DOSH Formaldehyde Standard WAC 296-856

1. DOSH Formaldehyde StandardWAC 296-856 John Furman PhD, MSN, COHN-S DOSH Technical Services

2. 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

3. Formaldehyde • Formalin • Formic Acid • Paraformaldhyde • Formal • Methyl Aldhyde • Methylene Glycol

4. 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

5. 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.

6. 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

7. 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

8. 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.

9. 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.

10. Regulated Areas • Shall be established where airborne formaldehyde concentrations exceed the TWA and STEL • Post danger signs at entrances • Access limited to authorized persons

11. 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

12. 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

13. 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.

14. 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.

15. 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

16. Hygiene • Change rooms -Provided for employees required to change into protective clothing. • Emergency showers - Providedwhere 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.

17. 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.

18. 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.

19. 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.

20. 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

21. 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

22. 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.

23. 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 .

24. 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

25. 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

26. 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

27. 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

28. 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.