INDIANA
UNIVERSITY-PURDUE UNIVERSITY at INDIANAPOLIS
IUPUI
• Department of Environmental Health and Safety
•
620 Union Drive, Room 043, Indianapolis, Indiana
46202
Purpose
and Background
The IUPUI Department of Environmental
Health and Safety (EHS) has developed this policy
to ensure a safe work environment and to protect
the health and safety of IUPUI faculty, staff, and
students who utilize or are potentially exposed
to formaldehyde. On May 27, 1992, the Occupational
Safety and Health Administration (OSHA) promulgated
a final rule 29 CFR 1910.1048. This standard applies
to all occupational exposures to formaldehyde -
formaldehyde gas, its solutions, and materials that
release formaldehyde.
Scope
This policy applies to all IUPUI
faculty, staff, and students who are exposed to
formaldehyde.
Policy
This policy has the following objectives:
- Identify employees exposed to
formaldehyde at or greater than 0.1 parts per
million (ppm) averaged over an eight-hour workday
or to solutions that contain greater than 1% formaldehyde
and provide information and training to this group
regarding the hazards of formaldehyde exposure;
- Improve engineering and work
practice controls to limit exposure to less than
the action level (0.5 ppm) for an eight-hour time
weighted average or less than the short term exposure
limit (STEL) of 2.0 ppm for any 15-minute period;
- Provide personal protective
equipment, signs, and labels to protect and notify
employees for the hazards involved;
- Provide information for emergencies
involving exposure or spill cleanup; and
- Institute a medical surveillance plan, if necessary.
Authority
and Responsibility
The
Department of Environmental Health and Safety shall
be responsible for:
- Developing, implementing, and
administering IUPUI’s Formaldehyde Hazard
Communication Program;
- Identifying work areas within
IUPUI facilities that contain formaldehyde;
- Determining which employees are
covered by this regulation;
- Performing all area evaluations;
- Performing all area and personal
air monitoring to determine exposure;
- Providing training to employees
who are covered by this regulation;
- Determining appropriate personal
protective equipment (PPE), work practices, and
engineering controls;
- Maintaining exposure and training
records;
- Reviewing and updating the program
whenever new information is available; and
- Ensuring compliance with all
federal, state, and local regulations.
The Departments on campus shall
be responsible for:
- Identifying those that are working
with or are exposed to formaldehyde;
- Providing the appropriate PPE,
work practices, and engineering controls;
- Ensuring that all faculty, staff,
and students who are assigned to workplaces where
there is exposure to formaldehyde have received
the proper training; and
- Reporting any spills or releases
to EHS.
The Employees shall be responsible
for:
- Participating in a training
session concerning formaldehyde hazards and use;
- Complying with all elements of
this program including their departmental procedures
for safely handling formaldehyde; and
- Reporting an exposure incident
or formaldehyde solution spill to their supervisor.
IUPUI Health Services shall be
responsible for:
- Providing medical consultations
and examinations of employees who are overexposed
to formaldehyde or those who have signs and symptoms
believed to be from an exposure to formaldehyde;
- Providing a written opinion for
each examination and include limitations on exposure
if necessary; and
- Making recommendations for medical
removal from workplace exposure when appropriate.
Health
Effects of Formaldehyde
The following are the health hazards
as reported in Appendix A of this OSHA regulation.
Specific information about commercial mixtures or
formulations may be obtained from manufacturers’
material safety data sheets (MSDS’s).
Acute
Effects of Exposure
Ingestion
(Swallowing): Liquids containing 10 to 40%
formaldehyde cause severe irritation and inflammation
of the mouth, throat, and stomach. Severe stomach
pains will follow ingestion with possible loss of
consciousness and death. Ingestion of dilute formaldehyde
solutions (0.03-0.04%) may cause discomfort in the
stomach and pharynx.
Inhalation (Breathing): Formaldehyde is
highly irritating to the upper respiratory tract
and eyes. Concentrations of 0.5 to 2.0 ppm may irritate
the eyes, nose and throat of some individuals. Concentrations
of 3 to 5 ppm also cause tearing of the eyes and
are intolerable to some persons. Concentrations
of 10 to 20 ppm cause difficulty in breathing, burning
of the nose and throat, cough, and heavy tearing
of the eyes. Concentrations of 25 to 30 ppm cause
severe respiratory tract injury leading to pulmonary
edema and pneumonitis. A concentration of 100 ppm
is immediately dangerous to life and health. Deaths
from accidental exposure to high concentrations
of formaldehyde have been reported.
