FORMALDEHYDE TRAINING

1. FORMALDEHYDE TRAINING

2. CONTENTS • Review of the OSHA Formaldehyde Standard • Potential Health Effects • Medical Surveillance • Personal Protective Clothing and Equipment • Safe Work Practices for Specific Operations • Spill Procedures • Appendix A: Material Safety Data Sheets (MSDS) • Appendix B: Air Monitoring Results

3. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.0148) • SCOPE • Applies to all occupational exposures to formaldehyde (i.e. formaldehyde gas, its solutions and materials that release formaldehyde)

4. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • Permissible Exposure Limits • TWA - 0.75ppm, as an 8-hour time-weighted average • STEL - 2.0pppm, any 15-minute period during the work shift • Action Level - 0.5 ppm, as an 8-hour TWA

5. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • Exposure Monitoring • Initial Monitoring • All employees who may be exposed at or above the Action Level or STEL • Periodic Monitoring • Exposures to at or above the action level, repeat monitoring every 6 months • Exposures at or above the STEL, repeat monitoring at least once a year during worst case conditions • Termination of Monitoring • if the result from two consecutive sampling periods taken at least 7 days apart indicate employee exposure below the action level and the STEL

6. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • Regulated Areas • Shall be established where airborne formaldehyde concentrations exceed the TWA and STEL • Post danger signs at entrances and access ways • Access limited to authorized persons

7. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • Control Methods • Institute engineering controls and work practices to maintain exposures below the TWA and STEL • Where necessary supplement controls with respiratory protection

8. OSHA FORMALDEHYDE (29 CFR 1910.1048 • Respiratory Protection • Where respirators are required, they will be provided at no cost to the employee, will be used properly, and will reduce formaldehyde exposures to levels at or below the TWA and STEL. • Whenever respirator use is required, a respiratory protection program conforming with OSHA regulations will be instituted.

9. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • Protective Equipment and Clothing • Contact of the skin and eyes with liquids containing 1 percent of more formaldehyde will be prevented by the use of protective clothing made of material impervious to formaldehyde and using protective equipment such as goggles and face shields, as appropriate to the operation.

10. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • Hygiene Protection • Change rooms will be provided for employees required to change from work clothing into protective clothing to prevent skin contact • Emergency showers will be located in areas where employees skin may be splashed with solutions containing 10% or greater formaldehyde • Emergency eye washes will be located in areas where employees eyes may be splashed with solutions containing 0.1% or greater formaldehyde

11. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • Housekeeping • Preventative maintenance of equipment, including surveys for leaks will be performed regularly • In areas where spillage may occur, provisions will be made to contain spills, decontaminate the work area and dispose of the waste • Employees repairing equipment leaks and cleaning up spills will be properly trained and will wear suitable protective equipment • Formaldehyde contaminated waste and debris will be placed in sealed containers bearing formaldehyde hazard warning labels

12. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048 • Medical Surveillance • Institute medical surveillance programs for all employees exposed to formaldehyde at concentrations at or exceeding the Action Level or exceeding the STEL • Medical disease questionnaires • Medical examinations • All medical procedures will be performed by or directly supervised by a licensed physician.

13. OSHA Formaldehyde Standard (29 CFR 1910.1048) • Hazard Communication • Formaldehyde gas, all mixtures or solutions composed of greater then 0.1 percent formaldehyde, and materials capable of releasing formaldehyde into the air at concentrations reaching or exceeding 0.1 ppm shall be considered a health hazard. • Employer shall comply with requirements of 29 CFR 1910.1200 (Hazard Communication) • Inform employees of specific health hazards (e.g.. cancer, irritation, sensitization of skin and respiratory system, eye and throat irritation, acute toxicity)

14. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • Hazard Communication (Cont'd) • Material Safety Data Sheets MSDS (provided by manufacturer) • Labels on all containers where formaldehyde constitutes a health hazard. Labels identify the chemical, list name and address of responsible party, contain the information “Potential Cancer Hazard”, and appropriately warn of other hazards

15. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • Employee Information and Training • All employees assigned to workplaces where there is a health hazard from formaldehyde shall participate in a training program. • Training will be provided at the time of the employees initial assignment and whenever a new hazard from formaldehyde is introduced into the work area. • Information and training will be provided at least annually for employees exposed to formaldehyde concentrations at or above the action level or STEL.

16. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • Employee Information and Training (Cont'd) • Affected employees will be informed of the location of written training materials and at their request, will be provided with this materials at no cost. • Information and training will be provided at least annually for employees exposed to formaldehyde concentration at or above the action level or STEL. • Affected employees will be informed of the location of written training materials and at their request, will be provided with this materials at no cost.

17. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • The employer will establish and maintain an accurate record of the following: • All measurements taken to monitor employee exposure to formaldehyde. • If no exposure monitoring is performed, the data used to determine that monitoring is not required. • Medical surveillance information • Respirator fit testing information

18. OSHA FORMALDEHYDE STANDARD (29 CFR 1910.1048) • RECORDKEEPING • Exposure records and determinations: at least 30 years • Medical records: the duration of employment plus 30 years • Respiratory fit test records: until replaced by more recent a record

19. Air Concentration (ppm) 0 - 0.5 0.05 - 1.50 0.05 - 2.0 0.10 - 5.0 Reported Health Effects None Odor threshold Eye sensation/irritation Irritation of the nose and throat Difficulty in breathing, burning sensation in the nose and throat, and coughing POTENTIAL HEALTH EFFECT - INHALATION

20. Air Concentration (ppm) 25 - 50 50 - 100 100 Reported Health Effects Tissue damage and serious respiratory tract injury such as pneumonitis. Associated symptoms may include sneezing, wheezing, chest constriction, bronchitis, headache excessive thirst, weakness, palpitations, nausea and vomiting Pulmonary edema/inflammation - severe lower airway effects Death. POTENTIAL HEALTH EFFECT - INHALATION

21. POTENTIAL HEALTH EFFECTS - INHALATION • Chronic Exposure: • Repeated or prolonged exposure may cause headache, rhinitis, nausea, drowsiness, respiratory impairment, kidney injury and pulmonary sensitization. • Neuropsychological effects may include sleep disorders, irritability, altered sense of balance, memory deficits loss, of concentration, and mood alterations. • Menstrual disorders and secondary sterility have occurred in women.

22. POTENTIAL HEALTH EFFECTS - INHALATION • Carcinogenic Effects: • Long-term exposure to formaldehyde is reported to be associated with an increased risk of cancer of the nose and accessory sinuses and nasopharyngeal and oropharyngeal cancer in humans.

23. POTENTIAL HEALTH EFFECTS - INGESTION • Acute Exposure: • Ingestion of formaldehyde solutions may cause burning of the mouth, throat and stomach, difficulty swallowing, nausea, vomiting and diarrhea, severe abdominal pain, headache, hypertension, vertigo, stupor, convulsions, unconsciousness and coma. May also cause damage to the liver, heart, brain, spleen, pancreas, kidney, and central nervous system. Mean fatal dose in humans is 1-2 ounces of a 37% solution. • Chronic Exposure • Repeated ingestion of small amounts of formaldehyde may cause gastrointestinal irritation, vomiting, and dizziness.

24. POTENTIAL HEALTH EFFECTS - SKIN CONTACT • Acute Exposure: • Vapors or solutions may cause smarting, white discoloration, roughness, hardness anesthesia, and first degree burns. In previously exposed individuals subsequent exposures may result in a sensitization dermatitis characterized by the sudden eruption of blisters on the eyelids, face, neck, scrotum and arms. • Chronic Exposure • Prolonged or repeated exposures may cause second degree burns, numbness, and itching rash, fingernail damage, hardening of tanning of the skin and sensitization. The dermatitis results from chronic exposure to formaldehyde may be either a sudden blistering reaction, or may be delayed several years with eruptions starting on the digital areas, wrists and other parts of the body

25. POTENTIAL HEALTH EFFECTS - Eye Contact • Acute Exposures • Airborne concentrations from 0.05 - 3.0 ppm may cause irritation with redness, itching, pain, blurred vision, and mild tearing. Concentrations from 4 - 20 ppm may cause profuse tearing and damage to the eye. Aqueous solutions effects range from transient, minor injury and discomfort to severe, permanent corneal pacification and loss of sight. • Chronic Exposure • Effects depend on the concentration and duration of exposure. • Reporting Symptoms • Employees will immediately report to their manager, other supervisory personnel, or site medical personnel, the development of any adverse signs or symptoms suspected of being related to formaldehyde exposure.

