Formaldehyde Safety 29 CFR 1910 1048 Subpart Z

Formaldehyde Safety 29 CFR 1910. 1048 Subpart Z Formaldehyde PPT--058 -01 Bureau of Workers’ Comp PA Training for Health & Safety (PATHS) 1

Program Topics v. Properties v. Uses v. Exposures v. Monitoring v. Compliance with 29 CFR 1910. 1048 PPT--058 -01 2

Program Topics v. Personal Protective Equipment (PPE) v. Medical Surveillance v. Hazard Communication and Training v. Records v. Bibliography PPT--058 -01 3

Glossary of Terms* v TLV-TWA = Threshold Limit Value-Time Weighted Average. Air concentration under which most people can work for 8 hours a day. v PEL = Permissible Exposure Limit. OSHA enforced; 8 hour airborne concentration. v PPM = Parts per million. Method of reading concentrations. v STEL = Short Term Exposure Limit. Amount to which persons may be exposed for 15 minutes. *Terms can also be found in the NIOSH Pocket Guide to Chemical Hazards -- http: //www. cdc. gov/niosh/npg PPT--058 -01 4

Glossary of Terms* v IDLH = Immediately Dangerous to Life & Health. Conditions which pose an immediate threat to life or health. v UEL = Upper Explosive Limit. Greatest amount of vapor/gas mixed with air where combustion can occur. v LEL = Lower Explosive Limit. Least amount of vapor/gas mixed with air where combustion can occur. *Terms can also be found in the NIOSH Pocket Guide to Chemical Hazards -- http: //www. cdc. gov/niosh/npg PPT--058 -01 5

29 CFR 1910. 1048, Subpart Z This Formaldehyde standard applies to all occupational exposures: • From formaldehyde gas, • Its solutions, and • Materials which release formaldehyde Requirements applicable to construction work under 29 CFR 1926. 1148 are identical to those set forth at 1910. 1048 of this chapter PPT-058 -01 6

OSHA General Duty Clause Section 5(a)(1)of the Occupational Safety and Health Act (OSHA), known as the General Duty Clause, provides that an employer must "furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees. ” Section 5(a)(2) requires employers to "comply with occupational safety and health standards promulgated under this Act. " Formaldehyde, Environmental Health and Safety Information PPT-058 -01 7

Formaldehyde One of a variety of aldehydes Webster’s dictionary for aldehyde: “…Abbreviation of alcohol dehydrogenatum dehydrogenated alcohol; Acetaldehyde; broadly: any of various highly reactive compounds typified by acetaldehyde and characterized by the group CHO. ” Formaldehyde is “an important precursor to many other chemical compounds, especially for polymers. ” PPT-058 -01 8

Formaldehyde In 2003: Estimated over 4 million people work in the formaldehyde industry Value of sales of formaldehyde and derivative products was over $145 billion 2005 annual worldwide production estimated at 50 billion pounds PPT-058 -01 9

Formaldehyde Is naturally occurring but can be produced by the oxidation of methanol June 10, 2011, US National Toxicology Program (NTP) indicated formaldehyde was “known to be a human carcinogen” Also known as: o Methanal o Formol o Methyl aldehyde o Methylene glycol o Methylene oxide PPT-058 -01 10

Formaldehyde Properties IDLH: Ca (20 ppm) Carcinogen OSHA PEL: TWA 0. 75 PPM STEL: 2 PPM as a 15 -minute STEL Nearly colorless gas with pungent, suffocating odor. Often used in aqueous solution, Formalin Pure formaldehyde has tendency to polymerize MW: 30. 0 Sol: Miscible IP: 10. 88 e. V RGas. D: 1. 04 (vapors are minimally heavier than air) UEL: 73% LEL: 7. 0% Flammable Gas Ignition temperature: 806 degrees F NIOSH Pocket Guide to Chemical Hazards, DHHS, 2005 PPT-058 -01 11

