Formaldehyde Program

Policy

All laboratories that use formaldehyde gas, its solutions, and materials that release formaldehyde shall adhere to the requirements stated in this policy and all related programs indicated.

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Authority and Responsibility

Environmental Health and Safety is responsible for:

  • Implementing this program;
  • Conducting exposure monitoring;
  • Recommending control methods; and
  • Revising this program in accordance with newly promulgated standards by the Occupational Safety and Health Administration (OSHA) or when circumstances such as exposure incidents occur.

Lab managers are responsible for:

  • Ensuring lab personnel working with formaldehyde gas, its solutions, and materials that release formaldehyde are trained in the hazards related to formaldehyde exposure; and
  • Ensuring personnel wear the proper personal protective equipment.

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Exposure Monitoring

All laboratories, which use formaldehyde in the workplace, must monitor employee exposure unless the employer can objectively document that the presence of airborne formaldehyde will not exceed the action level (AL) or short-term exposure level (STEL) under foreseeable conditions. 

Exemption

The use of 10% formalin has been reviewed and is exempt from the exposure monitoring requirement. The 10% formalin solution has a concentration of 4% formaldehyde and is primarily used in small quantities, which meet the OSHA definition of laboratory scale (milliliters).  Therefore, if the 10% formalin is utilized under acceptable engineering controls (i.e., fume hood or a Class IIB biosafety cabinet), objective data supports the conclusion that this task is exempt from the exposure monitoring requirement.   However, the lab must create a Standard Operating Procedure (SOP) for the use of 10% formalin.  The SOP shall cover potential hazards, engineering controls, protective equipment and spill response.  The lab occupants handling the 10% formalin, must sign-off on the SOP.   Training records must be on hand for review by the Safety Office or external regulatory agencies. 

Initial Monitoring

Environmental Health and Safety shall conduct initial exposure monitoring for employees who may be exposed at or above the AL of 0.5 parts per million (ppm) or at or above the STEL of two ppm.

Initial monitoring shall be repeated each time there is a change in production, equipment, personnel, or the control measures which may result in new or additional exposure to formaldehyde.

Periodic Monitoring

Periodic monitoring shall be conducted for those employees with initial monitoring results at or above the AL or STEL. Monitoring shall be conducted at least every six months.

Termination of Monitoring

Periodic monitoring shall be discontinued if the results from two consecutive sampling periods show that the employee exposure is below the AL and the STEL.

Employee Notification

Environmental Health and Safety shall notify the employee of the results within 15 business days of receiving the results of exposure monitoring. Notification shall be in writing. If the employee’s exposure is over either permissible exposure limit (PEL), STEL or AL, Environmental Health and Safety shall develop and implement a written plan to reduce employee exposure and give written notice to the employee. The written notice shall contain a description of the corrective action being taken to decrease the exposure.

Recordkeeping

Employee exposure monitoring results shall be maintained by Environmental Health and Safety. The records shall include: the date of the measurement; the operation being monitored; the methods of sampling and analysis and evidence of their accuracy and precision; the number, durations, time, and results of samples taken; types of protective devices worn; and the names, job classifications, social security numbers, and exposure estimates of the employees whose exposures are represented by the actual monitoring results.

Where Environmental Health and Safety has determined that no monitoring is required under this policy, 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 shall be maintained.

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Regulated Areas

Regulated areas shall be established where the concentration of airborne formaldehyde exceeds the TWA or the STEL. Signs shall be posted at all entrances and access ways with signs bearing the following information:

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.

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Methods of Compliance

Engineering and work practice controls shall be instituted to maintain employee exposure to formaldehyde at or below the TWA and the STEL. Whenever Environmental Health and Safety has established that feasible engineering controls and work practices cannot reduce employee exposure to or below either of the PELs to the extent feasible, respirators which satisfy this standard shall be provided.

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Respiratory Protection

Respirators shall be worn in the following situations:

  • During periods necessary to install or implement feasible engineering and work-practice controls;
  • During work operations, such as maintenance and repair activities or vessel cleaning, for which the employer establishes that engineering and work-practice controls are not feasible;
  • During work operations for which feasible engineering and work-practice controls are not yet sufficient to reduce employee exposure to or below the PELs; and
  • In an emergency.

The following table indicates the minimum requirements for respiratory protection under specific concentrations of formaldehyde.

Formaldehyde Concentration; Minimum Respirator Concentration Required

  • Up to 7.5 ppm: Full facepiece with cartridges or canisters specific for formaldehyde. (Note: Half-mask respirators with formaldehyde cartridges are permitted if gas-proof goggles are used with the mask.)
  • Up to 75 ppm: Full facepiece with chin, back, or chest style industrial sized canisters specific for formaldehyde.
  • Above 75 ppm: Self-contained breathing apparatus with positive pressure full facepiece.
  • Escape: Self-contained breathing apparatus, demand pressure-demand mode.

When air-purifying cartridge respirators are used, the cartridge shall be replaced after three hours of use or at the end of the workshift, whichever is shorter.

For specific information related to respirator use, refer to the Respiratory Protection Program.

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Personal Protective Equipment

The University of Chicago shall provide personal protective equipment to the employee at no cost. Lab managers shall assure that the employee wears the personal protective equipment provided to them. The type of protective clothing and equipment used shall be determined by Environmental Health and Safety and shall be based upon the form of formaldehyde to be encountered, the conditions of use, and the hazard to be prevented. Refer to the Personal Protective Equipment policy.

All contact of the eyes and skin with liquids containing one percent or more of formaldehyde shall be prevented by the use of chemical protective clothing made of a material impervious to formaldehyde.

Emergency showers and eye washes shall be readily accessible for employees if there is a possibility that the eyes or skin may be splashed with solutions containing 0.1% or greater of formaldehyde.

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Medical Surveillance

A medical surveillance program shall be implemented for all employees exposed to formaldehyde at concentrations at or above the AL or exceeding the STEL. Medical surveillance shall also be made available to any employee who develops signs and symptoms of overexposure to formaldehyde and for all employees exposed to formaldehyde in an emergency. The program shall consist of medical and physical examinations performed by a physician to detect any symptoms of overexposure.

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Hazard Communication

All employees who, under reasonably foreseeable conditions of use, could be exposed to concentrations of formaldehyde reaching or exceeding 0.1 ppm shall have the hazards associated with formaldehyde exposure communicated to them.

Labels

Hazard warning labels shall be affixed to formaldehyde gas containers, all containers with mixtures or solutions composed of greater than 1% formaldehyde, and containers with materials capable of releasing formaldehyde into the air. The label shall 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 a Material Safety Data Sheet.

Training

Training shall be provided to all employees who have the potential to be exposed to formaldehyde at or above 0.1 ppm. The training shall include, at a minimum, a description of the medical surveillance program, an explanation of the Material Safety Data Sheet for formaldehyde, a description of the potential health effects associated with exposure to formaldehyde, instructions for handling spills and emergencies, an explanation in the purpose for, proper use of, and limitations of personal protective equipment. Employees shall be trained at the time of initial assignment and whenever a new exposure to formaldehyde is introduced to the workplace. The training shall be repeated annually.

Reviewed: February 2014

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