Departmental Health & Safety Program Management Tool

TOPIC: Formaldehyde

OSHA Terms Formaldehyde Exposure Limits Monitoring Requirements Summary of Monitoring Requirements Health Effects Medical Surveillance

When to Post Signage Employee Training Personal Protective Equipment (PPE) Emergencies, Spills and Personal Contamination Reporting Injuries and Illnesses Formaldehyde Exposures...Not Just At Work

OSHA Terms

Action Level (AL) - This is the level at which OSHA requires that initial action be taken.  A concentration of 0.5 part formaldehyde per million parts of air (0.5 ppm) calculated as an eight (8)-hour time-weighted average (TWA) concentration.

Permissible Exposure Limit (PEL) - This is the level at which it is no longer safe to continue working in an environment without PPE including respiratory protection.  The employer will assure that no employee is exposed to an airborne concentration of formaldehyde which exceeds 0.75 parts formaldehyde per million parts of air (0.75 ppm) as an 8-hour TWA.

Short Term Exposure Limit (STEL) - The employer will assure that no employee is exposed to an airborne concentration of formaldehyde which exceeds two parts formaldehyde per million parts of air (2 ppm) as a representative 15-minute STEL. 

Formaldehyde Exposure Limits

Formaldehyde Exposure	Limit	Required Action
0.1 ppm to < 0.5 ppm	Below Action Limit	Employee training Exposure monitoring annually
≥ 0.5 ppm	Action Limit (AL)	Employee training Medical surveillance Exposure monitoring every 6 months
≥ 0.75 ppm	Permissible Exposure Limit (PEL)	Employee training Medical surveillance Exposure monitoring every 6 months Establish and post regulated areas  Respiratory protection and other PPE utilized Establish engineering and work practice controls to lower exposures to below PEL
≥ 2.0 ppm	Short Term Exposure Limit (STEL)	Medical surveillance Minimum exposure monitoring annually

Monitoring Requirements

It is the responsibility of the employer to monitor employees for formaldehyde exposure.

Initial Monitoring

Must be initiated for any occupational setting in which in the following criteria has been met:  formaldehyde gas, all mixtures or solutions composed of greater than 0.1 percent formaldehyde, and materials capable of releasing formaldehyde into the air, under reasonably foreseeable conditions of use, at concentrations reaching or exceeding 0.1 ppm. 

In making the determinations of anticipated levels of formaldehyde release, the employer may rely on objective data indicating the extent of potential formaldehyde release under reasonably foreseeable conditions of use.

Exposure sampling should be representative of the employee's full shift or short term exposure to formaldehyde.  Such samples should be acquired for each job classification in each work area for each shift, unless the exposure for different shifts has been documented to be equivalent. 

In initial monitoring, the employer should identify all employees who may be exposed at or above the AL or STEL using a representative sampling strategy and accurately determine the exposure of each such employee.  This should be repeated each time there is a change in the workplace that could result in new or additional exposure to formaldehyde.

An employee's current exposure level should be monitored any time the employer receives report of respiratory or dermal signs and symptoms associated with formaldehyde exposure.

Periodic Monitoring

The employer should periodically measure exposure levels for anyone shown to be at or above the AL or at or above the STEL.  If initial monitoring is shown to be at or above the AL, monitoring must taking place at a minimum of every 6 months.  If initial monitoring is shown to be at or above the STEL, monitoring should be repeated at a minimum of once per year.

Periodic monitoring may be terminated if two consecutive samples taken at least 7 days apart show that employee exposure is below the AL and the STEL.

Employee notification

Within 15 days of the receipt of results, the employer must notify each affected employee of monitoring results either individually in writing or in a posting location accessible to all necessary employees.  If exposure for any employee exceeds the PEL, the employer will provide those affected with a description of the corrective actions being taken to decrease exposure.

Summary of Monitoring Requirements

Type of Monitoring	Who is Affected	Time frame	Required Action
Initial Monitoring	Any employee potentially exposed	On first exposure If there is a change in production, equipment, personnel, or control measures Annually	Representative sampling acquired for all roles in all shifts Identify any employees exposed at or above the AL or STEL
Periodic Monitoring	Employee populations with an 8 hour TWA exposure ≥ 0.5 ppm or a representative 15 minute exposure ≥ 2 ppm	At a minimum of every 6 months	Repeat of initial monitoring of representative samples for all roles/shifts. May be terminated if two consecutive samples taken at least 7 days apart show that employee exposure is below the AL and the STEL
Immediate Monitoring	Employees with respiratory or dermal signs & symptoms associated with exposure	Promptly	Repeat of initial monitoring of representative samples for all roles/shifts.