Forms/Derivatives Formaldehyde can result from combustion of carbon compounds: o wood products o tobacco o automobile exhaust “The European Union decided on September 22, 2007 to ban formaldehyde use throughout Europe because of its carcinogenic properties. ” http: //sargentipaste. org/formaldehyde_FDA. html PPT-058 -01 12

Derivatives Many materials are made from formaldehyde “Relatives” = other materials which could be created due to chemical interactions with formaldehyde Formalin is one of these “relatives” PPT-058 -01 13

Formalin Water solution with 40% formaldehyde by volume or 37% by mass is called “ 100% Formalin” PPT-058 -01 14

Formalin Properties IDLH: Ca (20 PPM) OSHA PEL: 0. 75 PPM TWA STEL: 2 PPM An aqueous solution that is 37% formaldehyde by weight; inhibited solutions usually contain 6 -12% methyl alcohol MW: Varies Formalin Sol: Miscible IP: ? Specific Gravity: 1. 08 UEL: 73% LEL: 7% Class IIIA Combustible Liquid DOT: UN 1198 Guide # 132 or UN 2209 Guide #132 NIOSH Pocket Guide to Chemical Hazards, DHHS, 2005 PPT-058 -01 15

Other Derivatives Types Uses • Urea formaldehyde resin • Melamine resin • Phenol formaldehyde resin • Polyoxymethylene plastics • Building insulation • Plastics • Coatings and adhesives PPT-058 -01 16

Formaldehyde • Sunlight and bacteria in the environment break down formaldehyde • The human body quickly metabolizes formaldehyde converting it into formic acid • Formic acid in large amounts and concentrations can be harmful • Ant bites contain formic acid PPT-058 -01 17

Uses Drug testing Industrial applications: o Fabrics o Facial tissues, napkins and towels o Foamed insulation o Moulded products o Paints o Woodworking and cabinet making o Glues for bonding particle board PPT-058 -01 18

Uses o Precursor for chemical compounds (polymers) o Solutions of formaldehyde (formalin) used as: - Disinfectants - Preserving biological specimens o Permanent adhesives used in plywood and carpeting o Used to kill bacteria in toxoid vaccines o Also used in explosive production: - PETN - RDX PPT-058 -01 19

Uses: Dentistry Formocresol procedure: Formocresol is soaked in cotton pellets then placed in contact with the circulatory system in the open crown of the tooth Called “a baby root canal” procedure, injury has resulted! PPT-058 -01 20

Uses: Residences PPT-058 -01 21

Uses: Construction Materials o Used as a preservative o In residential conditions it can off-gas from wood products or other items containing formaldehyde o Such releases may occur from: ü Paints ü Varnishes ü Smoking PPT-058 -01 22

Uses: Insulation: Urea-formaldehyde foamedin insulation (UFFI) in homes Levels as low as 0. 046 PPM were correlated with eye and nasal irritation levels around 1. 9 PPM produced significant pulmonary function damage PPT-058 -01 23

Levels Found in Buildings Depends on: q Potency of emitting materials q Surface area to volume ratio q Environmental factors, like humidity and temperature q Age of emitting product q Ventilation available or lacking PPT-058 -01 24

Uses: Vehicle PPT-058 -01 25

Uses: Trailers were used for temporary housing for flood victims in 2006 in the US Persons using the trailers reported symptoms tracked down to exposure to formaldehyde found in the trailer paneling FEMA has since announced formaldehyde limits in trailers to be bought by them PPT-058 -01 26

Uses: Hair Salons Those who use the following salon products must follow the OSHA Standard 29 CFR 1910. 1048 if hair smoothing products contain: §Methylene glycol §Formalin All of these are names for, or treated as, formaldehyde in §Methylene oxide OSHA’s Formaldehyde standard!!! §Paraform §Formic aldehyde §Methanal §Oxomethane §Oxymethylene or §A material with a CAS # of 50 -00 -0 §Timonacic acid which can release formaldehyde under certain conditions PPT-058 -01 27