Skin (Dermal): Formalin (37% aqueous formaldehyde)
is severe skin irritant and a sensitizer. Contact
with formalin causes white discoloration, smarting,
drying, cracking, and scaling. Prolonged and repeated
contact can cause numbness and a hardening or tanning
of skin. Previously exposed persons may react to
future exposure with an allergic eczematous dermatitis
or hives.
Eye Contact: Formaldehyde solutions splashed
in the eye can cause injuries ranging from transient
discomfort to severe, permanent corneal clouding
and loss of vision. The severity of the effect depends
on the concentration of formaldehyde in the solution
and whether or not the eyes are flushed with water
immediately after the accident.
Note - The perception of formaldehyde
by odor and eye irritation becomes less sensitive
with time as one adapts to formaldehyde. This can
lead to overexposure if a worker is relying on formaldehyde's
warning properties to alert him or her to the potential
for exposure.
Chronic Effects of Exposure
Carcinogenicity: Formaldehyde
has the potential to cause cancer in humans. Repeated
and prolonged exposure increases the risk. Various
animal experiments have conclusively shown formaldehyde
to be a carcinogen in rats. In humans, formaldehyde
exposure has been associated with cancers of the
lung, nasopharynx and oropharynx, and nasal passages.
Mutagenicity: Formaldehyde is genotoxic in several
in vitro test systems showing properties of both
an initiator and a promoter.
Toxicity: Prolonged or repeated exposure to formaldehyde
may result in respiratory Impairment. Rats exposed
to formaldehyde at 2 ppm developed benign nasal
tumors and changes of the cell structure in the
nose as well as inflamed mucous membranes of the
nose. Structural changes in the epithelial cells
in the human nose have also been observed. Some
persons have developed asthma or bronchitis following
exposure to formaldehyde, most often as the result
of an accidental spill involving a single exposure
to a high concentration of formaldehyde.
Regulatory
Requirements
OSHA has set employee exposure limits
for formaldehyde. The action level (AL) is 0.5 parts
per million (ppm) calculated as an eight hour time
weighted average (TWA); the permissible exposure limit
(PEL) as an eight hour TWA is 0.75 ppm; and the 15-minute
short term exposure limit (STEL) is 2 ppm.
Exposure
Monitoring
Areas that have formaldehyde must monitor employees
to determine exposures to formaldehyde. Monitoring
is not required if it can be documented that the presence
of formaldehyde cannot result in airborne concentrations
that would cause an employee exposure at or above
the AL of 0.5 ppm or the 15-minute STEL of 2 ppm.
Initial monitoring
Initial monitoring shall be conducted to determine
who may be exposed to airborne concentrations at or
above the AL or STEL. Employee exposure to less than
0.1 ppm indicates a minimal exposure requiring no
further action or training.
Periodic Monitoring
Periodic monitoring shall be conducted for those employees
with initial monitoring results at or above the AL
or STEL. Those exposed to 0.1-0.5 ppm are required
to attend an information and training program but
no additional air sampling is required. For employees
exposed at greater than 0.5 ppm (or 2.0 ppm for a
15-minute STEL), there are several actions required.
This group must attend an information and training
session and repeat air sampling will be conducted
every six months for employees with exposure above
the AL. Monitoring will be conducted annually for
employees exposed about the STEL. In addition, standard
industrial hygiene methods will be employed to reduce
occupational exposure.
Termination of Monitoring
Periodic monitoring shall be discontinued if the results
from two consecutive sampling periods (at least seven
days apart) show that the employee exposure is below
the AL and the STEL.
Employee Notification
Employees shall be notified within 15 days of when
the test results are received of their personal exposure
results. If personal exposure is greater than the
PEL-TWA of 0.75 ppm and 2.0 ppm for a STEL, a written
plan to reduce exposure must be provided to the affected
employee.
Air sampling will be repeated when there is a change
in procedure, equipment, personnel, or control measures.
Air sampling will also be repeated when an employee
reports respiratory or dermal conditions believed
to be caused by formaldehyde.
