| WISHA Regional Directive 91-4 |  | |
WRD 91-4
SUBJECT: Inspection and Citation Guidelines for Occupational Exposure to Formaldehyde
I. Purpose: This directive provides uniform inspection procedures and guidelines to be followed when conducting inspections and issuing citations for workers potentially exposed to formaldehyde.
II. Background: On October 6, 1988, WISHA amended the Formaldehyde Standard, WAC 296-62-07540 through WAC 296-62-07550, to be as-effective-as changes to the Federal Rule (29 CFR 1910.1048) as published in Federal Register, Volume 52, Number 233 and Federal Register, Volume 53, Number 41. The changes affected exposure limits, monitoring requirements, protective equipment and clothing needs, emergency procedures, employee training, labeling, and material safety data sheets required by the Hazard Communication Standard. The following guidelines and instructions will provide assistance for consistent interpretations and applications for users of the standards.
III. Application.
A. Occupational Exposure to Formaldehyde.
1. Formaldehyde Uses. Formaldehyde is a reactive chemical with many uses.
a. The major consumers of formaldehyde are the manufacturers of compressed wood products. Formaldehyde is consumed in resins that are used as glues in the production of particleboard, plywood, and fiberboard. These wood products in turn are used in the construction, furniture, and mobile home manufacturing industries.
b. The plastics industry is the second largest user of formaldehyde-based resins. Molding compounds containing melamine, phenolic, or acetyl resins are capable of releasing formaldehyde when subjected to heat and/or pressure in the molding process. The final product, however, contains little free formaldehyde and has little potential for depolymerization, so that potential exposure to formaldehyde form use of the plastic product is minimal. Typical of plastics made from formaldehyde-based resins are lawn and garden equipment, plumbing fixtures, melamine tableware, and electrical insulation parts.
c. Formaldehyde-releasing resins are used to add wrinkle-free and durable press characteristics to synthetic and natural-fiber textiles. These resins leave residual formaldehyde in the products which can result in exposure to formaldehyde in the apparel industry. A dimethyloldihdroxyethyleneurea (DMDHEU)-based resin system is most currently used.
d. Formaldehyde-bearing resins are used in the coating industry, primarily as modifiers in alkyd and acrylic coating systems. Urea-formaldehyde resins are used in clear coating for wood furniture, primer coats for automobiles, baked enamels for appliances, and can coatings. Melamine-formaldehyde resins are generally used where outdoor exposure or contact with detergents require improved chemical resistance. Melamine-formaldehyde resins also have some application where corrosion resistance is important.
e. Paper products may be treated with formaldehyde derivatives (e.g., melamine or urea-formaldehyde) to add a desired finish or wet-strength quality. Melamine resins can be inactivated by a high sulfate concentration, and this problem is overcome by addition of excess formaldehyde.
f. Formaldehyde is an important constituent of embalming and preserving fluids because it performs two essential functions-disinfection and preservation. In mortuaries, embalming fluids may be injected in concentrated forms to preserve the organs in the visceral and thoracic cavities. Arterial fluids are prepared by diluting the concentrate and are injected into the arterial system through a hose. Formaldehyde's properties as a tissue preservative also account for its use in anatomy, histology, and pathology laboratories.
g. Formaldehyde-based chemicals are used in textile waterproofing, as accelerators in the production of rubber products, and in photographic developing. Foundries use formaldehyde-based resins in molds in the production of ferrous and non-ferrous goods.
h. Formaldehyde is used in the production of industrial chemicals including pentaerythritol 1, 4-butenediol, and trimethyl-o-propane.
i. Some detergents, fertilizers, explosives, and abrasive products are also manufactured with formaldehyde. Because formaldehyde is an effective bactericide, it is contained in cosmetic products, shampoos, and hair sprays. It is used in the manufacture of some pharmaceutical products and germicides, and it is used to clean dialysis equipment.
j. Formaldehyde is sometimes used as a disinfectant in fish hatcheries.
