Wayne State University

Aim Higher

Office of Environmental Health and Safety

Formaldehyde Guidelines

  1. EXPOSURE MONlTORING
     
    1. Health Hazard
      Formaldehyde gas, all mixtures or solutions composed of greater than 0.1 percent formaldehyde, and materials capable of releasing formaldehyde into the air under any normal condition of use at concentration reaching or exceeding 0.1 ppm shall be considered a health hazard. Employees exposed to this hazard or who have health complaints possibly related to formaldehyde exposure, shall be monitored to determine their exposure to formaldehyde.
       
    2. Exception
      Monitoring is not required if by using objective data it can be documented that the presence of formaldehyde or formaldehyde releasing products in the workplace cannot result in airborne levels of formaldehyde at or above the action level or STEL under foreseeable condition of use.
       
    3. Initial Monitoring
      The employer shall identify all employees who may be exposed at or above the action level or above the STEL and may use a representative sampling strategy to correctly characterize and not underestimate the exposure of any employee within each exposure group. This monitoring process shall be repeated each time there is a change in the production, equipment, process, personnel, or control measures which may result in new or additional formaldehyde exposure.
       
    4. Periodic Monitoring
      Employees exposed at or above the action level shall be monitored at least every six months and those exposed at or above the STEL shall be monitored at least once a year under the worst conditions. Monitoring may be discontinued when results from two consecutive sampling periods taken at least seven days apart show employee exposures below the action level or STEL.
       
    5. Employee Notification
      Employees or their designated representatives shall be allowed to observe monitoring of employee exposure. Within fifteen days of receiving monitoring results, affected employees shall be notified of the result either by written copies or by posting the results. When exposures are found in excess of either permissible exposure limit, a written plan describing action to be taken to reduce exposure to at or below the PEL shall be developed and implemented. A written notice describing the corrective action to be taken to decrease employee exposure shall be given to the affected employees.
       
  2. REGULATED AREAS

      Regulated areas shall be established where airborne formaldehyde levels exceed either the permissible exposure level of 0.75 ppm or the STEL. The following sign shall be posted at all entrances and accessways:

      DANGER
      FORMALDEHYDE
      IRRITANT AND POTENTIAL CANCER HAZARD
      AUTHORIZED PERSONNEL ONLY

  3. COMPLIANCE METHODS

      Engineering and work practice controls shall be instituted to reduce and maintain formaldehyde exposures at or below the PEL of 0.75 ppm and STEL.

      However, when it has been established that feasible controls cannot reduce exposures to acceptable levels, they shall be used to the extent feasible and supplemented with respiratory protection that satisfies the standard.

  4. RESPIRATORY PROTECTION

      The standard permits the use of respiratory protection when engineering or work practice controls are not feasible or during the period when feasible controls are being implemented. It describes the kinds of respirators that are permitted under conditions of use or concentration of formaldehyde. It also requires the company to have a respiratory protection program in compliance with OSHA 29 CFR 1910.134 (b), (d), (e), and (f); and to perform either quantitative or qualitative face fit tests in accordance with the procedures outlined in appendix E of the formaldehyde standard at the time of initial fitting and at least annually thereafter for all employees required to wear negative pressure respirators.

  5. PROTECTIVE EQUIPMENT AND CLOTHING
     
    1. Selection
      Employees shall comply with provisions of OSHA 29 CFR 1910.132 and 29 CFR 1910.133, and shall select protective equipment and clothing based upon the form in which formaldehyde is encountered, the conditions of use, and the hazards to be prevented. Eye and skin contact with liquids containing one percent or more formaldehyde shall be prevented by use of clothing impervious to formaldehyde and use of goggles and face shields as appropriate to the operation. Full body protection shall be worn for entry into areas where concentration exceed 100 ppm and emergency entry into areas of unknown concentration.
       
