The Catholic University of America

Environmental Health & Safety Manual

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19 - FORMALDEHYDE

19.1

PURPOSE

The purpose of this program is to ensure that no CUA employee is exposed to an airborne concentration of formaldehyde which exceeds the Occupational Safety and Health Administration's (OSHA) permissible exposure limit (PEL) of 0.75 parts per million (ppm) as an 8-hour time-weighted average (TWA) and/or to an airborne concentration of formaldehyde which exceeds 2 ppm as a 15-minute Short Term Exposure Limit (STEL).

19.2

SCOPE

This program applies to workplaces at CUA where employees may be subject to ANY occupational exposure to formaldehyde, formaldehyde gas, it's solutions, and materials that release formaldehyde.

19.3

BACKGROUND AND APPLICATION

The OSHA under 29 CFR 1910.1048 has established exposure monitoring and training requirements to prevent occupational exposure to formaldehyde.

When an employee's exposure is determined from representative sampling, the measurements used will be representative of the employee's full shift 8-hour) or short-term (15 minute) exposure to formaldehyde, as appropriate.

Formaldehyde gas, all mixtures or solutions composed of greater than 0.1% formaldehyde, and materials capable of releasing formaldehyde into the air under reasonably foreseeable conditions of use, at concentrations reaching or exceeding 0.1 ppm are subject to the requirements of hazard communication. The Hazard Communication section of this program will address the subjects of labels and other forms of warning, material safety data sheets (MSDS), and employee information and training.

19.4

DEFINITIONS

Action Level

Airborne concentration of 0.5 part per million (ppm) of formaldehyde calculated as an eight-hour Time Weighted Average (TWA).

Emergency

Any occurrence, such as but not limited to, equipment failure, rupture of containers, or failure of control equipment that results in an uncontrolled release of an significant amount of formaldehyde.

Employee Exposure

Exposure to airborne formaldehyde which would occur without corrections for protection provided by any respirator that is in use.

Formaldehyde

The chemical substance, HCHO, Chemical Abstracts Service Registry No. 50-0-0.

Permissible Exposure Limit (PEL)

  1. Time-Weighted Average: No employee will be exposed to an airborne concentration of formaldehyde that exceeds 0.75 parts formaldehyde per million parts of air (0.75 ppm) as an 8-hour TWA.
  2. Short Term Exposure Limit (STEL): Airborne concentration of formaldehyde of 2 ppm over a 15-minute exposure.

19.5

EXPOSURE MONITORING (See diagram at End of Chapter)

When an employee's exposure is determined from representative sampling, the measurements used will be representative of the employee's full shift (8-hour) or short-term (15-minute) exposure to formaldehyde, as appropriate.

  • Employees who may be exposed at or above the action level or at or above the STEL are to be monitored to determine exposure to formaldehyde.

However, if objective data indicates that the presence of formaldehyde or formaldehyde-releasing products in the workplace cannot result in airborne concentrations of formaldehyde that would cause any employee to be exposed at or above the action level or the STEL, then exposure monitoring is not required. This data will be documented.

  • If an employee is exposed at or above the action level, monitoring of affected employee will be repeated at least every 6 months.
  • If an employee is exposed at or above the STEL, CUA will repeat monitoring of affected employee at least once a year under worst conditions.

If CUA receives reports of signs and symptoms of respiratory or dermal conditions associated with formaldehyde exposure, CUA will monitor the affected employee's exposure.
CUA will notify affected employees, in writing, of monitoring results within 15 days of receiving the results. The written notice will contain a description of the corrective action being taken by the employer to decrease exposure.

Periodic monitoring may be discontinued if results from two consecutive sampling periods taken 7 days apart reveal exposure below the action level and the STEL.

19.6

REGULATED AREAS

All entrances and accessways into areas where the concentration of airborne formaldehyde exceeds the TWA (0.75 ppm) or STEL must be posted with the signs bearing the following information:

DANGER
FORMALDEHYDE
IRRITANT AND POTENTIAL CANCER HAZARD
AUTHORIZED PERSONNEL ONLY


Access to regulated areas, as above, will be limited to authorized persons who have been trained to recognized the hazards of formaldehyde.

Engineering controls and work practices will be instituted to reduce and maintain employee exposure at or below the TWA and the STEL.

Respirators will be supplemented if it is established that feasible engineering controls and work practices cannot reduce the exposure to or below the TWA or the STEL. (Refer to CUA Respiratory Protection Program prior to respirator use).

19.7

PERSONAL PROTECTIVE EQUIPMENT (PPE)

Supervisors will select the appropriate protective clothing based upon the form of formaldehyde to be encountered, the conditions of use, and the hazard to be prevented.

Use chemical protective clothing made of material impervious to formaldehyde and other PPE, such as goggles and face shields, when working with liquids containing 1% or more formaldehyde.

