dosh formaldehyde standard wac 296-856

DOSH Formaldehyde StandardWAC 296-856

John Furman PhD, MSN, COHN-SDOSH Technical Services

Scope

Applies to all occupational exposures to formaldehyde (formaldehyde gas, its solutions and materials that release formaldehyde)

– Formalin – 10-37% formaldehyde in solution with methanol or water

Formaldehyde

Formalin Formic Acid Paraformaldhyde Formal Methyl Aldhyde Methylene Glycol

Exposure

Vapors - Formaldehyde is a Volatile Organic Compound (VOC) that can be released as a vapor at room temperature.

Liquids – Is a skin/mucous membrane irritant and sensitizer

Common uses

Tissue preservatives and in embalming fluids in autopsy rooms and pathology labs.

Kidney dialysis units and central supply as a sterilant.

In operating rooms as a tissue preservative, and disinfectant.

Permissible Exposure Limits

TWA – 0.75ppm, as an 8-hour time-weighted average

STEL- 2.0ppm, any 15-minute period during the work shift

Action Level (AL) – 0.5ppm, as an 8-hour TWA– Exposure monitoring – Medical surveillance

Exposure Monitoring

Initial Monitoring– All employees who may be exposed at or above the

AL or STEL Periodic Monitoring

– Exposures at or above the Action Level, repeat monitoring every 6 months

Termination of Monitoring– If the result from two consecutive sampling periods

taken at least 7 days apart indicate exposure below the Action Level and the STEL

Exposure Monitoring

Provide written notification of exposure monitoring results to employees within 5 days of receipt.

Exposure monitoring is not necessary if you have documentation conclusively demonstrating that exposures will not exceed the AL or STEL.

Labeling

Label substances composed of greater than 0.1 percent formaldehyde and capable of releasing formaldehyde at concentrations greater than 0.1ppm to 0.5ppm.

Label templates can be found on the DOSH Chemical Hazard Communication web page.

Regulated Areas

Shall be established where airborne formaldehyde concentrations exceed the TWA and STEL

Post danger signs at entrances

Access limited to authorized persons

Engineering Controls

Institute engineering controls and work practices to maintain exposures below the TWA and STEL– Local exhaust Ventilation (BSCs)– General ventilation

Where necessary supplement engineering controls with respiratory protection

Work Practices

Keep solutions of formaldehyde closed when not in use

Perform tasks involving formaldehyde in well-ventilated areas

Do not autoclave or microwave formaldehyde solutions

Use substitute products whenever possible

Respiratory Protection

Where respirator use is required, a respiratory protection program conforming with WAC 296-842 will be instituted.

Use full-facepiece air-purifying respirators with cartridges or canisters approved for protection against formaldehyde.

Protective Equipment

Protect employees from contact with liquids containing 1 percent or more of formaldehyde.

Employers must ensure that employees wear PPE and respiratory protection.

Gloves

Breakthrough times and permeation data are available from most manufactures

Materials such as neoprene or nitrile are recommended

Latex is not resistant to most chemicals, including formaldehyde

Hygiene Change rooms - Provided for employees

required to change into protective clothing. Emergency showers - Provided where

employees may be splashed with solutions containing >10% formaldehyde

Emergency eye washes - Provided where employees eyes may be splashed with solutions containing >0.1% formaldehyde.

Housekeeping Preventative maintenance of equipment,

including surveys for leaks will be performed regularly.

Provisions for containing spills will be made.– WAC 296-824, Emergency Response applies

whenever an uncontrolled release of formaldehyde may occur.

Medical Surveillance

For employees – Initially and every 12 months for employees exposed

above the AL or STEL– Exposed during an emergency situation– Who develop signs and symptoms of exposure

Performed by or directly supervised by a licensed physician.

Medical Removal

The employer’s LHCP may implement job restrictions or removal

Pay, seniority and benefits are protected for 6 months

Employees may seek a second medical opinion.

Lab StandardWAC 296-828

Applies to laboratory use of hazardous chemicals

A written Chemical Hygiene Plan is required

WAC 296-856, applies to histology, pathology, and anatomy laboratories

Information and Training

Provide training to all exposed employees

Every 12 months and whenever a new hazard is introduced

Training content is listed in the Standard

Make MSDS available

Recordkeeping

Maintain records of:– All measurements taken to monitor employee

exposure.– Data used to determine that exposures will not

exceed the PELs– Medical surveillance information.– Respirator fit testing.

Recent Citations

WAC 296-824 – Emergency Response– Stores over 25 gallons of 10% formalin in 5, five

gallon cubes. – Employees were not trained on hazards and spill

clean up procedures– $700.00 penalty

.

Citations

WAC 296-856-200 – Training– Employees pour formalin or use prefilled formalin

containers for specimens obtained from surgery. Employees working in an area where a formalin spill could occur were not trained on the hazards of formalin exposure.

– $2,100.00 penalty

Citations WAC 296-828 – Lab Standard

– The employer did not inform and train laboratory employees about the presence of hazardous chemicals

– Pathology lab employees exposed to 10% formalin were not trained on the S/S of exposure, Appropriate work practices, emergency procedures, personal protective equipment

– $300.00 penalty

Citations WAC 296-856-200 – PPE

– The employer did not ensure eye protection and face shields were worn for protection from exposure to formaldehyde vapor and splash.

– You must also ensure that when face shields are worn, employees also wear chemical safety goggles

– $700.00 penalty

Citations

WAC 296-800-150 – Emergency Washing– The employer did not ensure that an emergency

eye wash was available where an employee's eyes could come into contact with corrosives, strong irritants, or toxic chemicals.

– Exposure to formalin and metricide– $1,200 penalty

Information

For more information contact Pam Edwards, IH4, 360-902-5436 or EDWP@lni.wa.gov

For on-site help with exposure monitoring, PPE selection, etc. contact your local DOSH Consultation office.