2. Formaldehyde Exposure
a. Formaldehyde exposure can occur in three ways:
(1) Exposure to liquid or solid formaldehyde (paraformaldehyde) and the accompanying vapors;
(2) Exposure to formaldehyde during primary processing of formaldehyde resins and other chemicals manufactured from formaldehyde; and
(3) Exposure to formaldehyde released from products that contain formaldehyde-based resins.
b. Occupational exposures to formaldehyde occur during heat and/or pressure processing of products made from or including formaldehyde-bearing resins. Examples of such exposures include the pressing of wood products, extrusion or injection molding of plastics, heat-setting of pleats on apparel, and casting of molds in foundry processes.
c. Occupational exposures to formaldehyde occur when a finished products contains residual formaldehyde or when hydrolosis-that is, the chemical breakdown of formaldehyde-containing materials to produce formaldehyde gas prompted by warm and humid work environments-occurs. The EPA has described this phenomenon as "pseudoconsumptive use" of formaldehyde; i.e., chemical identity is changed but not irreversibly. Examples of "Pseudoconsumptive" uses are:(1) urea-formaldehyde resins in fiberboard, particleboard, plywood, laminates, urea-formaldehyde foams and insulation products, molding compounds, and protective coatings; (2) urea-formaldehyde concentrates used to produce time-release fertilizers; and (3) hexamethylenetetramine.
3. Operations. Specific operations that cause employee exposure to formaldehyde include:
a.
Formaldehyde transfer operations.
b. Reactor or vessel cleaning.
c. Fugitive emmission in chemical plants.
d. Exposure to articles that have been treated with
formaldehyde-based resins before curing.
e. Exposure to articles containing cured resins during
transit from curing operations to storage or further processing.
f. Exposure to stored articles containing cured
resins, and
g. The application of formaldehyde-based resins.
NOTE: Short-term exposures occur during batch operations such as mixing and during periodic cleaning and maintenance activities. Concentrated formaldehyde solutions (37 percent or greater) are often diluted for sale or use by chemical distributors or end-users, such as hospitals. In addition, short-term exposures occur in mortuaries and laboratories (anatomy, histology, pathology, environmental testing, and school biology).
B. Health Effects. Based on the best available evidence in the agency's record on formaldehyde, OSHA determined that formaldehyde is genotoxic, showing properties of both a cancer initiator and promoter. When inhaled, formaldehyde exposure has been associated with cancer of the lungs, nasopharynx and oropharynx, and nasal passages.
1. Formaldehyde is highly irritating to the upper respiratory tract and eyes. Concentrations as low as 0.5 to 2 ppm may irritate the eyes, nose, and throat of some individuals. Concentrations of 3 to 5 ppm cause tearing of the eyes, and the severity of the effects become intolerable to some persons. Concentrations of 10 to 20 ppm cause difficulty in breathing, burning of the nose and throat, coughing, and heavy tearing of the eyes. Concentrations over 22 ppm can cause severe respiratory tract injury that can lead to pulmonary edema and pneumonitis. A concentration of 100 ppm is regarded as immediately dangerous to life or health (IDLH) for formaldehyde.
2. Some persons have developed asthma or bronchitis following exposure to formaldehyde; usually a single exposure to high concentrations of formaldehyde as the result of an accidental spill appeared responsible for the onset of symptoms.
3. Formalin (37 percent formaldehyde) is a skin irritant and sensitizer. Formalin solutions splashed in the eye have resulted in blindness. Less concentrated solutions can also injure the eyes and skin. The severity of the effect depends on the concentration of formaldehyde in solution and whether the affected tissue is flushed with water immediately after the accidental splash. Contact with formalin causes a white discoloration, pain, drying, cracking, and scaling of the skin. Prolonged and repeated contact can cause numbness and a hardening or "tanning" of the skin.
4. Previously exposed persons may react to exposure with an allergic eczematous dermatitis or hives. Employees in industries where there is direct skin contact with formaldehyde-releasing resins, (e.g., textiles) tend to have a higher than normal incidence of dermatitis. When patch tested, these persons sometimes show sensitization to formaldehyde.
