Title
Laboratory Safety Manual - Chapter 20: Formaldehyde Exposure Control Policy
Regulatory Standard
The Occupational Safety and Health Administration (OSHA) issued a standard (29 CFR 1910.1048) to ensure proper protection of all workers exposed to formaldehyde. The standard applies to all forms of formaldehyde including gas, aqueous solutions, solids, and materials that can release it. The OSHA permissible exposure limit (PEL) for formaldehyde is 0.75 parts per million (ppm) as an 8-hour time weighted average (TWA) and a short-term exposure limit (STEL) of 2 ppm in a 15-minute period. The OSHA action level (AL) for formaldehyde is 0.5 ppm as an 8-hour TWA. The action level is the threshold for increased exposure monitoring and initiation of medical surveillance.
Scope of Applicability
The Formaldehyde Exposure Control Policy applies to all laboratories and laboratory personnel on campus.
Responsibilities
Principal Investigators
- Designate and address the use of formaldehyde as part of the individual Laboratory Safety Plan.
- Ensure that laboratory personnel are aware of and trained in the hazards related to formaldehyde exposure.
- Ensure that laboratory personnel are utilizing the proper engineering controls, work practices and personal protective equipment (PPE) to minimize formaldehyde exposure.
Laboratory Employees
- Review the online Formaldehyde training as required
- Review and follow proper work practices, utilize proper engineering controls and wear proper personal protective equipment to minimize formaldehyde exposure.
The Department of Environment, Health & Safety (EHS)
- Implement the UNC Formaldehyde Exposure Control Plan.
- Conduct formaldehyde exposure monitoring.
- Review and provide feedback on individual Laboratory Safety Plans that identify formaldehyde use and recommend appropriate work procedures, controls and personal protective equipment (PPE).
- Continuously update formaldehyde safety resources such as the online Formaldehyde training and Formaldehyde safety webpage.
- Annually review and update the UNC Formaldehyde Exposure Control Plan.
Exposure Control Plan
Health Effects
There are several health effects both chronic and acute that can result from exposure to formaldehyde. Acute exposure to formaldehyde in the range of 0.1-3 ppm can irritate the eyes, nose, and throat, with shortness of breath, cough, and chest tightness occurring in the range of 10-20 ppm. Chronic exposure to formaldehyde can lead to sensitization, asthma-like respiratory problems, dermatitis, and in some cases, cancer. Due to the above acute and chronic symptoms that can occur with exposure to formaldehyde, both the OSHA action level for formaldehyde monitoring and the best workplace practices when working with formaldehyde are designed to keep potential formaldehyde exposures below the level where we would expect to see acute or chronic symptoms.
Hazard Assessment
Processes or occupational activities in UNC Chapel Hill laboratories that may result in formaldehyde exposure include (but are not limited to):
- Handling biological specimens/tissues preserved in formaldehyde
- Sterilization or disinfection procedures
- Embalming procedures
- Gross Anatomy laboratories involving cadavers
- Fumigation procedures
Training
All employees exposed to formaldehyde (including those that receive or transport biological samples/tissues preserved in formaldehyde) must be trained on its hazards and the available methods of protection at the time of initial job assignment and whenever a new exposure to formaldehyde is introduced into the work area. All employees assigned to workplaces where formaldehyde concentration meets or exceeds 0.1 ppm must be trained on an annual basis to confirm their understanding of formaldehyde, its hazards and the available methods of protection. Formaldehyde training is available online.
Hazard Communication
All mixtures or solutions composed of formaldehyde should be labeled to identify formaldehyde. Labels should be clear and should not just include the chemical formula but the full chemical name. Safety Data Sheets (SDSs) should be easily accessible to employees so they may review safety data on formaldehyde.
Medical Surveillance
Employee health complaints should be brought to the attention of the supervisor and employees should seek immediate medical attention at the University Employee Occupational Health Clinic (UEOHC). Medical surveillance will be implemented for all employees exposed to formaldehyde at or above the AL or STEL. Occupational medical services are also available for employees who develop signs and symptoms of overexposure to formaldehyde and for employees exposed to formaldehyde in emergencies.
