Formaldehyde

Purpose

The Occupational Safety and Health Administration (OSHA) issued a standard (29 CFR 1910.1048) to ensure the proper protection of all workers exposed to formaldehyde. The standard applies to all forms of formaldehyde including gas, aqueous solutions, solids, and materials from which it can be released. This program outlines what actions must be taken to assure compliance with this standard.

Application

All persons exposed to formaldehyde (including those that receive or transport biological samples/tissues preserved in formaldehyde) must be trained on its hazards and the available methods of protection. This training must occur at the time of initial job assignment and whenever a new exposure to formaldehyde is introduced into the work area. The online training may be used, or training may be provided by the Principal Investigator or designee; if the online training is not used, training documentation must be maintained in the lab for review by Environmental Health & Safety.

Note: The online training does have a one-year expiration. In laboratories, a standard operating procedure (SOP) for formaldehyde and/or formaldehyde solution use must be developed and maintained with lab-specific documentation.

All persons assigned to workplaces where airborne formaldehyde concentrations meet or exceed 0.1 ppm must be trained on an annual basis to confirm their understanding of formaldehyde, its hazards, and the available methods of protection. Such locations may include necropsy areas, histology, pathology, and anatomy labs/classes. It may also include areas where formaldehyde-containing products are used without engineering controls, such as when larger quantities of these products are used in the field. This training is mandatory and is available online. The online training must be supplemented by training performed by the principal investigator or supervisor on lab or workgroup-specific procedures.

If all work using formaldehyde-containing materials is performed inside a chemical fume hood or using snorkels or similar engineering controls, it is presumed that exposures over 0.1 ppm will not occur unless there is a spill outside of these controls. Similarly, if all work is performed in a Class II A2 or B biosafety cabinet that is connected to the building hazardous exhaust system, and where only small quantities are used, it is presumed that exposures over 0.1 ppm will not occur. Work with minute quantities where the exposures are of very short duration (for example, opening up a small container of formalin in which to place a piece of excised tissue) are also not of concern. For assistance or to arrange to monitor for suspect work exposures, please contact EHS directly.

Note that histology, pathology, and anatomy labs must comply with the written Hazard Communication Program requirements and the formaldehyde program guidance, not the Chemical Hygiene Plan requirements. See this program summary for guidance.

Scope

This program applies to all persons who work with or perform work in areas where formaldehyde-containing materials or products are used.

Environmental Health & Safety

Environmental Health & Safety is responsible for:

• Developing, implementing, and administering the program;
• Providing training on the safe use of formaldehyde-containing products and materials;
• Maintaining centralized records if online training is taken;
• Conducting formaldehyde exposure monitorings;
• When requested or as needed, review and provide feedback on formaldehyde use and recommend appropriate work procedures, controls, and personal protective equipment (PPE); and
• Evaluating the overall effectiveness of the program on a periodic basis and making appropriate changes as needed to assure the safety of personnel.

Involvement by Environmental Health & Safety does not relieve the departments, supervisors, or contractors of their individual responsibilities.

Principal investigators and supervisors

• Address the use of formaldehyde as part of the laboratory-specific documentation in the Chemical Hygiene Plan if applicable, or the Hazard Communication Plan for other worksites.
• Ensure that personnel performing work with formaldehyde are trained and provided appropriate protective equipment.
• Ensure that personnel are utilizing the proper engineering controls, work practices, and personal protective equipment (PPE) to minimize formaldehyde exposure.
• Contact Environmental Health & Safety to arrange exposure monitoring whenever work area exposures are or may be over 0.1 parts per million (ppm).

Employees

• Attend required training, either online and/or as provided by the principal investigator or designee. The online training must be taken if work area exposures are or may be greater than 0.1 ppm.
• Review and follow proper work practices, utilize proper engineering controls, and wear proper personal protective equipment to minimize formaldehyde exposure.