C. Clarification of the Formaldehyde Standard (WAC 296-62-07540)
1. Subsection (1), Scope and Application.
a. Formaldehyde refers solely to the chemical defined by Chemical Abstracts Services Registry (CAS) Number 50-00-0. This chemical is formaldehyde gas which, per se, is not available commercially. Most exposures are to formaldehyde gas which is emitted at various concentrations from numerous products made from formaldehyde-bearing resins. Various mixtures of formaldehyde, water, and alcohol, (sometimes referred to as "formalin") are also included in CAS #50-00-0.
b. The Formaldehyde Standard applies to all occupational exposures to formaldehyde. This includes general industry, and by cross-reference, maritime and construction. The only exceptions to this coverage occur where the Occupational Safety and Health Act does not give WISHA jurisdiction over employees. The scope of Formaldehyde Standard is not affected in most cases by the Hazardous Chemicals in Laboratories Standard. Hazardous Chemicals in Laboratories, chapter 296-828 WAC, specifically does not apply to formaldehyde used in histology, pathology, and human or animal anatomy laboratories; however, if formaldehyde is used in other types of laboratories which are covered by Hazardous Chemicals in Laboratories, the employer needs to comply with Chapter 296-828 WAC.
2. Subsection (3), Permissible Exposure Limits (PEL). Where there are measurable concentrations of other regulated contaminants which affect the same body systems as formaldehyde, citations should be issued per the WISHA Operations Manual, Chapter XIII-II-B. This manual cites WAC 296-62-07507 of the Air Contaminants Standard for use in cases where thre are potential additive and synergistic effects. The Air Contaminants Standard, WAC 296-62-07507(1), contains a formula which has the effect of proportionally reducing the PEL of each regulated toxic element of the multiple exposure. As an example, if a woodshop worker has an exposure to wood dust measured at 2.5 mg/m3 TWA, which represents 50 percent of the PEL of 5 mg/m3, the PEL for formaldehyde (1 ppm TWA) would be reduced by 50 percent, resulting in a PEL for a concurrent formaldehyde exposure of 0.5 ppm. WAC 296-62-07507(1) requires employers to meet these adjusted PELs where there is an exposure to a mixture of air contaminants regulated by Table 1. The body system primarily affected by formaldehyde is the respiratory system (upper and lower). The immune system may also be affected (Formaldehyde is a sensitizer which provokes an IgE (immunoglobulin mediated response). Appendix E of this directive contains guidance for calculating the adjusted PELs and SAEs (sampling and analytical errors). The adjusted PELs should apply only to enforcement of Subsection (3), Permissible Exposure Limit and (6), Methods of compliance. The Short-term Exposure Limit (STEL) and action level (AL) should not be adjusted for mixtures for compliance evaluations.
3. Subsection (4), Exposure Monitoring. Subsection (4) of the Formaldehyde Standard requires employers to determine their employees' exposure to formaldehyde if any mixture or solution present in the workplace contains 0.1 percent or more of formaldehyde, or if materials capable of releasing formaldehyde into the workplace air result in employees being exposed to formaldehyde at concentrations reaching or exceeding 0.1 ppm. The inspector should verify the employee exposure via bulk or air samples.
a. Objective Data. The exposure determination must consist of actual measurements unless the employer can produce objective data to document that no employee will be exposed to formaldehyde at concentrations exceeding the 0.5 ppm Time Weighted Average (TWA) action level (AL), or the 2 ppm STEL under foreseeable conditions of use. Industry-wide studies or generic exposure estimates may be a source of objective data; however, the use of such data must accurately characterize actual employee exposures. For exposures less than the AL or STEL, area samples may also be used as the basis for exposure determinations, if they represent those exposures.
b. Medical Complaints. Regardless of employee exposure level, if there are employee health complaints, the employer is required to take action to determine employee exposure.
c. Exception. If mixtures or solutions composed of 0.1 percent or less of formaldehyde are used, employee exposure is below 0.1 ppm, and there are no employee health complaints then an employer should not be cited for not monitoring. (See WAC 296-62-07540(4)(a)(ii)(A).)
d. Repeat Monitoring. If there is a change in production, equipment, process, personnel, or control measures, which may result in a new or additional exposure to formaldehyde, the initial monitoring shall be repeated. For example, apparel manufacturers and other producers/users of formaldehyde resin finished fabrics may need to repeat initial determinations with different fabric lots.
e. Sampling Methods. As long as the method selected for sampling and analysis meets the criteria for precision and accuracy set out in the Formaldehyde Standard, the employer is free to choose from many methods available for monitoring exposure to formaldehyde.
(1) Among the methods available are the chromotrophic acid method which relies on use of a midget impinger, gas chromatographic methods which collect formaldehyde in a specially prepared tube, passive diffusion badges, and handheld monitors.
