Summary of 1992 Amendments to OSHA Formaldehyde Standard

Background

On May 26, 1992, the Occupational Safety and Health Administration (OSHA) issued a final rule for occupational exposure to formaldehyde, amending a 1987 OSHA regulation. Industry and labor worked cooperatively with OSHA to improve and clarify certain portions of the 1987 rule. The 1992 rule reflects those cooperative efforts and incorporates many of the changes recommended by industry and labor.

Importantly, there are four key changes in the 1992 OSHA standard that
employers must be aware of:

• A reduced exposure limit
• A medical removal provision
• Additional hazard communication standards
• New employee training requirements

Permissible Exposure Limit: Reduced from I ppm to 0.75 ppm

The 1992 OSHA rule reduces the amount of formaldehyde gas workers can be exposed to over an eight-hour period. This permissible exposure limit, or eight-hour time weighted average (TWA), has been reduced to
0.75 parts per million (ppm) from I ppm set in 1987.

Engineering controls to achieve the new 0.75 ppm standard must be in place by June 26, 1993. Respiratory protection equipment required to meet the TWA must be in use by Sept. 24. 1992.

Medical Removal Protection Program (MRP)

The new. medical removal protection program (MRP) supplements existing medical surveillance requirements and is triggered if an employee reports certain formaldehyde-related problems -significant eye or upper airway irritation, respiratory sensitization or dermal irritation or sensitization.

The MRP program generally begins with a two-week remediation and evaluation period, during which steps are taken to improve the employee's condition through controllable factors such as increased ventilation and protective equipment and clothing. After the remediation period, a company-designated physician will determine whether the employee must be removed temporarily, from his/her usual work environment.

If temporary removal is necessary, the company must transfer the employee to a comparable job where there is less or no exposure to formaldehyde. Ifsuch a position is unavailable, employers must guarantee the worker's job, seniority, pay and benefits for up to six months.

Near the end of the temporary removal period, the employee's condition will be re-evaluated. All decisions concerning permanent removal or restricted activity must be made by licensed medical doctors. Employees are entitled to second and third medical opinions as necessary.

The MRP program becomes effective Dec. 28,1992.

Hazard Communication: Labeling Requirements

The 1992 rule contains specific labeling requirements for materials containing more than 0.1 percent (by weight) of formaldehyde.

Where potential workplace exposure from a product that releases formaldehyde is between 0.1 and 0.5ppm over an eight-hour TWA, product labels must state that formaldehyde is present and tell where further safety information is available.
Where potential workplace exposure from a product that releases formaldehyde is greater than 0.5 ppm over the eight-hour TWA, specific information about potential health effects, including cancer, must appear on the label.

The new OSHA hazard communication provisions must be implemented by Dec. 28,1992.

Employee Training: Required Annually

T'he 1992 rule requires annual training for all employees exposed to formaldehyde levels of 0.1 ppm or greater over an eight-hour TWA.

This training should cover all aspects affecting employees' safe work with formaldehyde, including discussion of the contents of material safety data sheets, the purpose of the medical surveillance program, proper use of protective clothing, and equipment and emergency procedures.

As already required, this training must occur at the time of initial
assignment to a workplace where there is potential for exposure, as well as whenever a new workplace formaldehyde exposure occurs.

The new annual training requirement is effective Aug. 25, 1992.

This is asummaryofthe OSHAformaldehyde standard. For complete details, refer to the final rule as published in the May 27,1992, Federal Register Vol. 57 No. 102.

Employees Guide to Compliance with OSHA Formaldehyde Standard

On May 26, 1992, the Occupational Safety and Health Administration
(OSHA) issued a final rule for occupational exposure to formaldehyde;
amending the existing regulation that took effect February 1988 (29 CFR Part 1910-1048). Following is a summary of the major requirements of the standard (changes are in all CAPS):

Scope and Application

The final OSHA standard applies to all occupational exposures to formaldehyde, including formaldehyde gas, its solutions and materials that release formaldehyde. Except where noted, amended portions of the standard took effect June 26, 1992
.
Permissible Exposure Limits

AN EMPLOYEE'S TIME WEIGHTED AVERAGE (TWA) EXPOSURE TO AIRBORNE FORMALDEHYDE CANNOT EXCEED 0.75 PPM OVER AN EIGHT-HOUR PERIOD.
An employee's short term exposure to airborne formaldehyde cannot exceed 2 ppm over a 15-minute period.

