DOSH Formaldehyde Standard WAC 296-856

Download Report

Transcript DOSH Formaldehyde Standard WAC 296-856

DOSH Formaldehyde
WAC 296-856
John Furman PhD, MSN, COHN-S
DOSH Technical Services
 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
Formic Acid
Methyl Aldhyde
Methylene Glycol
 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
 In operating rooms as a tissue preservative,
and disinfectant.
Permissible Exposure Limits
 TWA – 0.75ppm, as an 8-hour time-weighted
 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
 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
 Exposure monitoring is not necessary if you
have documentation conclusively demonstrating
that exposures will not exceed the AL or STEL.
 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
 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.
 Breakthrough times and permeation data are
available from most manufactures
 Materials such as neoprene or nitrile are
 Latex is not resistant to most chemicals,
including formaldehyde
 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.
 Preventative maintenance of equipment,
including surveys for leaks will be performed
 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
 Employees may seek a second medical opinion.
Lab Standard
WAC 296-828
 Applies to laboratory use of hazardous
 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
 Training content is listed in the Standard
 Make MSDS available
 Maintain records of:
– All measurements taken to monitor employee
– 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
 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
 WAC 296-828 – Lab Standard
– The employer did not inform and train laboratory
employees about the presence of hazardous
– 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
 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
– $700.00 penalty
 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
 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.