Under the standard, an employer may not allow the use of dry sweeping or dry brushing where such activity could contribute to employee exposure to silica unless wet sweeping, HEPA-filtered vacuuming, or other methods that minimize the likelihood of exposure are not “feasible.” 29 C.F.R. § 1926.1153(f)(1). The standard contains a similar prohibition on the use of compressed air to clean clothing or surfaces; such use is prohibited unless the compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air or “[n]o alternative method is feasible.” 29 C.F.R. § 1926.1153(f)(2). What is the definition of “feasible” in this context?

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.