(2) Appendix A to this directive summarizes information submitted to the formaldehyde docket on passive and direct reading devices for the measurement of formaldehyde. Limitations, where known, are also given.
4. Subsection (8), Protective Equipment and Clothing. This section addresses the selection and maintenance of protective equipment and clothing, including aprons, goggles, face shields, and suits. The inspector should evaluate potential formaldehyde hazards and use professional judgment in enforcing the general requirements of WAC 296-24-07501 and WAC 296-24-078 which are incorporated into the Formaldehyde Standard by reference. Violations of these general requirements should be cited under WAC 296-62-07540(8). Some Personal Protective Equipment (PPE) requirements are specified by the Formaldehyde Standard, and violations of these requirements should be cited under WAC 296-62-07540(8)(a).
a. Solutions containing greater than one percent formaldehyde are damaging to the skin and severely damaging to the eyes. Consequently, protective equipment adequate to prevent contact with such solutions must be provided to employees, and the equipment must be kept in good repair and free of formaldehyde contamination.
b. Some solids that release formaldehyde and solutions that contain less than one percent formaldehyde can also pose a hazard to employees. Subsection (8)(a) requires the employer to provide protective clothing or equipment, as needed, in accordance with the general standards for protective equipment and clothing WAC 296-24-07501 and WAC 296-24-078 to prevent contact with irritating or sensitizing materials.
c. Formaldehyde gas poses little hazard for dermal contact, although there are a few reports in the literature that indicate sensitization from high airborne concentrations. At the IDLH concentration, the standard requires whole body protection, essentially equivalent to Level A protection as referenced in WAC 296-62-3170, Appendix B (7)(a), to prevent potential sensitization.
d. Butyl and nitrile glove materials provide the greatest permeation protection. Greater thicknesses of other materials (natural rubber, PVC, polyethlyene) may be suitable for shorter immersion periods, but gloves may have to be changed more frequently due to degradation. All these materials are generally suitable for splash protection. Appendix B to this instruction summarizes the permeation data available for formaldehyde. Barrier creams are not regarded as effective protection for formaldehyde, since there is no data demonstrating their efficiency.
5. Subsection (9), Hygiene Protection
a. Emergency Showers. Because of the severe dermal effects that can occur when employees have skin contact with concentrated solutions of formaldehyde and because of the relative irreversibility of dermal sensitization to formaldehyde, the employer is required to provide conveniently located quick drench showers for employees who become splashed with solutions of 1 percent or greater formaldehyde as the result of equipment failure, improper work practices, or other emergencies. Whether or not the employee is wearing protective clothing does not affect the need for quick drench showers since the employee must be able to remove PPE splashed with a formaldehyde solution.
b. Eye Wash Facilities. Liquid formaldehyde can also cause severe damage to the eyes. Thus, the standard required employers to provide appropriate eye wash facilities within the immediate work area for emergency use by any employee whose eyes are splashed with the solutions containing 0.1 percent or more of formaldehyde.
c. The degree of sophistication of the emergency shower and/or eyewash station varies with the size of the potential splash. The use of portable units or hand-held fixtures should be carefully evaluated. Such use should be limited to small spills (generally less than 8 oz.), provided that all possible affected body parts can be flushed continuously for 15 minutes. (For this reason, bottle-type eyewashes are not acceptable.) Appendix C of this directive contains specific (nonmandatory) evaluation criteria for emergency showers and eyewashes.
6. Subsection (11), Emergencies. Subsection (11) ensures that the employer will prepare for any situation where equipment failure, spill or rupture of containers, or failure of control equipment would result in an uncontrolled release of formaldehyde that could result in injury or loss of life. If such circumstances could occur in an accident, the employer must establish procedures for evacuation and access to emergency medical care, obtain needed equipment for evacuation and access to emergency medical care, obtain needed equipment for evacuation and reentry into the area, and establish procedures for equipment repair, spill, cleanup, decontamination, and waste disposal. Subsection (11) violations should be grouped with any applicable violations under WAC 296-62-300. The threshold quantity for formaldehyde for evaluation of catastrophic potential is 500 lbs.
a. There is not a specific exposure level that triggers the emergency provisions. When determining if there is a need to provide for emergencies, the employer should consider whether employees' lives or health could be jeopardized in the worst reasonable predictable accident (i.e., the worst outcome of any possible scenario) unless employees are promptly evacuated from the area.
b. A 30-minute exposure to 100 ppm is potentially fatal, an pulmonary edema has been seen after exposures of 50 ppm. These levels can be generated by relatively small spills (a pint or less), even in ventilated areas.
