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SM 445-2-H CHAPTER 22

Industrial Hygiene – Formaldehyde Protection Program

22.1  Purpose. To specify the minimum Occupational Safety and Health Program (Program) requirements for providing personnel adequate protection from chemical, physical and/or biological stressors, such as noise, chemical exposures, excessive temperatures, dusts, mists, and vapors within the Department of the Interior (Department or DOI) and U.S. Geological Survey (Bureau or USGS).

22.2  References.

A.  29 CFR 1910.1048, Formaldehyde.

B.  29 CFR 1910.1048 Appendix A, Substance Technical Guidelines for Formalin.

C.  29 CFR 1910.1048 Appendix B, Sampling Strategy and Analytical Methods for Formaldehyde.

D.  29 CFR 1910.1048 Appendix C, Medical Surveillance - Formaldehyde.

E.  29 CFR 1910.1048 Appendix D, Nonmandatory Medical Disease Questionnaire.

F.  29 CFR 1910.1048 Appendix E, Qualitative and Quantitative Fit Testing Procedures.

G.  29 CFR 1910.1200, Hazard Communication Standard.

H.  29 CFR 1910.1450, Occupational Exposure to Hazardous Chemicals in Laboratories.

22.3  Scope. This policy shall apply to all operations and activities within USGS where formaldehyde or formaldehyde-containing compounds or solutions are used.

22.4  Requirements.

A.  Engineering controls shall be employed to the maximum extent practical to eliminate or reduce employee exposures to acceptable levels. Engineering controls include enclosing and/or providing appropriate ventilation systems for subject operations. Approved laboratory hoods or local exhaust ventilation shall be used for all laboratory manipulations involving the use of formaldehyde in sample preservation and preparation.

B.  Limits for employee exposure to formaldehyde shall be in accordance with 29 CFR 1910.1048(C). Air monitoring or formal exposure assessment shall be conducted in accordance with 29 CFR 1910.1048(d). In general monitoring is required unless it can be objectively documented that the operation cannot result in concentrations above the Action Level or Short Term Exposure Limit (STEL) under all expected operating conditions. Previously evaluated operations shall be assessed if there is any change that could reasonably be expected to result in increased exposure.

C.  Where engineering controls are not feasible and airborne concentrations exceed allowable limits, respiratory protection shall be issued in accordance with this Handbook’s chapter on Respiratory Protection and 29 CFR 1910.1048(g). Where potential for skin and eye contact exists, personal protective equipment shall be used per 29 CFR 1910.1048(h) and hygiene facilities provided per 29 CFR 1910.1048(i).

D.  In addition to the applicable training requirements of this Handbook’s chapters on Chemical Hygiene and Hazard Communication, personnel working with formaldehyde or formaldehyde containing solutions shall receive chemical-specific information and training in accordance with 29 CFR 1910.1048(m) - (n).

E.  Medical surveillance shall be provided to personnel who suspect exposures to formaldehyde. Medical records shall be maintained by the servicing Human Resources Office in accordance with current personnel and medical guidelines.

F.  Formaldehyde products shall be stored in a cool, well-ventilated area and in accordance with any additional requirement listed in the Material Safety Data Sheet. Waste formaldehyde products shall be properly stored in a labeled hazardous waste container for proper disposal or made available for recycling if practical.

22.5   Responsibilities.

A.    Bureau Safety Manager/Bureau Industrial Hygienist.

(1)  Develops Bureau wide guidance and program policy on formaldehyde use and compliance.

(2)  Assists Regional Safety Managers in establishing air monitoring protocols and obtaining Public Health Service contracts for air monitoring and medical surveillance as necessary.

(3)  Provide Bureau program oversight and periodically evaluates Regional Headquarters and science program effectiveness, providing recommendations to management for program enhancement.

B.    Regional Safety Managers.

(1)  Review formaldehyde operations as part of Regional Headquarter and Science Program field safety and health evaluations and provide management with recommendations for program improvement.

(2)  Provide technical guidance and assist Regional Safety Officers and Collateral Duty Safety Program Coordinators (CDSPC’s) in establishing personnel training programs.

(3)  Assist Regional Safety Officers in establishing air monitoring protocols and obtaining contracts for air monitoring and medical surveillance as necessary.

C.    Regional Safety Officer.

(1)  Reviews formaldehyde operations as part of science program field safety and health evaluations and provides management with recommendations for program improvement.

(2)  Provides technical guidance and assists field organization CDSPC’s in establishing field employee training programs.

(3)  Assists field organizational management and CDSPC’s in establishing air monitoring protocols and obtaining contract services for air monitoring and medical surveillance as necessary.

D.    Collateral Duty Safety Program Coordinator (CDSPC).

(1)  Assists supervisors and organizational management in coordinating and carrying out all training, medical surveillance, and record keeping requirements of this chapter.

(2)  Coordinates air-monitoring requirements with Regional Safety Officer or Regional Safety Manager, as applicable. The Bureau Industrial Hygienist may be consulted as needed.

E.    Organizational Managers and Supervisors/Project Chiefs/Laboratory Supervisors.

(1)  Provide personnel training specific to the hazards of, and protective measures to be taken when working with, formaldehyde.

(2)  Monitor or otherwise formally assess formaldehyde operations to determine whether potential for overexposure exists.

(3)  Employ engineering controls to the maximum extent practical to eliminate or control formaldehyde exposures to below established safe levels.

(4)  If required, establish and implement respiratory protection and medical surveillance programs for personnel exposed to formaldehyde.

(5)  Coordinate any new operations using formaldehyde with the CDSPC as soon as these operations become known so that hazard controls may be established prior to start up.

(6)  Establish and assign resources necessary to implement engineering controls to eliminate formaldehyde exposures and provide resources necessary to carry out the requirements of this chapter.

22.6   Additional Resources.

A.  Occupational Exposure to Formaldehyde (OSHA Fact Sheet).

B.  Formaldehyde (EPA).

C.  Consumer Product Safety Commission (Formaldehyde).

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U.S. Department of the Interior, U.S. Geological Survey, Reston, VA, USA
Contact: APS, Office of Policy and Analysis
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Last modification: 28-Aug-2002@16:59 (kk)