Recordkeeping
Personal exposure monitoring records will be maintained
by EHS for at least 30 years. All medical surveillance
records will be maintained by Occupational Health/Student
Health Services for the duration of employment and
retained by Medical Records for a period of 30 years
thereafter. Respirator fit test records will be maintained
by EHS until replaced by a more recent record. Records
of training will be kept by EHS.
All records must be made available to the Department
of Labor - IOSHA upon request. Personal exposure records
are available to the subject employee or his representative.
Medical records shall be provided upon request to
the subject employee or to anyone with the subject
employee's written consent.
Engineering
and Work Practice Controls
Engineering controls relate primarily
to proper ventilation to control or dilute employee
exposure to formaldehyde at or below the TWA and STEL.
Depending on the task, proper ventilation may be a
chemical fume hood, slot area ventilators, or general
room ventilation. Local exhaust methods such as fume
hoods or slot ventilators should be used if the formaldehyde
source is small enough that the vapors can be contained
by such a device.
Work practice controls are those measures which reduce
exposure by altering the manner in which tasks are
performed. This may include limiting splashing of
formalin solutions, washing formaldehyde-soaked materials
in water, and maintaining the covers on containers
that emit formaldehyde as much as possible. Surfaces
contaminated with formalin solutions should be cleaned
as soon as possible in order to limit skin and inhalation
exposures. Food and drink consumption and storage
is prohibited from areas where formaldehyde is used
and stored to eliminate the potential for ingestion.
Engineering controls and work practices should be
analyzed by each department for each task or area.
This information should be provided to the users of
formaldehyde and appropriate procedures should be
implemented to reduce exposure.
Regulated
Areas
Regulated areas shall be established
where the concentration of airborne formaldehyde exceeds
the TWA or STEL. Signs shall be posted at all entrances
and access ways with signs bearing the following information:
DANGER
FORMALDEHYDE
IRRITANT AND POTENTIAL CANCER HAZARD
AUTHORIZED PERSONNEL ONLY
All affected employees must be notified of access
restrictions for these regulated areas. Access to
regulated areas shall be limited to authorized persons
who have been trained to recognize the hazards of
formaldehyde.
Labeling
Specific label information is required
for the following materials: formaldehyde gas, mixtures
or solutions containing greater than 0.1% formaldehyde,
and any other material capable of releasing formaldehyde
into the air at concentrations of 0.1 ppm or greater.
Required label information includes:
•
That the product contains formaldehyde.
• The name and address of the responsible
party.
• The words "Potential Cancer Hazard"
and that it is a respiratory sensitizer.
• That physical and health hazard information
is available from EHS and from a Material Safety
Data Sheet.
Personal
Protective Equipment (PPE)
Protective equipment shall be provided by the department
according to the task or area where formaldehyde is
used or stored. Parts of the body that may need to
be protected include eyes, nose and mouth, hands,
arms and the trunk of the body. Butyl and nitrile
rubber are materials that are effective in limiting
penetration of formalin solutions to the skin.
If an employee might be splashed in the eyes with
formalin solutions, goggles are the appropriate eye
protection. If significant splashing is likely, a
face shield in combination with goggles is recommended.
Gloves of appropriate material and thickness for the
task should be used to protect hands. For a task that
may produce splashes to the trunk of the body, an
impermeable suit or rubber apron should be worn to
prevent work or street clothing from becoming wet
and contacting the skin.
If an employee must work in an area where the formaldehyde
concentration cannot be controlled within the TWA
or STEL, a respirator must be worn. Respirator use
requires a medical examination, training, and fit
testing prior to its first use. Other than for emergency
situations, this should not be necessary if appropriate
work practices and engineering controls are implemented.
Emergency,
Spill Clean-up, and Disposal Procedures
Exposure Emergency
For areas where formaldehyde solutions of 1% or greater
are used or stored, an emergency shower must be conveniently
located. Areas that use formaldehyde solutions of
0.1% or greater must have an emergency eyewash located
within the immediate work area.
If a person's eyes, skin, or clothing are splashed
with a formalin solution, the affected area should
be washed with water for at least 15 minutes. For
overexposure to formaldehyde gas, the affected person
should be moved away from the source into fresh air.