Health Effects

Acute Exposure

Nausea and irritation of the skin, eyes, nose, and throat. Coughing and wheezing are common, and upper respiratory tract irritation can exacerbate symptoms related to asthma and other respiratory illnesses.

Chronic Exposure

Respiratory symptoms including chronic runny nose, chronic bronchitis, obstructive lung disease, and cancer.

Formaldehyde as a Carcinogen

Following the publication of a report by the National Toxicology  Program in January of 2010, formaldehyde has been declared by the US Environmental Protection Action and the Department of Health and Human Services as a known carcinogen when inhaled by humans.  It has been directly linked with cancers of the upper respiratory tract, in particular nasopharyngeal and sino-nasal cancers.  There is also evidence to support a relationship between formaldehyde and lymphohematopoietic cancers, in particular myeloid leukemia and Hodgkin's lymphoma.

Medical Surveillance

Formaldehyde Exposure & Medical Surveillance Flow Chart

Related Links and Information

Concentra Urgent Care

For Respirator Fit Testing contact Training and Compliance.

More information on PPE can be found in the Personal Protective Equipment section of this document

OSHA's medical evaluation guideline for formaldehyde exposure above the AL or STEL:

When to Post Signage 

Hazard Communication

Hazard communication is required for formaldehyde gas, all mixtures or solutions composed of greater than 0.1 percent formaldehyde, and materials capable of releasing formaldehyde into the air, under reasonably foreseeable conditions of use, at concentrations reaching or exceeding 0.1 ppm.

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.

Labels

As a minimum, for all materials listed above capable of releasing formaldehyde at levels of 0.1 ppm to 0.5 ppm, labels shall identify that the product contains formaldehyde; list the name and address of the manufacturer and state that physical and health hazard information is readily available from the employer and from material safety data sheets. For materials listed above capable of releasing formaldehyde at levels above 0.5 ppm, labels will state all of the previous information as well as the chemical's potential for respiratory sensitization, and will contain the words "Potential Cancer Hazard."

Material safety data sheets

UVM's Written Hazard Communication Program outlines the requirements for departments that need to develop, implement, and maintain workplace protocols for managing formaldehyde exposures.  At a minimum Departments must describe how the requirements specified in this section for labels and other forms of warning and material safety data sheets, and for employee information and training, will be met.

Employee Training

All employees with exposure to formaldehyde must participate in the training program, unless it can be proven that their exposure is less than 0.1ppm. Trainings must be repeated every year, unless a new source of formaldehyde is introduced to the workplace-when the training must be given again.

Employee Training must include:

• Contents of the MSDS sheet
• Purpose and description of the medical surveillance
• Description of health hazards associated with formaldehyde exposure, and signs and symptoms of exposure.
• Instruction to immediately report to supervisor if experiencing signs or symptoms of exposure.
• Purpose, use of, and limitations of personal protective clothing and equipment.
• Instructions for handling clean up of spills, emergencies, and clean up procedures.
• Description of work operations around formaldehyde, and related safe work practices.
• Explanation of work practice controls.
• Review of emergency procedures and assignments of employee during an emergency.
• Training materials should be available to employees and they should be informed of where to find them.

Control Methods

• Use ventilation when working with formaldehyde. Remember that formaldehyde is heavier than air and ventilation near the ceiling will pull vapors past your face and be less efficient.
• Contain vapors whenever possible, behind hoods, etc.
• Substitute for formalin-free materials whenever possible

Work Practice Controls

• Keep containers covered when not actively in use
• Do not block ventilation
• Keep face out of airstream
• Keep exhaust grills clean/clear

Record Keeping

A minimum of one person per department is required to annually review formaldehyde training materials and to share that training with all affected department members (those who will be exposed to formaldehyde).  After completing the training, a survey listing the training attendees will be completed. Oversight for these records will be kept by Risk Management & Safety for a period of 30 years as required, and will fulfill the affected departments' record keeping requirements.