7. Subsection (12), Medical Surveillance
A. The provisions of subsection (12) establish an approach to medical surveillance based on an employee's exposure potential.
(1) All persons who are required to wear respirators as the result of their formaldehyde exposure must fill out a medical disease questionnaire, such as the optional form contained in Appendix D to the Formaldehyde Standard, on an annual basis. (Note: The employer is required to administer the questionnaire, a process which is required to be under the supervision of a licensed physician, and involves assisting the employee as necessary to complete the questionnaire.) These persons must then be offered a physical examination and a pulmonary function test.
(2) All persons who are exposed to formaldehyde at concentrations between the action level and the 1 ppm TWA limit (but not over the STEL) must be given the opportunity to participate in a medical surveillance program on an annual basis by filling out a medical disease questionnaire. If an employee exposed between the action level and the 1 ppm TWA limit is showing signs and symptoms that may be formaldehyde-related, the employer must administer to the employee a medical disease questionnaire without delay. If the physician determines on the basis of the medical disease questionnaire, that it is necessary to examine the employee, the employee would then be sent to the physician for further examination.
(3) If exposures are less than 0.5 ppm but the employee is showing signs and symptoms that may be formaldehyde-related, the employee must be evaluated via a medical disease questionnaire, and further surveillance would be conducted on the basis of the physician's determination, as it is for concentrations between 0.5 and 1 ppm.
b. Subsection (12)(c)(ii) requires the physician to make a determination, based on evaluation of the medical disease questionnaire, as to whether additional medical surveillance specified in subsection (12)(d), i.e., a medical examination, is necessary to ensure the employee is not being placed at increased risk of material impairment of health from exposure to formaldehyde. In some cases, the physician will require additional information to reach a determination about the employee's health, the determination made in subsection (12)(c)(ii) must be provided to the employer in writing, and a copy given to the employee within 15 days of its receipt by the employer.
c. Emergencies pose a very different situation from routine surveillance. If the employer has determined that an emergency situation could occur, then there must be a prior arrangement with a physician or hospital to ensure that any employee acutely exposed to formaldehyde in an emergency receives prompt medical intervention, as required by subsection (11). The emergency plan must also specify what information should be given to emergency care providers, per the requirements of subsection (12)(f), and how it is to be transmitted.
8. Subsection (13), Hazard Communication. WRD 90-2 issued an administrative stay of subsections (13)(a)(I) through (13)(d)(1) of the Formaldehyde Standard.
a. In the interim, WISHA will continue to enforce the Hazard Communication Standard (HCS) with respect to formaldehyde.
b. Subsection (13)(a) was not stayed. It reemphasizes that hazard communication covers formaldehyde exposures occurring in the manufacture and use of wood products. When applicable, this paragraph shall be cited along with appropriate violations under the HCS.
9. Subsection (14), Employee Information and Training
a. All employees exposed to formaldehyde at concentrations at or above 0.1 ppm or to solutions containing greater than 0.1 percent or more of formaldehyde must receive initial training upon hire.
b. All employees exposed at or above the action level or the STEL must be trained annually.
c. The administrative stay on subsection (13), Hazard Communication, does not affect the status of the training requirements under (14).
(1) Training for formaldehyde conducted after April 4, 1988, must cover all applicable requirements contained in subsection (14)(d) of the Formaldehyde Standard.
(2) Employees previously trained on formaldehyde's hazards under the HCS (WAC 296-62-054) must be retrained in order to cover additional information contained in the Formaldehyde Standard.
(3) Initial training for employees not previously covered by WAC 296-62-07540 must be provided as soon as possible once the employer has identified that they are exposed to formaldehyde. A reasonable amount of time, no more than three months, should be given to the employer to permit identification of affected employees and to obtain training materials.