Exposure Monitoring

Employers with workplaces covered by the OSHA standard must routinely monitor employee exposure to formaldehyde UNLESS THE EMPLOYER CAN SHOW THAT POTENTIAL EXPOSURE WOULD NOT ORDINARILY REACH THE 0.5 PPM ACTION LEVEL OR 2 PPM SHORT TERM

EXPOSURE LIMIT (STEL). Affected employees must be notified in writing of the results of monitoring tests.
Periodic monitoring must be conducted at least every six months for levels above 0.5 ppm and at the times of greatest concentration for
exposure above the STEL or at least once a year.

Regulated Areas

Where the concentration of airborne formaldehyde exceeds either the TWA or STEI, regulated areas must be established and posted with signs warning:

DANGER
FORMALDEHYDE
IRRITANT AND POTENTIAL CANCER HAZARD
AUTHORIZED PESONNEL ONLY

Access to such areas should be limited to persons who have been trained
to recognize the hazards of formaldehyde.

Methods of Compliance: Engineering Controls and Work Practices

Engineering controls and work practices to minimize exposure to
formaldehyde must be adopted NO LATER THAN JUNE 26, 1993, to
ensure that employee exposure remains at or below the new permissible TWA and the short term exposure limit.
If use of engineering controls and work practices do not bring exposure
within the permissible levels or such measures are not feasible, employers must supplement them with respirators NO LATER THAN
SEPT. 24, 1992, so that the TWA and STEL are met.

Respiratory Protection

When required, respirators must be provided by the employer AS SOON AS POSSIBLE, BUT NO LATER THAN SEPT. 24,1992.
RESPIRATORS USED MUST BE APPROVED BY THE MINE SAFETY AND HEALTH ADMINISTRATION (MSHA) AND BY THE NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH (NIOSH) UNDER 30 CFR PART 11.

Protective Equipment and Clothing
Based on the type of formaldehyde exposure, the conditions of use and potential hazards, employers must provide -and ensure the use and maintenance of -appropriate protective clothing and equipment, such as aprons and formaldehyde-impervious clothing, goggles and face shields.
Contact with the skin or eyes of solutions of 1 percent or more of formaldehyde should be prevented through the use of chemical resistant clothing, goggles and face shields.

Hygiene Protection

Changing areas must be provided for employees required to wear
protective clothing.
Where there is potential for employees to be splashed with formaldehyde
solutions of 1 percent or greater, employers must provide quick-drench
showers.
Where there is potential for employees' eyes to be splashed with solutions of 0.1 percent or more formaldehyde, eyewash facilities must be provided in the immediate work area.

Housekeeping

For operations involving formaldehyde liquids or gas, employers must
monitor for leaks and spills and conduct regular visual inspections.

Emergencies

Where the possibility exists for an emergency involving formaldehyde,
employers must assure that appropriate procedures are in place to
minimize risk.

Medical Surveillance
A medical surveillance program, which includes the administration of a
medical questionnaire and examination by a licensed medical doctor (as
necessary) must be instituted for all employees

• Who are exposed to formaldehyde at the action level or above the ML
• Who develop symptoms of overexposure
• Who are exposed to formaldehyde in an emergency

Medical examinations must be provided for employees who wear
respirators or are exposed to formaldehyde in emergency situations.

Medical Removal

IF AN EMPLOYEE REPORTS CERTAIN FORMALDEHYDE­RELATED HEALTH PROBLEMS -SIGNIFICANT IRRITATION OF THE EYES OR UPPER AIRWAYS, RESPIRATORY SENSITIZATION, DERMAL IRRITATION OR DERMAL SENSITIZATON -MEDICAL REMOVAL PROTECTION PROVISIONS MUST BE INITIATED.

THESE PROCEDURES MUST BE IN PLACE BY DEC. 28,1992, AND INCLUDE PHYSICIAN REVIEW OF SYMPTOMS, ATTEMPTED REMEDIATION THROUGH THE USE OF PERSONAL PROTECTIVE EQUIPMENT OR OTHER WORK PRACTICES, POTENTIAL TEMPORARY JOB TRANSFER, MEDICAL EXAMINATIONS, WITH SECOND AND THIRD MEDICAL OPINIONS AS NECESSARY, AND POSSIBLE PERMANENT REMOVAL.

MEDICAL REMOVAL PROVISIONS DO NOT APPLY IF DERMAL IRRITATION OR SENSITIZATION IS SUSPECTED OF BEING CAUSED BY APRODUCT CONTAINING LESS THAN 0.05 PERCENT FORMALDEHYDE.

IF TEMPORARY REMOVAL IS NECESSARY A COMPARABLE JOB WITH SIGNICANTLY LESS OR NO EXPOSURE TO FORMALDEHYDE MUST BE PROVIDED.

AN EMPLOYEE SUBJECT TO TEMPORARY JOB TRANSFER OR REMOVAL WILL HAVE HIS/HER POSITION, SENIORITY, PAY AND BENEFITS PROTECTED FOR UP TO SIX MONTHS.