If there are symptoms of overexposure, the person
should report to IUPUI Health Services during normal
working hours or University Hospital Emergency Admitting
when IUPUI Health Services is not open.
Spill Cleanup
Formaldehyde spills may create exposure for those
cleaning up the spills. Therefore, a spill should
be handled as described in the Emergency Procedures
Handbook by contacting Public Safety Dispatch at 274-7911.
Disposal
According to the IUPUI Waste Disposal Guidelines,
aqueous formaldehyde solutions up to 10% in concentration
may be disposed by means of the sanitary sewer system.
Solutions should be carefully poured into the drain
without significant splashing and followed by flushing
with cold water for at least five minutes. Formaldehyde
concentrations greater than 10% and any other solutions
that users are not comfortable in pouring down the
drain will be picked up by Environmental Health and
Safety through the Hazardous Waste Manifest System.
Medical
Surveillance
The medical surveillance program is
available to all employees exposed to concentrations
above the AL or the STEL, to employees who develop
signs and symptoms of overexposure, and to employees
exposed during emergencies. All medical procedures
covered by this program will be performed by or under
the supervision of a licensed physician without cost
to the employee.
Medical
Disease Questionnaire
A medical disease questionnaire must
be administered to employees prior to assignment and
annually for a job where exposure to formaldehyde
is at or above the AL or STEL and for employees experiencing
signs and symptoms of overexposure. The questionnaire
asks for information including work history, smoking
history, upper respiratory irritation or disease,
and allergic skin conditions or dermatitis. Results
of the questionnaire will guide the physician in determining
whether a medical exam is necessary.
Medical
Examinations
A medical examination shall be provided
to the appropriate people as a result of the questionnaire
and to those required to wear a respirator to reduce
exposure to formaldehyde. The medical exam will cover
the following:
- A physical exam with emphasis on irritation
or sensitization of the skin or respiratory system,
shortness of breath, or irritation of the eyes.
- Pulmonary function testing for respirator wearers.
- Any other testing which the examining physician
deems necessary.
- Counseling employees who have medical conditions
that may be aggravated by or lead to impairment
of their health by formaldehyde exposure.
A medical exam shall also be
provided to employees exposed to formaldehyde during
an emergency. This exam shall include a medical and
work history with emphasis on any evidence of upper
or lower respiratory, problems, allergic conditions,
skin reactions or hypersensitivity, and any evidence
of eye, nose, or throat irritation. The examining
physician may also conduct any testing deemed necessary
to evaluate the employee's health effects relative
to formaldehyde exposure.
Physician’s
Written Opinion
For each exam performed involving formaldehyde
exposure, a written opinion will be completed by the
examining physician. The opinion will contain only
results that pertain to formaldehyde exposure. Results
of the medical exam must be retained and a copy of
the written opinion must be provided to the affected
employee within 15 days of completion. The written
opinion shall include:
• A statement about
whether the employee has any medical condition that
would place the employee at an increased risk of
material impairment of health from exposure to formaldehyde.
• Any recommended limitations on employee's
exposure or changes in use of personal protective
equipment.
• A statement that the employee has been notified
of the first two requirements.
Medical
Removal
Under certain conditions, it may be
medically necessary to reassign an employee to a comparable
position with significantly less exposure to formaldehyde.
Medical removal provisions apply only to those employees
who report significant irritation of the upper respiratory
system or eyes, respiratory sensitization, and dermal
irritation or sensitization attributed to workplace
formaldehyde exposure. Medical removal does not apply
to skin irritation or sensitization caused by products
containing less than 0.05% formaldehyde.
The following steps must be taken and
conditions met to qualify for medical removal:
• The employee reports
signs or symptoms of exposure to IUPUI Health Services;
• If a medical exam is deemed unnecessary
by the physician, a two-week evaluation/remediation
period begins to ascertain if symptoms subside.
• If conditions get worse during the two-week
period, the employee shall return to IUPUI Health
Services prior to expiration of the two weeks.
• If symptoms have not subsided after two
weeks, the employee shall be examined by IUPUI Health
Services.
• If the exam indicates significant irritation
or sensitization, IUPUI Health Services will make
recommendations of restriction or removal.