Exposure Monitoring
Exposure monitoring is required for work areas where the concentration of formaldehyde exceeds the STEL or AL. Representative sampling will be performed in order to determine which university work activities fall within this scope. EHS will conduct initial exposure monitoring for employees who may be exposed at or above the STEL or AL. Initial monitoring will be repeated each time there is a change in production, equipment, personnel, or control measures which may result in new or additional exposure to formaldehyde. If an employee exhibits signs and symptoms of formaldehyde exposure, EHS will promptly monitor the affected employee's exposure. Periodic monitoring will be conducted for those employees with initial monitoring results at or above the STEL or AL. If the last monitoring results reveal employee exposure at or above the AL or STEL, EHS will repeat monitoring at least every six months. Periodic monitoring will be discontinued if the results from two consecutive sampling periods show that the employee exposure is below the AL and the STEL.
Monitoring and Reporting Results
Monitoring results must be relayed to the employee 15 days after exposure monitoring occurred. The principal investigator or supervisor will be responsible for discussing the results with the employee and the employee will verify that they have received and reviewed the results and send a signed copy back to EHS. The signed copy will be placed in the employee's medical file. If the employee's exposure is over the STEL and/or AL, then EHS will develop and implement a plan to reduce employee exposure and give notice to the employee. The notice to the employee will contain a written description of the corrective action being taken to decrease the exposure.
Regulated Areas
The university shall establish regulated areas where the concentration of airborne formaldehyde exceeds either the TWA or the STEL and post and maintain legible signs bearing the following information at all entrances or access ways:
DANGER
FORMALDEHYDE
IRRITANT AND POTENTIAL CANCER HAZARD
AUTHORIZED PERSONNEL ONLY
Access to the regulated area shall be limited to authorized persons who have been trained to recognize the hazards of formaldehyde.
Engineering Controls
Ventilation is the best method for reducing the concentration of airborne substances in the breathing zone of workers. Local exhaust ventilation in the form of a chemical fume hood, snorkel or downdraft table should be used whenever possible.
Work Practices/Administrative Controls
Work practices and administrative controls can also help in reducing airborne concentrations of formaldehyde and potential exposures. Recommended laboratory work practices include:
- Develop a standard operating procedure (SOP) for formaldehyde and/or formaldehyde solution use (see example: Formaldehyde Solution Use in Small Animal Perfusions)
- Keep solution containers of formaldehyde closed when not in use
- Use the minimal amount of formaldehyde required for each procedure
- Perform tasks involving formaldehyde in well ventilated areas
- Do not autoclave or microwave formaldehyde solutions
- Use formaldehyde preservative substitutes whenever possible
Personal Protective Equipment (PPE)
PPE is important to prevent for employee splash or other sudden contact with formaldehyde by creating a barrier between the user and formaldehyde. PPE minimizes the potential for employee exposure, but unlike engineering and work practice controls, does not reduce ambient formaldehyde exposure levels. Therefore PPE should only be used as a supplement to engineering and work practice controls. Recommended PPE includes impermeable gloves, eye protection, lab coats and in some cases respiratory protection. Respirators should only be used in limited circumstances (emergencies or when engineering /work practice controls are not feasible). Employees must receive training, fit testing and medical evaluation before being permitted to wear tight fitting respirators. Air purifying respirators must be approved by NIOSH for protection against formaldehyde.
Housekeeping and Spill Response
In areas where formaldehyde is utilized and spills may occur, provisions must be made to contain spills, decontaminate the work area and dispose of the waste. Employees cleaning up spills must be properly trained and wear suitable protective clothing. For small spills (<100 ml aqueous solution), remove all ignition sources, isolate the hazard area and deny entry to unnecessary persons, contain the spill with absorbent materials while wearing proper protective equipment. For larger spills (>100 ml aqueous solutions) or emergencies where the PEL or STEL may be exceeded, evacuate the area and call EHS (919-962-5507) during work hours or 911 after hours.
Emergency Situations
A written plan should be in effect for work areas that are known to use large volumes of formaldehyde or are more likely to have a spill based on the work process. The emergency plan should be communicated to employees and posted in an accessible area. The EHS Emergency Response/HazMat team and other emergency responders should also be informed of work area in case they respond to a major incident.
Related Requirements
External Regulations and Consequences
29 CFR 1910.1048 (Toxic and Hazardous Substances - Formaldehyde)
Contact Information
Policy Contacts
Catherine Brennan
Executive Director, Department of Environment, Health & Safety
Phone: 919-843-5331
Email: crbrennan@ehs.unc.edu
Back to Chapter Nineteen
Forward to Chapter Twenty One