OSHA

The standard does not require employers to demonstrate that wet methods, a HEPA-filtered vacuum, or other methods are impossible to use in order to establish “infeasibility” for purposes of paragraph (f). As explained in the preamble to the standard, the limited “infeasibility” exceptions included in these housekeeping provisions are intended to encompass situations where wet methods, HEPA-filtered vacuuming, and other exposure-minimizing methods are not effective, would cause damage, or would create a hazard in the workplace. See 81 Fed. Reg. at 16795-96. For example, an employer can establish infeasibility for these purposes by demonstrating that wet sweeping, using a HEPA-filtered vacuum, and other methods that minimize the likelihood of exposure would negatively impact the quality of the work being done. However, even in cases where one of the acceptable cleaning methods may not be feasible, employers may be able to use another acceptable cleaning method.