• For removal, IUPUI shall transfer the employee
from the current formaldehyde exposure and if possible,
transfer the employee to work having no or significantly
less exposure to formaldehyde;
• The employee shall be transferred to comparable
work for which the employee is qualified or can
be trained in a short period (up to 6 months), where
the formaldehyde exposures are as low as possible,
but not higher than the action level.
• If comparable work is unavailable, IUPUI
shall maintain earnings, seniority and benefits
until such work becomes available, until the employee
is determined to be unable to return to workplace
exposure, until the employee is determined to be
able to return to his original job status, or for
six months, whichever comes first.
• If the affected employee is removed, he
will undergo a second medical exam within six months.
• Compensation during removal may be reduced
if the employee receives compensation from a public
or employer program or from outside employment.
The affected employee may designate
a second physician to review his case and repeat exams
or tests as deemed necessary. If the employee-designated
physician and IUPUI Services do not agree on their
findings and recommendations, a third physician who
is a specialist in the field will be selected by the
two involved physicians. Involved parties will comply
with the findings and recommendations of the third
physician unless an agreement was mutually accepted
that was consistent with recommendations of at least
one of the three physicians.
Hazard
Communication
Information
and Training
Information and training will be
provided to all employees exposed to formaldehyde
at or above 0.1 ppm or to solutions containing greater
than 0.1 percent formaldehyde. Key people in affected
departments will be provided with information that
they will use in training their employees. This
training must be provided at the time of initial
assignment, when a new exposure or procedure is
introduced, and at least annually. Information and
training shall include the following:
• Location and explanation
of this Formaldehyde Hazard Communication Program
and the material safety data sheet(s) for formaldehyde-containing
products.
• A description of the health hazard of formaldehyde.
• Procedures to follow if signs or symptoms
of exposure appear.
• Where formaldehyde is used and stored in
the workplace.
• Work practices and engineering controls
to limit exposure.
• Personal protective equipment (PPE) necessary
for the job.
• Emergency procedures for exposures, spills,
and cleanup.
Employees shall be trained at the time
of initial assignment and whenever a new exposure
to formaldehyde is introduced to the workplace. The
training shall be repeated annually.
Labels
Hazard warning labels shall be affixed
to formaldehyde gas containers, all containers with
mixtures or solutions composed of greater than 1%
formaldehyde, and containers with materials capable
of releasing formaldehyde into the air. The label
shall identify that the product containers formaldehyde,
list the name and address of the responsible party,
and state that the physical and health hazard information
is readily available from an MSDS.
Material Safety Data Sheets
(MSDS’s)
Departments using formaldehyde shall
keep an MSDS readily available to all employees
on all shifts.
Glossary
Action Level (AL) – a concentration
of 0.5 part formaldehyde per million parts of air
(0.5ppm) calculated as an eight (8) – hour
time-weighted average (TWA) concentration.
Authorized Person – any person
required by work duties to be present in regulated
areas, or authorized to do so by the employer or
by the OSH Act of 1970.
Eczematous Dermatitis - is an inflammatory
response of the skin to any of multiple exogenous
and endogenous agents. Also known as eczema.
Emergency – any occurrence,
such as but not limited to equipment failure, rupture
of containers, or failure of control equipment that
results in an uncontrolled release of a significant
amount of formaldehyde.
Employee Exposure – the exposure
to airborne formaldehyde which would occur without
corrections for protection provided by any respirator
that is in use.
Formaldehyde – the chemical
substance, HCHO, Chemical Abstracts Service (CAS)
Registry No. 50-00-0.
Formalin – an aqueous solution
of formaldehyde that contains 4-12% formaldehyde.
Permissible Exposure Limit (PEL)
– a concentration of 0.75 part formaldehyde
per million parts of air (0.75 ppm) calculated as
an eight (8) - hour time-weight average (TWA). No
employee shall be exposed to an airborne concentration
of formaldehyde above the PEL-TWA.
Responsible Party – the manufacture
of the chemical.
Short Term Exposure Limit (STEL)
– a concentration of 2 parts formaldehyde
per million parts of air (2 ppm) calculated over
a 15-minute time period. No employee shall be exposed
to an airborne concentration of formaldehyde above
the STEL for a 15-minute time period.
References
Occupational Health and Safety Administration’s
(OSHA’s) final rule – 29 CFR 1910.1048.
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