26. MEDICAL SURVEILLANCE PROGRAM • General • The employer shall institute medical surveillance programs for all employees who: • are exposed to formaldehyde concentrations at or above the Action Level or above the STEL • develop signs and symptoms of overexposure to formaldehyde (see MSDS) • are exposed to formaldehyde in an emergency • All medical procedures will be performed by or under the supervision of a licensed physician and will be provided without cost to the employee, without loss of pay, and at a reasonable time and place.

27. MEDICAL SURVEILLANCE PROGRAM • Medical Surveillance • Administration of a medical disease questionnaire and an evaluation of the questionnaire by a physician to determine whether a medical examination is necessary (employees not wearing respirators) will be made available to employees: • prior to assignment to a job where formaldehyde exposure is at or above the action level or above the STEL and annually thereafter • promptly upon determining that an employee is experiencing signs and symptoms indicative of possible overexposure to formaldehyde

28. MEDICAL SURVEILLANCE PROGRAM • Medical Examinations • Medical examinations will be given to any employee when: • based on the information provided on the medical questionnaire, the physician feels the employee may be at increased risk from exposure to formaldehyde • the employee is required to a wear respirator to reduce exposure to formaldehyde (see Respiratory protection Policy) • Medical examinations will be made available as soon as possible to employees exposed to formaldehyde in an emergency

29. MEDICAL SURVEILLANCE PROGRAM • Physician’s Written Opinion • For any examination required by the standard, the employer will obtain a written opinion from the examining physician discussing only those findings relating to occupational exposures to formaldehyde • The written opinion will include: • physician’s opinion as to whether the employee has a medical condition that would increase the risk of material impairment of health with exposure to formaldehyde • recommendations on limiting employee’s exposure or changes inure of personal protective equipment • a statement that the employee has been informed by the physician of any medical conditions that would be aggravated by exposure to formaldehyde and whether there is need for further examination or treatment

30. MEDICAL SURVEILLANCE PROGRAM • Physician’s Written Opinion (Cont'd) • The employer will retain the results of the medical examination and tests conducted by the physician in records • The employer will provide a copy of the physician’s written opinion to the affected employee within 15 days of its receipt

31. PERSONAL PROTECTIVE CLOTHING AND EQUIPMENT • Purpose • To provide employees with a means of protecting themselves against unnecessary exposures to formaldehyde • Skin Contact: Protective gloves, sleeves, aprons • Eye Contact: Safety glasses/goggles, face shields • Inhalation: Local exhaust ventilation (LEV), respirators

32. PERSONAL PROTECTIVE CLOTHING AND EQUIPMENT • Proper Use • Personal protective clothing and equipment can only be effective if it is used properly. • Select the appropriate type of clothing or equipment (e.g. gloves, respirators, LEV) according to Hazard Assessment performed by supervisor for PPE. • Properly maintain and store personal protective equipment after use. • Replace defective or damaged personal protective equipment such as safety glasses, gloves, or respirator components. Mechanical equipment such as LEV can be effectively repaired.

33. PERSONAL PROTECTIVE CLOTHING AND EQUIPMENT • Limitations • Personal protective equipment appropriate for use with one substance may be totally inappropriate for use with another substance (e.g. respirators, gloves). Inappropriate use of personal protective equipment may result in unnecessary exposures or injury • Know the expected service life of personal protective equipment and replace it as necessary. • For respirator cartridges utilizing adsorption as the filtration mechanism, when all available collection sites have been filled, “break through” occurs and contaminants will pass through the cartridge. • Likewise, gloves will provide protection for only specific periods of time before the contaminant permeates through the glove material and “breakthrough” occurs.