Personal Protective Equipment (PPE)

PPE Eyewear

• When working with formaldehyde under a hood or local exhaust ventilation, use basic safety glasses.
• When working with formaldehyde outside of a hood or specially ventilated area, use chemical goggles.
• If splashing is possible, use a face mask in addition to chemical goggles.

PPE Gloves

If skin contact is unlikely, use nitrile exam-style gloves. Rinse and remove if contaminated, always wash hands after removal.

If skin contact is possible, use utility nitrile gloves over exam-style nitrile gloves. Rinse well after contamination, and check for leaks before reuse.

Respirators

If formaldehyde levels exceed the PEL use of a respirator, in addition to increase control methods and changes in work place practices, will help reduce exposure to employees. Respirators may also be used for employees sensitized to formaldehyde.

The first step in acquiring a respirator is having the employee fill out a Respirator Request Form provided by the Training and Compliance office. Once Training and Compliance has received the request the employee will be contacted with further instructions for a free medical evaluation at Concentra Medical Center in South Burlington.

Provided the employee passes the medical evaluation for using a respirator they will be trained and tested for correct fit at the Training and Compliance Office in Essex Jct. If the employee does not pass the medical evaluation alternate accommodations will be arranged.

Emergencies, Spills and Personal Contamination

Refer to UVM Emergency Planning information for specifics regarding: Emergency Response, Emergency Prevention or Emergency Equipment.

Spills

Small Spills: Wear utility gloves and chemical goggles, absorb and clean from perimeter inward, bag spill material and label as hazardous waste.

Large Spills: Cover spill if possible to keep fumes down. Evacuate area, and contact Environmental Safety at 656-5400.

Contamination of eyes/skin

If eyes are contaminated with formaldehyde, rinse in eye wash station for 15 minutes, holding eyes open to be rinsed. Get medical assistance.

If skin is contaminated with formaldehyde, stand under running emergency shower for 15 minutes. Get medical assistance.

Reporting Injuries and Illnesses

Report all injuries and illnesses believed to be related to exposure to formaldehyde to Risk Management & Safety.

Formaldehyde Exposures...Not Just At Work

OSHA Hazard Alert as communicated in an April 11, 2011 press release...

Recent reports from Oregon OSHA, California OSHA, and now Federal OSHA should alert salon owners and stylists to look closely at the hair smoothing products they are using to see if they contain methylene glycol, formalin, methylene oxide, paraform, formic aldehyde, methanal, oxomethane, oxymethylene, or CAS Number 50-00-0. All of these are names for or treated as formaldehyde under OSHA's Formaldehyde standard. Products containing them can expose workers to formaldehyde; employers who manufacture, import, distribute, or use the products must follow OSHA's formaldehyde standard.

An excerpt from class-related materials at the University of Minnesota School of Public Health raises the flags below regarding environmental exposures to formaldehyde:

Sources of formaldehyde in the home include building and insulating materials, smoking, household products, and the use of un-vented, fuel-burning appliances, like gas stoves or kerosene space heaters.

Formaldehyde Uses and Potential Indoor Sources

Products	Examples
Paper Products	Grocery bags, sax paper, facial tissues, paper towels, disposable sanitary products
Stiffeners, wrinkle resisters and water repellents	Floor covering(rugs linoleum, varnishes, plastics), carpet adhesive binder, fire retardants, permanent press clothes
Insulation	Urea formaldehyde foam insulation (UFFI)
Combustion Devices	Natural gas, kerosene, tobacco smoke
Pressed-wood products	Pressed-wood products Plywood, particle board, decorative paneling
Other	Cosmetics, deodorants, shampoos, fabric dyes, disinfectants

Even though many products have the potential for releasing formaldehyde into indoor air, relatively few are responsible for causing significant levels of contamination. Pressed wood products and UFFI (Urea Formaldehyde Foam Insulation) can release formaldehyde at greater rates than other products.

In homes, the most significant sources of formaldehyde are likely to be pressed wood products made using adhesives that contain urea-formaldehyde (UF) resins. Pressed wood products made for indoor use include: particleboard (used as sub flooring and shelving and in cabinetry and furniture); hardwood plywood paneling (used for decorative wall covering and used in cabinets and furniture); and medium density fiberboard (used for drawer fronts, cabinets, and furniture tops). Medium density fiberboard contains a higher resin-to-wood ratio than any other UF pressed wood product and is generally recognized as being the highest formaldehyde-emitting pressed wood product.