(4) The training provisions of subsection (14) are to be cited rather than the HCS information and training requirements if the employee is covered by (14).
d. Appendix A to the Formaldehyde Standard provides general information which is appropriate for a training program. This outline would need to be supplemented by plant specific information. In addition, the OSHA hazard recognition training program on formaldehyde may be of assistance to employers who need to train employees. The program includes information on the standard but it is being revised to more fully reflect the changes. (See OSHA Fact Sheet 89-27.)
10. Supplemental Information. Appendix D to this directive summarizes the Formaldehyde Standard triggering events.
D. Inspection Procedures. The following procedures shall be followed in addition to the guidance in the WISHA Operations Manual, OSHA Technical Manual (used as WISHA supplements), and IMIS Forms Manual.
1. Authorization to Review Limited Medical Information. Appropriately qualified compliance personnel are authorized to review medical disease questionnaires and medical opinions mandated by the Formaldehyde Standard when the limitations and procedures in OSHA Instructions CPL 2-2.30 and CPL 2-2.33 are followed.
a. Qualified compliance personnel are industrial hygienists or professionals with training in medical disciplines.
b. This authorization is pursuant to WAC 296-62-05209(3).
2. Recording in the IMIS. In addition to current instructions for completing the OSHA-1, as found in the IMIS Manual, the following shall be recorded in Item 42 for all inspections where employees exposure to formaldehyde is investigated for compliance with WAC 296-62-07540 and/or WAC 296-62-054.
|
Type |
ID | Value |
| N | 16 | Form |
3. Contested Cases. For contested cases of WAC 296-62-07540 and/or 296-62-054 involving formaldehyde which the industrial hygiene supervisor supports as strong cases, the industrial hygiene supervisor sends a brief memorandum summarizing the fact tot he industrial health program manager. After the information is reviewed, the Assistant Director may notify the Attorney Generals Office for recommendation on the case.
IV. Action: OSHA Instruction CPL 2-2.52 dated November 20, 1990, was used to develop this directive. The directive is ALAEA as the OSHA Instruction. This directive will serve as a guideline to inspectors when interpreting and applying exposures, violations and citations relating to formaldehyde.
V. Effective Date: This directive will be effective as of March 29, 1991, and will remain in effect until superseded or cancelled.
Nick Kirchoff, Assistant Director
Division of Industrial Safety and Health
Department of Labor and Industries
805 Plum Street Southeast
Olympia, Washington 98504
Telephone: (206) 753-6500
APPENDIX A
Passive and Direct Reading Devices1
COMPANY:
Air Quality Research (415-664-2097).
PRODUCT NAME: Passive Formaldehyde Kit (PF-20).
METHOD OF COLLECTION: Bisulfite coated glass fiber
filter.
DETECTION: Chromotropic acid.
SENSITIVITY: 0.1 ppm for 8 hours; .5 ppm for 15
minutes.
INTERFERENCES: Low humidity may cause adverse effects.
COMMENTS: Manufacturer claims the PF-20 monitor will
operate in a humidity range of 20 to 90% RH. Face velocities must be
greater than 25 cm/s during sampling.
COMPANY:
Assay Technology (415-424-9947).
PRODUCT NAME: Chem Chip T.
DETECTION: Colorimetric (Furpald, procedure).
SENSITIVITY: 0.1 ppm for 8 hours; 0.3 ppm for 15
minutes.
INTERFERENCES: Other aldehydes but less
interference with higher molecular weights.
COMMENTS: Good for the STEL according to
manufacturer's literature. Interferences of other aldehydes would cause
a problem in certain industries such as embalming where glutaraldehyde may
also be present.
COMPANY:
Crystal Diagnostic (617-933-4114).
PRODUCT NAME: AirScan T.
METHOD OF COLLECTION: Chemical reaction.
DETECTION: Visible.
SENSITIVITY: 0.1 ppm 8 hours; STEL (see
comments).
INTERFERENCES: Possibly humidity but not
definite.
COMMENTS: The company states their monitors are
sensitive enough for the STEL if the badge is allowed to develop for
several hours. The results on the humidity interference were inconclusive.
COMPANY:
CEA Instructment, Inc. (201-644-2300).
PRODUCT NAME: Model 555.
METHOD OF COLLECTION: Direct Reading Instrument.
DETECTION: Colorimetric (pararosaniline).