Hazard Communication

FORMALDEHYDE GAS, ALL MIXTURES OR SOLUTIONS COMPOSED OF MORE THAN 0.1 PERCENT FORMALDEHYDE AND MATERIALS GENERALLY CAPABLE OF RELEASING FORMALDEHYDE AT CONCENTRATIONS OF ABOVE 0.1 PPM OR GREATER ARE SUBJECT TO GENERAL HAZARD COMMUNICATION REQUIREMENTS EFFECTIVE DEC: 28,1992.

WHERE THE POTENTIAL TWA EXPOSURE FROM A PRODUCT IS BETWEEN 0.1 AND 0.5 PPM, LABELS MUST STATE THAT THE PRODUCT CONTAINS FORMALDEHYDE, GIVE THE NAME AND ADDRESS OF THE RESPONSIBLE PARTY AND TELL WHERE FURTHER SAFETY INFORMATION IS AVAILABLE. WHERE EXPOSURE IS GREATER THAN 0.5 PPM, LABELS MUST ADDRESS POTENTIAL HEALTH HAZARDS INCLUDING RESPIRATORY SENSITIZATION AND MUST CONTAIN THE WORDS "POTENTIAL CANCER HAZARD."LABELING REQUIREMENTS ARE EFFECTIVE DEC. 28,1992.
Those who produce or import formaldehyde or formaldehyde-containing products affected by the standard must provide appropriate labels and material safety data sheets (MSDSs) to downstream users of such products BY DEC. 28,1992.
BY AUG. 25, 1992, employers must develop, implement and maintain a written hazard communication program for formaldehyde exposure in the workplace describing how labeling, warning: training and informational requirements will be met.

Employee Information and Training

Employers must provide training to all employees assigned to workplaces where there is exposure to formaldehyde AT CONCENTRATIONS GREATER THAN 0.1 PPM OVER AN EIGHT-HOUR 'IWABY AUG. 25,1992, UNLESS IT CAN BE SHOWN THAT EXPOSURE IS EQUAL TO OR LESS THAN 0.1 PPM.

This training must be provided at the time of initial assignment, whenever new workplace formaldehyde exposure occurs AND AT LEAST ANNUALLY THEREAFI'ER,
Employee training should include discussion of the contents of material safety data sheets, the purpose of the medical surveillance program, potential health hazards from formaldehyde exposure, the purpose and proper use of personal protective clothing and equipment and emergency procedures.

Recordkeeping

Employers must maintain and keep accurate records of employee exposure monitoring tests, medical surveillance data and respirator fit tests.

Definitions Related to OSHA Formaldehyde Standard

Authorized Person -any person whose work duties require his/her presence in
regulated areas and who has been trained to recognize the hazards of formaldehyde.
Emergency -any occurrence, such as equipment failure. container rupture, etc., that results in an uncontrolled release of a significant amount of formaldehyde.
Employee Exposure -exposure to airborne formaldehyde not corrected for protection
provided by any respirator usage.

Formaldehyde (HCHO) -a simple organic molecule, composed of one carbon, one oxygen. and two hydrogen atoms. HeHO is both naturally occurring and commercially produced. Formaldehyde is an essential ingredient in a number of products and industries, including wood panel products, furniture, resins, glues, textiles, clothing, pharmaceuticals and cosmetics.

Material Safety Data Sheet (MSDS) -a required part of the hazard communication standard. The MSDS must be readily available in the workplace and provide information about potential health hazards, safe handling precautions and first-aid procedures associated with formaldehyde and formaldehyde-containing materials.

Permissible Exposure Limit (PEL) • the average (eight-hour TWA) and short-term (STEL) exposures for airborne formaldehyde that employees may be exposed to without respirators.

Regulated Area -any area in the work-place where the concentration of airborne formaldehyde exceeds the PEL. Such areas must be posted with signs warning: DANGER. FORMALDHYDE. IRRITANT AND POTENTIAL CANCER HAZARD. AUTHORIZED PERSONNEL ONLY.

Short Term Exposure Limit (STEL) -the highest level allowed for short-tenn (15­minute) exposure to formaldehyde. Concentrations of formaldehyde in excess of 2 ppm over a 15-minute period trigger additional employee protection requirements.

Time Weighted Average (TWA) -the average amount of fonnaldehyde a worker may be exposed to during an eight-hour shift. Levels in excess of the 0.75 ppm TWA trigger additional employee protection requirements.
This is a summary ofthe OSHA fom/aldehyde standard. For complete details, refer to the final rule as published in the May 27,1992, Federal Register Vol. 57No. 102.

The Formaldehyde Institute August 1992

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