shoes, and attaching components. See the Low Pressure/Wet Cleaning Method in Appendix L for the full procedure.

Under 1915.1001AppL, is dry brushing allowed during Low Pressure/Wet Cleaning or Wet Method operations?

No — the use of dry brushing during Low Pressure/Wet Cleaning operations is expressly prohibited, and the Wet Method also prohibits dry brushing during those operations. See the prohibition in Appendix L to 1915.1001.

Under 1915.1001AppL [D], what are the requirements for the Wet Method that may be used when a facility inspects no more than 5 pairs of brakes or 5 clutches per week?

For small-volume shops, the Wet Method requires first thoroughly wetting parts with a fine mist (spray bottle, hose nozzle, or similar low-pressure delivery), wiping parts clean with a cloth, placing used cloths into impermeable labeled containers for disposal per 1915.1001(l) or laundering them so they do not release asbestos above 0.1 f/cc, and immediately cleaning up any spills. These steps are described in Appendix L to 1915.1001.

Under 1915.1001AppL [D](2), how must used cleaning cloths be handled or laundered after the Wet Method?

Used cloths must either be placed in an impermeable container, labeled under 1915.1001(k)(8) and disposed per 1915.1001(l), or laundered in a way that prevents release of asbestos fibers in excess of 0.1 fibers per cubic centimeter of air. See Appendix L to 1915.1001.

Under Appendix L, what does OSHA mean by an "equivalent method" and what must an employer demonstrate to use one?

An equivalent method must be written in sufficient detail to be reproducible and must be demonstrated to produce exposures equal to or less than those from the Negative Pressure/HEPA method described in paragraph [A]. The employer must show the method's exposures are equal to or lower than the Appendix A method. See the Equivalent Methods description in Appendix L to 1915.1001.

Under Appendix L, what exposure level should an employer use when comparing an equivalent method to the Negative Pressure/HEPA method?

For comparison, employers must assume the Negative Pressure/HEPA method will not exceed 0.016 fibers per cubic centimeter (f/cc) as measured by the OSHA reference method and averaged over at least 18 personal samples. See the comparison parameter in Appendix L to 1915.1001.

Under 1915.1001AppL, what must be done when filters in wet-cleaning systems become full?

When filters in systems using filters become full, they must be wetted with a fine mist of water, removed immediately, placed in an impermeable container, labeled per 1915.1001(k)(8), and disposed of according to 1915.1001(l). See the Low Pressure/Wet Cleaning and Appendix L text at Appendix L to 1915.1001.

Under 1915.1001AppL, must the enclosure integrity and sleeve condition be checked before starting Negative Pressure/HEPA work?

Yes — the enclosure must be sealed tightly and thoroughly inspected for leaks, and the integrity of sleeves and ports must be examined before work begins. See the inspection requirements in Appendix L to 1915.1001.

Under 1915.1001AppL, are employers allowed to use alternative wetting agents or solvents in Low Pressure/Wet Cleaning?

Yes — the Low Pressure/Wet Cleaning method specifies using water containing an organic solvent or wetting agent in the reservoir, provided the flow is controlled to gently flood components and suppress dust. See the Low Pressure/Wet Cleaning steps in Appendix L to 1915.1001.

Under Appendix L and OSHA letters of interpretation, can an employer rely on residential or EPA clearance levels instead of demonstrating occupational exposures when proposing an equivalent method?

No — employers must demonstrate occupational exposures using appropriate industrial sampling and cannot substitute EPA residential clearance values for occupational exposure assessments; OSHA does not endorse employer protocols that simply use EPA school/clearance criteria for occupational compliance. See the exposure-comparison requirement in Appendix L to 1915.1001 and OSHA's interpretation discussing asbestos sampling protocols and the inapplicability of EPA clearance levels to OSHA exposure requirements in Asbestos sampling protocol requirements (Oct. 7, 2015).

Under 1915.1001AppL, what should an employer do if it wants to demonstrate an "equivalent method" will achieve exposures at or below the Negative Pressure method?

The employer must produce a written, reproducible procedure and then document exposure measurements showing that employee exposures from the proposed method are equal to or less than the 0.016 f/cc benchmark (the assumed exposure for the Negative Pressure method), using representative personal sampling. See the Equivalent Methods requirements in Appendix L to 1915.1001 and the exposure-comparison guidance in the same appendix.

Under 1915.1001AppL, what controls are required to prevent splashes and spills during Low Pressure/Wet Cleaning?

You must use a catch basin positioned to avoid splashes and spills, control the flow so the assembly is gently flooded (not blasted), and avoid practices that cause aerosolization of asbestos dust; follow the Low Pressure/Wet Cleaning steps in Appendix L to 1915.1001.

Under Appendix L, how does OSHA expect employers to label asbestos-containing waste and containers used for filters or cloths?

Asbestos-containing waste, full filters, and cloths placed in impermeable containers must be labeled in accordance with paragraph 1915.1001(k)(8), and disposed of following 1915.1001(l). See the disposal and labeling requirements referenced in Appendix L to 1915.1001.

Under 1915.1001AppL, if a shop does only a few brake or clutch jobs each week, does that relieve them from following any asbestos controls?

No — small volume does not eliminate controls; it only allows the employer, for facilities performing no more than 5 pairs of brakes or 5 clutches per week, to use the Wet Method in paragraph [D]. All other hygiene, labeling, cleanup, and disposal rules still apply. See the small-shop provision in Appendix L to 1915.1001.

Under Appendix L and OSHA guidance, can employers rely on point counting bulk results alone to assume safety for brake and clutch work?

No — OSHA has not endorsed point-counting or bulk-percent rules as showing an asbestos exposure is safe; bulk analysis may trigger regulatory requirements but does not substitute for exposure controls and sampling. See Appendix L to 1915.1001 and OSHA's discussion about bulk analysis and point counting in the Letter of Interpretation "Asbestos point counting regulations" (Nov. 5, 2014).