Uses: Hair Salons Brazilian Blowout in hair salons Excellent! PPT-058 -01 28

Product Labels If a product contains 0. 1% or more formaldehyde or can release formaldehyde into air above 0. 1 PPM, its label must include: § Statement that the product has formaldehyde in it; § Name and address of manufacturer, importer, or other company responsible for the product § Statement that employer and SDSs can readily give health hazard information PPT-058 -01 29

Label Requirements Additionally, if product can release formaldehyde into air above 0. 5 PPM, label must have: § A list of all product health and safety hazards, § The phrase “Potential Cancer Hazard” PPT-058 -01 30

Product (SDS) Information 1. Name of product used on its label 2. Name (including common names) of all hazardous chemicals in product at more than 1% (or more than 0. 1% for carcinogens) or that could be released above OSHA limits into air or could be a health risk to employees 3. Health & safety information for each listed hazardous chemical (physical properties and health hazards) 4. Common ways people are exposed 5. Exposure limits in the air PPT-058 -01 31

Product (SDS) Information 6. Whether chemical is listed as a carcinogen by OSHA, IARC* or NTP* 7. How to safely store and use the product; what PPE to wear and what to do during an emergency 8. Name, address and telephone number of company or person responsible for preparing the MSDS (SDS) and the date it was last changed. *IARC=International Association of Research Chemists *NTP=National Toxicology Program PPT-058 -01 32

Salon Employer’s Duties If tests show formaldehyde is above 0. 75 PPM of air during 8 -hour shift or 2 PPM during any 15 -minute period, employer must: o Install ventilation to reduce exposure o Lower heat settings on blow-dryers, flat irons, etc. o Give workers respirators and train in their use o Ensure employees understand label and MSDS (SDS) o Post signs at entrances to formaldehyde areas o Tell employees about health effects, use of PPE, train how to safely clean up spills and dispose of materials If level is 0. 5 PPM for 8 -hr shift or 2 PPM for any 15 -minute period, employer must get workers medical attention and air test periodically PPT-058 -01 33

Salon Employer’s Duties If air tests show levels above OSHA limits, follow certain standard parts if product contains formaldehyde: § Give employees PPE and train on use § Explain how to understand product label and MSDS (SDS) § Provide eye and skin washing equipment § Train to safely clean up spills and dispose of materials § Get medical attention if symptoms show or if employee(s) exposed during an emergency § Keep records: air tests, medical attention and respirator fit tests http: //www. osha. gov/pls/oshaweb/owadisp. show_document? p_table=INTERPRETATION. . . PPT-058 -01 34

Occupational Exposure by inhalation is mainly from 3 sources: Ø Thermal or chemical decomposition of resins, Ø Aqueous solution emissions Ø Combustion of formaldehyde containing materials PPT-058 -01 35

Transmittal Means Formaldehyde exposure can be transmitted by touching materials containing formaldehyde then touching your face, eating or drinking without washing your hands PPT-058 -01 36

Exposures and Symptoms • Concentrations between 0. 05 PPM and 0. 5 PPM produce a sensation of irritation to eyes with burning, itching, redness and tearing • Accidental splashing with aqueous solutions of 37% formaldehyde (formalin) has produced a wide range of ocular injuries including corneal opacities and blindness • Skin contact can cause irritation of the skin and allergic contact dermatitis • These disorders can occur at levels well below those encountered by most formaldehyde workers Excerpted from a March 25, 1998 OSHA Interpretation Letter to Mr. Ryan Hopper from Mr. John B. Miles, Jr. , Directorate of Compliance Programs concerning regulations affecting embalming using formaldehyde PPT-058 -01 37

Exposures and Symptoms include: o Erythema (abnormal redness of skin) o Edema o Vesiculation (blisters) or hives Exposure to liquid formalin can provide skin reactions in sensitized individuals even when airborne concentrations are well below 1 PPM Excerpted from a March 25, 1998 OSHA Interpretation Letter to Mr. Ryan Hopper from Mr. John B. Miles, Jr. , Directorate of Compliance Programs concerning regulations affecting embalming using formaldehyde PPT-058 -01 38