Ventilation is the best method for reducing the concentration of airborne substances in the breathing zone of workers. Local exhaust ventilation in the form of a chemical fume hood, snorkel, or downdraft table must be used whenever possible. Class II A2, B, or C1 biosafety cabinets that are connected to the building hazardous exhaust system can be used if only minute quantities of formaldehyde are being used over a short duration.

Work practices and administrative controls can also help in reducing airborne concentrations of formaldehyde and potential exposures and are to be used in conjunction with engineering controls. Recommended work practices include:

• Develop a standard operating procedure (SOP) for formaldehyde and/or formaldehyde solution use;
• Keep solution containers of formaldehyde closed when not in use;
• Use the smallest amount of formaldehyde required for each procedure;
• Perform tasks involving formaldehyde in well-ventilated areas;
• Do not autoclave or microwave formaldehyde solutions;
• Use formaldehyde preservative substitutes whenever possible; and
• Assure that all primary and secondary containers are labeled as required.

Personal protective equipment (PPE) is important to prevent employee splash or other sudden contacts with formaldehyde by creating a barrier between the user and formaldehyde. PPE minimizes the potential for employee exposure, but unlike engineering and work practice controls, does not reduce ambient formaldehyde exposure levels. Therefore PPE should only be used as a supplement to engineering and work practice controls. Recommended PPE includes impermeable gloves, eye protection, lab coats, and in some cases respiratory protection.

Respirators are only to be used in limited circumstances (emergencies or when engineering/work practice controls are not feasible). Persons wearing respiratory protection must receive training, fit testing, and a medical evaluation from Environmental Health & Safety before being permitted to wear tight-fitting respirators.

If a person's skin could be splashed with solutions containing 1 percent or greater formaldehyde (because of equipment failure, work practices or an accident), a quick drench safety shower must be available for use.

If a person's eyes could be splashed with solutions containing 1 percent or greater formaldehyde (because of equipment failure, work practices or an accident), a safety eyewash must be available for use.

In areas where formaldehyde is utilized and spills may occur, provisions must be made to contain spills, decontaminate the work area and dispose of the waste. Employees cleaning up spills must be properly trained and wear suitable protective clothing. For small spills (<100 ml aqueous solution), remove all ignition sources, isolate the hazard area and deny entry to unnecessary persons, contain the spill with absorbent materials while wearing proper protective equipment. For larger spills (>100 ml aqueous solutions), spills outside a chemical fume hood or biosafety cabinet, or emergencies where the permissible exposure limit (PEL) or short-term exposure limit (STEL) may be exceeded, evacuate the area and call 540-231-3600 during work hours or 911 after hours. 

To clean up solid Paraformaldehyde, dampen the absorbent pad with methanol before placing it over the spilled material and allow it to sit for a few minutes before wiping up. After the spill has been completely absorbed, wash down the contaminated area with soap and water at least two times.

All debris resulting from a spill response, including any contaminated clothing and PPE, must be kept in a properly labeled, sealed container until it can be removed by Environmental Health & Safety as hazardous waste.

The OSHA permissible exposure limit (PEL) for formaldehyde is 0.75 parts per million (ppm) as an 8-hour time weighted average (TWA) and a short-term exposure limit (STEL) of 2 ppm in a 15-minute period. The OSHA action level (AL) for formaldehyde is 0.5 ppm as an 8-hour TWA. The action level is the threshold for increased exposure monitoring and initiation of medical surveillance.

Exposure monitoring is required for work areas where the concentration of formaldehyde exceeds the STEL or AL. Representative sampling will be performed in order to determine which university work activities fall within this scope. EHS will conduct initial exposure monitoring for employees who may be exposed at or above the STEL or AL. Initial monitoring will be repeated each time there is a change in production, equipment, personnel, or control measures which may result in new or additional exposure to formaldehyde. If an employee exhibits signs and symptoms of formaldehyde exposure, Environmental Health & Safety will promptly monitor the affected employee’s exposure. Periodic monitoring will be conducted for those employees with initial monitoring results at or above the STEL or AL. If the last monitoring results reveal employee exposure at or above the AL or STEL, Environmental Health & Safetywill repeat monitoring at least every six months. Periodic monitoring will be discontinued if the results from two consecutive sampling periods show that the employee exposure is below the AL and the STEL.