If there is a danger of formaldehyde reaching the eye area, use chemical safety goggles and a face shield.

Clean or launder PPE and clothing that have become contaminated with formaldehyde before its reuse.

19.8

HYGIENE PROTECTION

Emergency eyewashes and showers are conveniently located within the work area for emergency use.

The supervisor is responsible to conduct a program to detect leaks and spills, including regular visual inspections, for operations involving formaldehyde liquids or gas.

Perform preventative maintenance of equipment at regular intervals.

Place formaldehyde-contaminated waste and debris in sealed containers bearing a label warning of formaldehyde's presence and or the hazards associated with formaldehyde. (See section 19.11.1, Labels)

19.9

MEDICAL SURVEILLANCE

A medical surveillance program will be instituted for all employees exposed to formaldehyde at concentrations at or exceeding the action level or exceeding the STEL.

Medical surveillance will be available for employees who develop signs and symptoms of overexposure to formaldehyde and for all employees exposed to formaldehyde in emergencies.

19.10

MEDICAL REMOVAL

If a physician selected by CUA finds that significant irritation of the mucosa of the eyes or of the upper airways, respiratory sensitization, dermal irritation, or dermal sensitization result from workplace formaldehyde exposure and recommends restrictions or removal, CUA will comply with the restrictions or recommendation of removal.

CUA will remove the affected employee from the current formaldehyde exposure, and if possible, transfer the employee to work having no or significantly less exposure to formaldehyde.

When an employee is removed, CUA will transfer the employee to comparable work for which the employee is qualified or can be trained in a short period (up to 6 months), where the formaldehyde exposures are as low as possible but not higher than 0.5 ppm.

CUA will arrange for a follow-up medical examination to take place within six months after the employee is removed.

19.11

HAZARD COMMUNICATION

19.11.1

Labels

Hazard warning labels should be affixed to all containers of formaldehyde gas, all mixtures, or solutions composed of greater than 0.1% formaldehyde, and materials capable of releasing formaldehyde into the air, under reasonably foreseeable conditions of use, at concentrations reaching or exceeding 0.1 ppm.

For all materials capable of releasing formaldehyde at levels of 0.1 ppm to 0.5 ppm, labels will identify that the product contains formaldehyde, list the name and address of the responsible party, and state that physical and health hazard information is readily available from the supervisor and material safety data sheets (MSDS).

For materials capable of releasing formaldehyde at levels above 0.5 ppm, labels will address all hazards, including respiratory sensitization and the words "Potential Cancer Hazard."

Warning labels which impart the same information as the required warning statements may be used.

19.11.2

Material Safety Data Sheets

Material safety data sheets for formaldehyde will be located in the workplace where it is used and will be readily accessible during each work shift. The MSDS must be in English and contain the identity of the chemical and it's chemical and common name(s).

The name, address and telephone number of the chemical manufacturer who can provide additional information on the chemical and appropriate emergency procedures, if necessary, must be listed on the MSDS.

Chemical manufacturers and distributors will ensure that CUA is provided an appropriate MSDS with the initial shipment, and with the first shipment after a MSDS is updated.

19.11.3

Employee Information and Training

The supervisor will ensure that all employees who are assigned to workplaces where there is exposure to formaldehyde will participate in a training program annually.

However, training is not required, if objective data shows that employees are not exposed to formaldehyde at or above 0.1 ppm.

Information and training will be provided at the time of initial assignment, and whenever a new exposure to formaldehyde is introduced into the work area.

Affected employees will be informed of the location of written training materials which will be made readily available.

19.11.4

Training Program (See Diagram at End of Chapter)

The training program will include the following:

  • A discussion of the contents of this standard and the contents of the MSDS;
  • The purpose for and a description of the medical surveillance program required by this standard;
  • A description of the potential health hazards associated with exposure to formaldehyde and description of the signs and symptoms of exposure to formaldehyde;
  • Instructions to immediately report to the supervisor the development of any adverse signs or symptoms that could be attributable to formaldehyde exposure;
  • Description of operations in the work area where formaldehyde is present and an explanation of the safe work practices appropriate for limiting exposure to formaldehyde in each job;
  • The purpose for, proper used of, and limitations of personal protective clothing and equipment;
  • Instructions for handling spills, emergencies, and clean-up procedures;
  • An explanation of engineering and work practice controls for employee protection, and
  • A review of emergency procedures including the specific duties or assignments of each employee in the event of an emergency.

As a minimum, specific health hazards that will be addressed are:

  • Cancer,
  • Irritation and sensitization of the skin and respiratory system,
  • Eye and throat irritation, and
  • Acute toxicity.

19.12

RECORDKEEPING

All monitoring measurements of employee exposure to formaldehyde will be maintained by EHS.

When monitoring is not required, a record of the objective data relied upon to support the determination that no employee is exposed to formaldehyde at or above the action level will be maintained by EHS.