Exposure Limits The odor threshold for most people is around 0. 05 PPM with highest level at 1 PPM Maximum workplace concentration is 0. 3 PPM 0. 5 – 1 1 and above Effect Begin to sense eye irritation 5% to 20% report eye irritation Greater sensory irritation PPT-058 -01 39

Hazards Addressed by Employer In classifying the hazards of formaldehyde, at least the following hazards are to be addressed by the employer: o Cancer; o Skin and respiratory sensitization; o Eye, skin and respiratory tract irritation; o Acute toxicity effects; o Flammability PPT-058 -01 40

Exposure Monitoring Each employer covered by this standard: • Shall monitor employees to determine their exposure to formaldehyde • Unless objective data reveals no such exposure • Employer’s sampling/data shall be representative of employee’s full shift or short term exposure PPT-058 -01 41

Sampling Ø 29 CFR 1910. 1048(d)(1)(iv) Ø Representative samples for each job classification in each work area shall be taken for each shift unless employer can document with objective data that exposure levels for a given job classification are equivalent for different work shifts PPT-058 -01 42

Initial Monitoring Employer shall identify all employees who may be exposed at or above: q the action level or q the STEL q accurately determine the exposure of each employee so identified PPT-058 -01 43

Initial Monitoring Employer: § May measure each individual potentially exposed, or § Develop a representative sampling strategy and measure sufficient exposures within each job classification for each work shift PPT-058 -01 44

Initial Monitoring Repeat each time there is a change in the following which may result in a new or additional exposure: o Production o Equipment o Process o Personnel o Control measures PPT-058 -01 45

Monitoring Employer shall monitor affected employee’s exposure if reports are received of signs or symptoms of respiratory or dermal conditions associated with formaldehyde exposure PPT-058 -01 46

Monitoring Impinger 3 Passive monitor types Gas monitor PPT-058 -01 47

Periodic Monitoring Determine exposure for employees shown by initial monitoring to be exposed at or above action level or at or above the STEL (2 ppm for 15 minutes) If last monitoring results reveal at or above action level, repeat monitoring every 6 months If last results indicate exposure at or above STEL, repeat monitoring of employees at least once a year under worst conditions PPT-058 -01 48

Termination of Monitoring Periodic monitoring may be discontinued if: ü Results from 2 consecutive sampling periods taken at least 7 days apart show employee exposure is below action level ü STEL results must be statistically representative and consistent with employer’s knowledge of the job and work operation PPT-058 -01 49

Monitoring Accuracy v Shall be accurate at the 95% confidence level to within plus or minus 25% for airborne concentrations of formaldehyde at the TWA and the STEL v And to within plus or minus 35% for airborne concentrations of formaldehyde at the action levels PPT-058 -01 50

Monitoring Accuracy Each affected employee must be notified within 15 working days of results after employer receives them Affected employees or representatives shall be given opportunity to observe monitoring If affected area requires PPE to view monitoring, employer will provide the PPE and ensures observer complies with all safety and health procedures PPT-058 -01 51

Regulated Areas § Established where TWA or STEL are exceeded § Access limited to those trained to recognize formaldehyde hazards § Entrances and accessways posted with signs reading: PPT-058 -01 52

Sign Where concentration exceeds TWA or PEL, a sign must be posted reading: DANGER FORMALDEHYDE MAY CAUSE CANCER CAUSES SKIN, EYE, AND RESPIRATORY IRRITATION AUTHORIZED PERSONNEL ONLY PPT-058 -01 53

Methods of Compliance Institute engineering and work practice controls to reduce employee exposure at or below the TWA and STEL If unable to reduce completely, supplement with correct respirators PPT-058 -01 54

Respirator Program Conforms to 29 CFR 1910. 134(b) through (d), (except (d)(1)(iii), (d)(3)(iii)(b)(1), and (2)), and (f) through (m), covering each person required to use a respirator Air purifying respirators with chemical cartridges or canisters without end-of-service-life indicators approved by NIOSH; Replace as specified by paragraphs (d)(3)(iii)(B)(1) and (B)(2) of 29 CFR 1910. 134 or at end of work shift, whichever occurs first PPT-058 -01 55