Processes or occupational activities at Virginia Tech that may result in formaldehyde exposure include (but are not limited to):

• Handling biological specimens/tissues preserved in formaldehyde;
• Sterilization or disinfection procedures;
• Embalming procedures;
• Gross Anatomy laboratories involving cadavers; and
• Fumigation procedures.

If all work using formaldehyde-containing materials is performed inside a chemical fume hood or using a snorkel or similar engineering control, it is presumed that exposures over 0.1 ppm will not occur unless there is a spill outside of these controls. Similarly, if all work is performed in a Class II A2, B or C1 biosafety cabinet that is connected to the building hazardous exhaust system, and where only small quantities are used, it is presumed that exposures over 0.1 ppm will not occur. Work with minute quantities where the exposures are of very short duration (for example, opening up a small container of formalin in which to place a piece of excised tissue) are also not an exposure concern. For assistance or to arrange to monitor for suspect work exposures, please contact Environmental Health & Safety directly.

Employee(s) will be notified in writing of the results of the assessment within 15 workdays or the results will be posted in an appropriate location accessible to all affected persons.

If the result is above the STEL, AL, or PEL, the notification will include the actions that are being taken to reduce the exposure to below these limits.

The university will establish regulated areas where the concentration of airborne formaldehyde exceeds either the PEL or the STEL and post and maintain legible signs bearing the following information at all entrances or access ways:

DANGER

FORMALDEHYDE

IRRITANT AND POTENTIAL CANCER HAZARD

AUTHORIZED PERSONNEL ONLY

Access to the regulated area shall be limited to authorized persons who have been trained to recognize the hazards of formaldehyde.

Medical surveillance will be provided by Environmental Health & Safety for all employees exposed to formaldehyde at or above the AL or STEL. Occupational medical services are also available for employees who develop signs and symptoms of overexposure to formaldehyde and for employees exposed to formaldehyde in emergencies. If respirators need to be worn by an employee, the employee must be medically cleared, fitted to the respirator, and trained annually by Environmental Health & Safety.

Each histology, pathology, and human or animal anatomy laboratory, and any workgroup using formaldehyde outside of other types of laboratories, must include formaldehyde in its hazard communication program. This includes proper labeling and having a Safety Data Sheet (SDS).

All persons exposed to formaldehyde (including those that receive or transport biological samples/tissues preserved in formaldehyde) must be trained on its hazards and the available methods of protection. This training must occur at the time of initial job assignment and whenever a new exposure to formaldehyde is introduced into the work area. The online training may be used, but it must be supplemented by the lab and procedure-specific training. If training is provided by the principal investigator or designee in lieu of the online training, it must address the following:

• Properties of formaldehyde;
• Formaldehyde exposure limits and exposure monitoring;
• Engineering and work practice controls in use in the lab;
• Required use of personal protective equipment;
• How to respond to spills and other exposure events;
• Potential health effects; and
• How to recognize and reports signs or symptoms of formaldehyde exposure.

Training documentation must be maintained in the lab for at least three years for review by Environmental Health & Safety. Note: The online training does have a one-year expiration. 

All persons assigned to workplaces where airborne formaldehyde concentrations meet or exceed 0.1 ppm must be trained on an annual basis to confirm their understanding of formaldehyde, its hazards, and the available methods of protection. Such locations may include necropsy areas, histology, pathology, and anatomy labs/classes. It may also include areas where formaldehyde-containing products are used without engineering controls, such as when larger quantities of these products are used in the field. The training is mandatory and must be repeated annually. You can register to take this training online. This training must be supplemented by specific training on the engineering and work practice controls used at the location.