SENSITIVITY: 0.01 ppm continuous reading.
INTERFERENCES: Temperature can cause a problem;
other aldehydes.
COMMENTS: A review article states that there is a long
equilibration time and calibration must be done often. Interferences of
other aldehydes would cause a problem in certain industries such as
embalming where glutaraldehyde may also be present.
COMPANY:
CEA Instructment, Inc. (201-644-2300).
PRODUCT NAME: TGM 555.
METHOD OF COLLECTION: Direct Reading Instrument.
DETECTION: Colorimetric (pararosaniline).
SENSITIVITY: 0.003 ppm continuous reading.
INTERFERENCES: Temperature can cause a problem;
other aldehydes.
COMMENTS: Modification of Model 555. Need to
average the continuous readout for STEL. Interferences of other aldehydes
would cause a problem in certain industries such as embalming where
glutaraldehyde may also be present.
COMPANY:
Dosimeter Corporation (513-489-8100).
PRODUCT NAME: Model F-3.
METHOD OF COLLECTION: Cellulose sponge containing
a sorbent.
DETECTION: Visual with a comparator badge.
SENSITIVITY: 0.03 ppm for 4 hours.
INTERFERENCES: None listed.
COMMENTS: Manufacturer's stated sensitivity
would make it adequate for STEL.
COMPANY:
DuPont.
PRODUCT NAME: Pro-Tek C-60 T.
METHOD OF COLLECTION: Modified 1% bisulfite.
DETECTION: Colorimetric (Chromotropic acid).
SENSITIVITY: 0.12 ppm for 8 hours; 1 ppm for 15
minutes.
INTERFERENCES: Phenol, ethanol and other alcohols
but in concentrations 8 times and 15 times, respectively.
COMMENTS: Not good for STEL. The interferences of
phenol and ethanol may cause problems in certain industries such as
plywood manufacturing.
COMPANY:
Envirotech Services, Inc. (608-643-4755).
PRODUCT NAME: ETS Dosimeter
T.METHOD OF COLLECTION: Organic acid on
polycarbonate sponge.
DETECTION: Colorimetric (Purpald procedure).
SENSITIVITY: 0.1 ppm 8 hours.
INTERFERENCES: Other aldehydes.
COMMENTS: Not good for STEL. Intreferences or
other aldehydes which would cause a problem in certain industries such as
embalming where glutaraldehyde may also be present.
COMPANY:
Foxboro Analytical (203-853-1616).
PRODUCT NAME: Miran-1A.
METHOD OF COLLECTION: Direct Reading Instrument.
DETECTION: Infrared Spectrophotometer.
SENSITIVITY: 1 ppm continuous reading.
INTERFERENCES: Any compound which has an
absorbance at 3.58 micrometers (C-1a stretch). Possibly any aliphatic
hydrocarbon may interfere.
COMMENTS: Need to average the continuous readout for STEL or
TWA.
COMPANY:
MDA Scientific, Inc.
PRODUCT NAME: Lion Formaldemeter.
METHOD OF COLLECTION: Direct Reading Instrument.
DETECTION: Electrochemical.
SENSITIVITY: 0.3 ppm.
INTERFERENCES: Compounds that are easily oxidized
such as methanol. Phenol, ethanol and formic acid.
COMMENTS: Not useable for STEL due to the short
sampling time (approximately 20 seconds) and the time delay for the
electrochemical cell to return to zero would prevent rapid sequential
measurements.
COMPANY:
Sensidyne (813-530-3602).
PRODUCT NAME: 91L.
METHOD OF COLLECTION: Visible color indication.
SENSITIVITY: 0.2-5 ppm.
INTERFERENCES: Aldehydes, acid gases and ketones.
COMMENTS: The tube has the sensitivity for the STEL but
taking a continuous 15-minute sample would be difficult. The number of
interferences may lead to a problem.
COMPANY:
3M (612-733-8029).
PRODUCT NAME: 3721 T.
METHOD OF COLLECTION: Bisulfite impregnated pad.
DETECTION: Colorimetric (Chromotrophic acid).
SENSITIVITY: 0.1 ppm for eight hours.
INTERFERENCES: Manufacturer claims phenol is not
an interference since the monitor has a low collection efficiency for
phenol.