Respirator Program Employers must: Select and provide appropriate respirator to employees; Equip air purifying full face piece respirator with approved canister or cartridge; For escape, provide one of the following options: Ø SCBA; either demand or pressure- demand mode, Ø Full face piece respirator with chin style or front-or back-mounted industrial-size canister or cartridge approved formaldehyde PPT-058 -01 56

Respirators Employer-supplied respirators must be used: ü During installation/implementation of engineering and work-practice controls ü Maintenance/repair activities ü Vessel cleaning where other controls are not feasible ü Work operations where exposure can not be reduced to or below the PELs PPT-058 -01 57

Respirator NIOSH Pocket Guide to Chemical Hazards, Appendix E, Formaldehyde; airborne concentration/condition of use and required respirator For formaldehyde atmospheres with: < 7. 5 PPM (10 x PEL) Full-facepiece respirator with cartridges or canisters specifically approved for protection against formaldehyde. A half-mask respirator with cartridges specifically approved formaldehyde can be substituted provided that effective gas-proof goggles are provided and used in combination with the half-mask respirator PPT-058 -01 58

Respirator < 75 PPM (100 x PEL) (1) Full-face mask respirator with chin style or chest- or back-mounted type with industrial size canister specifically approved formaldehyde; (2) Type C supplied-air respirator; demand type or continuous flow type, with full face piece, hood, or helmet PPT-058 -01 59

Respirator >75 PPM (100 x PEL) (1) Self-contained breathing apparatus with positive- pressure full-face piece; (2) Combination supplied-air, full-face piece positivepressure respirator with auxiliary self-contained air supply PPT-058 -01 60

Respirator Substitution v A half-mask respirator with cartridges specifically approved formaldehyde can be substituted for the full face piece respirator providing that effective gas-proof goggles are provided and used in combination with the half-mask respirator v Those with difficulty with negative pressure respirator, employer must provide with powered air-purifying respirators (PAPR) PPT-058 -01 61

PPE ü Conforms to 29 CFR 1910. 132 and 1910. 133 ü Selected based on form of formaldehyde, use conditions, and hazard to be prevented ü Prevent all contact with formaldehyde of 1% or more ü Impervious clothing, goggles and face shields ü Contact with irritating or sensitizing materials prevented to extent necessary PPT-058 -01 62

PPE Face shield and goggles are required if chance of formaldehyde reaching eyes Full body protection for entry into areas where air concentrations exceed 100 PPM, and For emergency reentry to areas of unknown concentration PPT-058 -01 63

Contaminated Clothing § Any clothing contaminated with formaldehyde must be cleaned or laundered before reuse § Ventilate contaminated clothing § Establish a storage area § Label containers for clothing/equipment and provide signs PPT-058 -01 64

Contaminated Clothing Only trained persons remove contaminated material from storage area to clean, launder or dispose No employee takes such clothing/equipment home Employer repairs/replaces such clothing/equipment to be serviceable Any person laundering, cleaning, or repairing contaminated clothing is apprised of harmful effects and safety procedures for handling PPT-058 -01 65

Hygiene Protection Provide change rooms per 29 CFR 1910. 141 for employees Quick drench showers for 1% or greater splash situations Eye wash stations for 0. 1% or greater in immediate work area PPT-058 -01 66

Housekeeping Conduct programs where liquids or gases are used: o To detect leaks and spills o And conduct regular inspections o Preventative maintenance PPT-058 -01 67

Spill Areas Provide for spill control Ø Decontamination and Ø Waste disposal ü Repair leaks ü Clean-up spills by properly trained employees ü With proper PPE PPT-058 -01 68

Contaminated Waste & Debris Placed in sealed containers o With label warning and o Associated hazards For each workplace where a formaldehyde emergency may occur: o Assure proper procedures to minimize injury and life loss o Appropriate procedures shall be implemented during an emergency PPT-058 -01 69

