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Standard Interpretations
06/04/1986 - Tufting of undyed and unwashed cotton is not covered in the scope of the revised cotton standard of December 13, 1985. |
Standard Interpretations - Table of Contents |
Standard Number: | 1910.1043 |
June 4, 1986
Mr. Richard N. Hopper Dear Mr. Hopper: This is in response to your letter of March 27 to Dr. Susan Harwood, concerning the tufting of undyed and (we presume) unwashed cotton. Please excuse the delay in our response. This operation is not included in the scope of the revised cotton dust standard of December 13, 1985, nor is it included in the scope of the permissible exposure limit for cotton dust contained in Table Z-1 of 29 CFR 1910.1000. But it is also not in the list of excluded operations, processes and industries listed in the standard. The operation is not covered because it slipped past the attention of the Occupational Safety and Health Administration (OSHA) and was not considered during the rulemaking procedures. Therefore, no inferences should be drawn about the nature of the health hazard from the fact that it is not covered by OSHA's standard. We appreciate the opportunity to clarify this matter for you. If you have further questions, please do not hesitate to contact us.
Sincerely,
Dr. Susan Harwood Dear Dr. Harwood: The Carpet and Rug Institute is the national trade association of American carpet and rug manufacturers. Included in the members are small rug manufacturers who makes throw rugs for bathrooms, children's rooms, etc. These rugs are made by tufting or inserting a face yarn into a performed back and anchoring these yarns into the back with some type of latex backing compound. The manufacturers purchase undyed yarns and dye the small rugs after the tufting operation. Since these small rug manufacturers are not engaged in yarn manufacturing, slashing, weaving or involved with waste for textiles, it would appear they would be exempted from the Occupational Exposure to Cotton Dust Rule. Would appreciate your confirming this.
Sincerely,
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Standard Interpretations - Table of Contents |
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