DOSH Formaldehyde Standard WAC 296-856
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Transcript DOSH Formaldehyde Standard WAC 296-856
DOSH Formaldehyde
Standard
WAC 296-856
John Furman PhD, MSN, COHN-S
DOSH 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 wellventilated 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 296842 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 Standard
WAC 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 [email protected]
For on-site help with exposure monitoring,
PPE selection, etc. contact your local DOSH
Consultation office.