Medical Surveillance Per OSHA 29 CFR 1910. 148, the employer shall institute a medical surveillance program for all employees: o Exposed to formaldehyde at or exceeding the action level (0. 5 PPM for 8 hr TWA) or exceeding the STEL (2 PPM) o Developing signs and symptoms of overexposure o Exposed to formaldehyde in emergencies “There is evidence that signs and symptoms associated with formaldehyde exposure will occur only in exceptional circumstances when airborne exposure is less than 0. 1 PPM and when formaldehyde is present in material in concentrations less than 0. 1 percent. ” 29 CFR 1910. 1048 (l)(1)(ii) PPT-058 -01 70

Medical Procedures Medical Disease Questionnaire Shall be performed by or under the supervision of a licensed physician and without cost to employee, without loss of pay and at a reasonable time/place PPT-058 -01 71

Questionnaire o Completed prior to assignment to formaldehyde exposure at or above action level or above STEL and annually thereafter o History of employee o Based on questionnaire whether a medical exam is required for those not required to wear a respirator PPT-058 -01 72

Medical Exam Based on questionnaire, those who may be at increased risk from exposure to formaldehyde and at time of initial assignment Then at least annually thereafter to those required to wear a respirator to reduce exposure q Physical exam: emphasis on evidence of irritation or sensitization of skin and respiratory system, shortness of breath or irritation of the eyes q Lab exam: for respirator wearers; baseline and annual pulmonary function tests q Any other test deemed necessary by physician PPT-058 -01 73

Exposed in an Emergency Physical exam made available as soon as possible to all employees exposed during an emergency Exam will include: ü Medical and work history ü Emphasis on evidence of upper or lower respiratory problems ü Allergic conditions ü Skin reaction or hypersensitivity ü Any evidence of eye, nose or throat irritation ü Other elements considered appropriate by physician PPT-058 -01 74

Information to Physician Employer shall provide physician: o Copy of the standard (29 CFR 1910. 1048) o Appendix A, C, D and E of the standard o Description of job duties as related to formaldehyde exposure o Representative exposure level o Information regarding PPE and respiratory protection used o Previous exam information o If non-routine exam, how emergency occurred and possible exposure PPT-058 -01 75

Medical Surveillance In writing, with results of medical exam, but will not reveal specific findings or diagnoses unrelated to occupational exposure to formaldehyde Written Opinion Contents Whether exposure would place employee at increase risk of material impairment PPT-058 -01 76

Medical Surveillance § Limitation recommendations on employee’s exposure § Changes in use of PPE, including respirators § Statement employee has been informed by physician of any medical conditions which may be aggravated by exposure § Employer shall retain results of exam and tests conducted by physician § Employer provides copy of written opinion to employee within 15 days of receipt PPT-058 -01 77

Medical Removal Applies when employee reports: o Significant irritation of mucosa of eyes or upper airways o Respiratory sensitization o Dermal irritation o Dermal sensitization attributed to workplace formaldehyde PPT-058 -01 78

Medical Removal Medical removal provisions do not apply in the case of dermal irritation or dermal sensitization when the product suspected of causing the dermal condition contains less than 0. 05% formaldehyde PPT-058 -01 79

Medical Evaluation • Employee’s report of over- exposure shall be evaluated by employer-appointed physician • Two (2) week evaluation/remediation period: q Do the symptoms subside untreated? q Or with use of creams, PPE, first-aid treatment? PPT-058 -01 80

Medical Evaluation If signs worsen: employee referred to physician prior to expiration of 2 -week period Employee’s earnings, seniority and benefits may not be altered during 2 week period PPT-058 -01 81

If Signs/Symptoms Persist Employee examined by employer-appointed physician If products to which employee is exposed contain less than 0. 1% formaldehyde, physician, in absence of contrary evidence, shall presume dermal irritation or dermal sensitization are not attributable to formaldehyde 29 CFR 1910. 1048, Appendix C, contains additional guidelines PPT-058 -01 82