    2. Maintenance
      Formaldehyde contaminated protective equipment and clothing shall be cleaned or laundered before reuse. A storage area shall be established to ventilate contaminated clothing and equipment to minimize employee exposure. Storage areas and containers for contaminated clothing and equipment shall have labels and signs as follows:

      3. DANGER
      FORMALDEHYDE-CONTAMINATED (CLOTHING) EQUIPMENT
      AVOID INHALATION AND SKIN CONTACT

    3. Employer Responsibility
      The employer shall assure that:
      1. Only persons trained to recognize the hazards of formaldehyde are assigned to cleaning, laundering or disposal;
      2. No employee takes contaminated equipment or clothing home;
      3. All required protective clothing and equipment is repaired and replaced for each affected employee as necessary for continued effectiveness; and
      4. Any person who launders, cleans or repairs contaminated equipment or clothing is informed about potentially harmful effects of formaldehyde and of procedures to safely perform their assignment.
         
  6. HYGIENE PROTECTION
     
    1. Skin Protection
      Change rooms in compliance with OSHA 29 CFR 1910.141 shall be provided for employees required to change from regular clothing into protective clothing to avoid skin contact with formaldehyde. Where employee's skin may be splashed with solution containing one percent or more formaldehyde, employers shall provide conveniently located quick drench showers and assure that employees use them.
       
    2. Eye Protection
      Where the possibility exists that an employee's eye may be splashed with solution containing 0.1 percent or more formaldehyde, employers shall provide eyewash facilities within the immediate work area.
       
  7. HOUSEKEEPING
     
    1. Spills and Leaks
      Employers shall conduct a program to detect leaks and spill, including regular inspections, and shall undertake preventive maintenance at regular intervals where liquid or gaseous formaldehyde is used;
       
    2. Containment, Decontainment and Disposal
      Where leaks or spills may occur, provisions shall be made for containment, contamination, and waste disposal. Employers shall assure that leaks are repaired and spills cleaned up promptly by trained and appropriately protected employees, and that formaldehyde waste and debris are disposed of in sealed containers bearing a label warning of the presence of formaldehyde and hazards associated with it.
       
  8. EMERGENCIES

      Employers shall assure appropriate procedures are used to minimize injury or loss of life where emergencies involving formaldehyde may occur.

  9. MEDICAL SURVEILLANCE
     
    1. Employees Covered
      Medical surveillance programs shall be instituted for all employees exposed to formaldehyde at or above the action level or STEL. The program shall be available to employees who develop signs and symptoms of formaldehyde overexposure and to all employees exposed in emergencies. It is pointed out that sign and symptoms associated with formaldehyde exposure occurs only in exceptional circumstances when exposure is less than 0.1ppm and formaldehyde is present in materials in less than 0.1 percent concentration.
       
    2. Physician Examination
      The examination and medical procedures shall be performed by or under the supervision of a licensed physician and shall be provided to employees without cost or loss of pay, and at a reasonable time and place. The following medical surveillance shall be made available to employees prior to a job assignment and annually thereafter where formaldehyde exposure is at or above the action level or above the STEL, and also where it has been determined that an employee is experiencing signs and symptoms indicating possible overexposure to formaldehyde:
       
      1. Administration of medical disease questionnaire such as one detailed in appendix D of the standard that elicits information on work history, smoking history, evidence of nose, eye or throat irritation, etc.;
         
      2. A determination by the physician based on evaluation of the questionnaire whether a medical examination is necessary for employees not required to wear respirators to reduce formaldehyde exposure.
         
    3. Medical Examination
      This examination shall be given to any employee who the physician feels, based on the medical questionnaire, may be at increased risk from formaldehyde exposure. The examination shall also be given at the time of initial assignment, and at least annually thereafter, to all employees required to wear a respirator for protection. The examination shall include:
       
      1. A physical examination emphasizing skin and respiratory system irritation and/or sensitization or eye irritation;
      2. Laboratory examination for respirator wearer consisting of baseline and annual pulmonary function tests;
      3. Any other tests deemed by the physician as necessary to complete a written opinion;
      4. Counselling employees with medical conditions that would be directly or indirectly aggravated by formaldehyde exposure on the increased risk of health impairment.
         
    4. Emergencies
      The employer shall make medical examinations available as soon as possible to all employees exposed in an emergency and it shall include medical and work history and any other elements considered appropriate by the examining physician.
       