Physician’s Findings If physician finds workplace formaldehyde exposure to be the cause of employee’s condition, employer may have to: Ø Restrict or remove employee from exposing job Ø Removed employee must be transferred to comparable work for which qualified or can be trained in a short period (up to 6 months) PPT-058 -01 83

Employee Status No such work available? Employer maintains employee’s current earnings, seniority and other benefits: Ø Until such work becomes available, Ø Until employee is determined to be unable to return to workplace formaldehyde exposure, Ø Until the employee is determined to be able to return to original job status, Ø Or for six (6) months, whichever comes first PPT-058 -01 84

Follow-up Exam Arranged by employer o To determine worker’s return to job status, or o Permanent removal Physician shall decide within 6 months of date of employee’s removal whether original job status can be resumed or if removal is to be permanent Earnings, seniority and other benefits to the removed employee may be reduced to extent employee receives compensation for earnings lost during period of removal either from a publicly or employer-funded compensation program or from employment with another employer PPT-058 -01 85

Follow-up Exam Employer selects initial physician Employer notifies employee that employee may designate a second physician Employer may condition its participation in and payment for multiple physician review if employee within 15 days: Ø Informs employer of intent to seek a second medical opinion Ø Employee initiates steps to make appointment with second physician PPT-058 -01 86

Lack of Agreement If findings of first and second physician lack agreement, employer and employee through their respective physicians shall designate a third physician; a specialist in the field at issue 1. Third physician reviews original findings 2. Conducts exams to resolve the disagreement 3. Alternate: employer and employee may designate third physician PPT-058 -01 87

Lack of Agreement Employer shall act consistent with findings of third physician unless employer and employee reach agreement otherwise consistent with recommendations of at least 1 of the 3 physicians PPT-058 -01 88

Hazard Communication Addresses: q Hazards of formaldehyde in workplace, q Formaldehyde gas, q All mixtures or solutions composed of greater than 0. 1% formaldehyde, q Materials capable of releasing formaldehyde into the air, under reasonably foreseeable conditions of use, at concentrations reaching or exceeding 0. 1 PPM PPT-058 -01 89

Minimum Hazards Addressed Health hazards the employer needs to address are: o Cancer o Irritation and sensitization of skin and respiratory system o Eye and throat irritation and o Acute toxicity PPT-058 -01 90

Hazards Addressed Manufacturers, importers, producers of Formaldehyde or Formaldehyde-containing products: v Shall provide downstream employers using or handling these products with an objective determination through required labels and SDSs if these items may constitute a health hazard within the meaning of 29 CFR 1910. 1200(d) under normal conditions of use PPT-058 -01 91

Labeling Information on all containers: q For all materials listed capable of releasing formaldehyde at levels of 0. 1 PPM to 0. 5 PPM q Identify the product contains formaldehyde q Name and address of responsible party q State physical and health hazard information is available from: o Employer o SDS PPT-058 -01 92

Haz. Comm Labels For materials capable of releasing formaldehyde at levels above 0. 5 PPM Labels shall address Ø All hazards defined in 29 CFR 1910. 1200(d) and Appendices A and B Ø Including Respiratory sensitization Ø And contain the words, “Potential Cancer Hazard” In determining potential levels of formaldehyde release, employer may rely on objective data indicating extent of potential release under reasonably foreseeable conditions of use PPT-058 -01 93

Substitute Warning Label Employer may use warning labels required by other statutes, regulations or ordinances which impart the same required information of 29 CFR 1910. 1048(m)(3) PPT-058 -01 94

Safety Data Sheet (SDS) o Any employer using formaldehyde-containing materials per 29 CFR 1910. 1048 (m)(1)(i) shall comply with requirements of 29 CFR 1910. 1200(g) pertaining to SDSs o Manufacturers, importers and distributors of formaldehyde containing materials shall assure SDSs and updated information are provided to all employers purchasing such materials with initial shipment and when SDSs are updated PPT-058 -01 95

Hazard Communication Program At a minimum, program describes how the requirements will be met for: q Labels and other warnings q SDS q Employee information and training PPT-058 -01 96

Training Program Employees assigned to workplaces where there is formaldehyde exposure shall be trained Employer is not required to provide training to employees if exposure is not at or above 0. 1 PPM Employer shall inform workers of location of written training materials and make them readily available Upon request by the Assistant Secretary and the Director of OSHA, provide all training materials related to training program PPT-058 -01 97

Training Program o At time of initial assignment o When a new formaldehyde exposure is introduced o Repeated at least annually o Conducted in an understandable manner Topics: 1. Contents of this regulation (29 CFR 1910. 1048) 2. SDS contents 3. Purpose and description of medical surveillance program 4. Potential health hazards, signs and symptoms of exposure PPT-058 -01 98

Training Program Topics: 5. How to report adverse signs and symptoms 6. Operations in the work area and safe work practices 7. Purpose, use and limitations of PPE Handling spills, emergencies and clean up procedures 8. Engineering and work practice controls and instructions for use 9. Emergency procedures PPT-058 -01 99

Recordkeeping Exposure Measurements: Maintain accurate records of all measurements taken to monitor employee exposure to formaldehyde Record shall include: Ø Date of measurement Ø Operation being monitored PPT-058 -01 100

Exposure Measurements - Methods of sampling, analysis and evidence of their accuracy and precision - Number, durations, time and results of samples taken - Types of protective devices worn - Names, job classifications, social security numbers and exposure estimates of employees whose exposures are represented by monitoring results PPT-058 -01 101

Medical Surveillance Exposure Determinations When employer determines no monitoring is required, maintain records of data upon which such a determination was made PPT-058 -01 102

Medical Surveillance For each employee subject to medical surveillance under this standard, record includes: ü Name and social security number ü Physician’s written opinion ü Copy of medical exam results, questionnaire and test results PPT-058 -01 103

Respirator Fit Testing o Protocol selected for the fit testing o Copy of fit testing results o Size and manufacturer of respirators available for selection o Date of most recent fit testing o Name/social security number of each tested employee o Respirator type and face piece selected PPT-058 -01 104

Record Retention Records Retained Exposure records & determinations At least 30 years Medical Duration of employment plus 30 years Respirator fit testing Until replaced by a more recent record PPT-058 -01 105

Availability of Records Upon request, employer shall make all records available to Assistant Secretary and Director of OSHA Employer shall make employee exposure records and estimates from monitoring available for examination and copying by employees, former employees and employee representatives Employee medical records shall be made available for examination and copying by employees, former employees or anyone with specific written consent of employee or former employee PPT-058 -01 106

29 CFR 1910. 1048, Appendices Appendix A: Substance Technical Guidelines for Formalin Appendix B: Sampling Strategy and Analytical Methods Appendix C: Medical Surveillance Appendix D: Nonmandatory Medical Disease Questionnaire PPT-058 -01 107

Summary o Determine if products contain formaldehyde or derivatives o If so, take proper precautions o If employed in an industry involved in formaldehyde production or the production of any of its “relatives, ” recognize the employer must take specific actions to reduce the hazard to employees o Understand the safety requirements and regulations governing working around and handling such products o Adopt and use best practices and proper PPE to limit your exposure, and thereby reduce your consequences PPT-058 -01 108

Bibliography 29 CFR 1910. 1048, Formaldehyde, Subpart Z, Toxic and Hazardous Substances 29 CFR 1910. 1200, Hazard Communication, Subpart Z – Toxic and Hazardous Substances March 25, 1998 OSHA Interpretation Letter to Mr. Ryan Hopper from Mr. John B. Miles, Jr. , Directorate of Compliance Programs, at http: //www. osha. gov/pls/oshaweb/owadisp. show_document? p_table=INTERPRETATION NIOSH Pocket Guide to Chemical Hazards, DHHS, 2007 or most current addition at http: //www. cdc. gov/niosh/npg PPT-058 -01 109

Questions PPT-058 -01 110