    5. Physical Information
      The employer shall provide the examining physician with a copy of the standard and Appendices A, C, D, and E; a job description of exposed employees; representative exposure levels; information on respiratory and personal protective equipment; previous medical examination information controlled by employer; and detailed description of emergency exposures, including exposures employees may have received.
       
    6. Physician Opinion
      The employer shall obtain a written opinion for each required examination containing results of the medical examination, except specific findings or diagnoses unrelated to formaldehyde exposure.
       
  10. HAZARD COMMUNICATION

      Formaldehyde gas, all mixtures or solution composed of greater than 0.1 percent formaldehyde, and materials capable of releasing formaldehyde into the air under any normal condition of use at concentration reaching or exceeding 0.1 ppm shall be considered a health hazard and shall be handled in compliance with the OSHA Hazard communications Standard 1910.1200 parts (e) through (j).

  11. EMPLOYEE INFORMATION AND TRAINING
     
    1. Participation
      All employees assigned to workplaces having a formaldehyde health hazard, as defined in section 1(A), shall participate in a training program. Information and training shall be provided at the time of initial assignment and whenever a new formaldehyde hazard is introduced; and at least annually for employees exposed to formaldehyde at or above the action level or STEL.
       
    2. Training Program
      The training program shall be conducted in a readily understood way and shall include:

      1. A discussion of this standard and contents of Material Safety Data Sheets;
      2. Purpose for and description of the medical surveillance program;
      3. Description of potential health hazards associated with formaldehyde exposure, as well as signs and symptoms of exposure;
      4. Immediate reporting of any adverse signs or symptoms that employee may relate to formaldehyde exposure;
      5. Description of formaldehyde work areas and operations and safe work practices for limiting exposure at each job;
      6. Purpose, use and limitations of protective clothing and equipment;
      7. Handling of spills, emergencies and clean-up;
      8. Review of emergency procedures including each employee's specific duties or assignments.
         
    3. Training Material Access
      The employer shall inform all affected employees of the written training material location and shall make these available at no cost; and upon request, shall provide this material to the Assistant Secretary of Labor, and Director of the National Occupational Safety and Health (NIOSH).
       
  12. RECORD KEEPING
     
    1. Exposure Measurements
      An accurate record of all measurements taken to monitor formaldehyde exposure shall be established and maintained to include:

      1. measurement date;
      2. operation monitored;
      3. sampling and analysis method with evidence of accuracy and precision;
      4. number, duration, time and results of samples taken;
      5. protective devices worn and;
      6. names, job classifications, social security numbers, and exposure estimates of employees whose exposures are represented by the actual monitoring results.
         
    2. Exposure Determination
      Where it has been determined that monitoring is required, the employer shall maintain a record of the objective data relied upon for the determination that no employee is exposed at or above the action level.
       
    3. Medical Surveillance
      An accurate record shall be maintained for each employee subject to medical surveillance which shall include name and social security number of employee, physician's written opinion, employee's health complaints that may be related to formaldehyde exposure, and a copy of medical examination results.
       
    4. Respirator Fit Tests
      Accurate records for employees subject to negative pressure respirator fit testing shall be established and maintained to include a copy of the fit testing protocol, the results of any fit testing performed, size and manufacturer of respirators available, tested employee, and the respirator type and facepiece selected.
       
    5. Record Retention
      Records required by this standard shall be retained for at least 30 years on exposures and determinations; for duration of employment plus 30 years for medical records; and records on fit testing shall be kept until replaced by a more recent record.
       
    6. Availability of Records
      Upon request, all records maintained shall be made available for examination and copying to the Assistant Secretary of Labor and Director of NIOSH. Employee exposure records including estimates from representative monitoring shall be made available upon request for examination and copying to the subject employee, former employee, and employee representatives in accordance with OSHA 29 CFR 1910.20 parts (a) through (e), and (g) through (i).

      Medical records required by this standard shall be provided upon request for examination and copying to the subject employee and former employee or to anyone having the specific written consent of the subject employee or former employee