COMMENTS: Not good for the STEL. Sampling for longer than 16
hours in low humidity may make it unusable.
COMPANY:
Kem Medical (800-553-0330).
PRODUCT NAME: 8510 Vapor-Tank.
METHOD OF COLLECTION: Moistened chemical pad.
DETECTION: Colorimetric (Chromotropic acid).
SENSITIVITY: 0.02 ppm (8 hours); 0.64 ppm (15
minutes).
INTERFERENCES: None listed but colorimetric
methods usually have some interferences.
COMMENTS: Manufacturer's material states that
humidity should not be a problem but if it does cause a problem then the
exposure would be underestimated. They do state that 20% RH did not cause
a problem, however, that RH is probably at room temperature.
COMPANY:
Air Technology Labs, Inc. (209-435-3545).
PRODUCT NAME: Passive Bubbler.
METHOD OF COLLECTION: 3-methyl-2benzothiazolinone
hydrazone hydrochloride (MBTH) solution.
DETECTION: Colorimetric.
SENSITIVITY: 0.2 ppm for 8 hours. 0.8 ppm for 15
minutes.
INTERFERENCES: Other aliphatic aldehydes.
COMMENTS: Device is a passive liquid sampler that
is independent of humidity effects.
1This is a summary of information from the formaldehyde docket on passive and direct reading devices. It is not a comprehensive list of all available devices. For further information contact the OSHA Salt Lake City Laboratory (FTS 588-4270).
APPENDIX B
Summary of Published Permeation Data
| THICKNESS RATE
|
GENERIC
MATERIAL COMMENTS |
BREAKTHROUGH RATE |
STEADY STATE |
|
| (minutes) | (ug/cm2/min) | |||
| .28 - .60 | Nitrile | >
360 to >1260 |
||
| .23 | Viton | > 960 | ||
| Chemrel | > 480 | Suit Material | ||
| .08 | Silver Shield | > 360 | Glove only | |
| .43 | Butyl | > 240 to > 960 | > 240 = mixture | |
| PE/Tyvek | > 360 to > 480 | |||
| .07 | PE/EVOH/PE | > 240 | 35C, Swedish | |
| Teflon | > 180 | |||
| .05 | CPE | > 180 | ||
| .38 - .74 | NEOPRENE | 120 to > 480 | < 90 to < 900 | |
| .16 - .46 | Natural Rubber | 4 to > 480 | 10 to 900 | |
| .60 | Viton/neoprene | > 60 | ||
| Neo + Nat Rub | 35 | < 600 | ||
| Nitrile - PVC30 | 30 | < 9 | ||
| .50 | PVA | 6 to > 240 | Degrades, no water BkTh for mixture | |
| .15 - .51 | PVC | 4 to > 480 | < 10 to < 900 | |
APPENDIX C
Nonmandatory
Evaluation Criteria for
Emergency Showers and Eyewashes
The criteria for acceptable eyewashes and quick drench showers should be taken from ANSI Z358.1-1981, which will be revised in the near future. The National Safety Council Data Sheet I-686-Rev. 86 contains comparable criteria, but not identical specifications. Generally, the main criteria for judging acceptability are:
(1) Initiation: One hand, one action. Once initiated, flow continues, leaving both hands free.
(2) Location: 15 seconds, 25 feet travel, maximum (for highly concentrated solutions, 10 seconds, 10 feet maximum). Eyewashes positioned 34" - 39" high, showers approximately 82" high, with 67" high activation (maximum), positioned 23" (maximum) off center from shower head. Location must be clearly marked, well lighted, and easily accessible, i.e., no obstacles, doorways, or turns.
(3) Water quality: Potable, temperature (60-100 degrees F, ideally 90-95 degrees F). Pressure (eyewash 30 psi at supply line, shower 30 psi), amount (eyewash 3 gallons/minute for 15 minutes minimum, shower 30 gallons/minute for 15 minutes minimum), maintenance (float-away covers or means to prevent contamination; flush units weekly for a minimum of 3 minutes; bump test eyewashes daily, showers weekly; full flow testing monthly).
(4) Training: Routine drills advisable. As a minimum, employees must know the location and proper use of eyewashes and showers (i.e., initiate, remove contaminated clothing, flush full 15 minutes, etc.).
APPENDIX D
Formaldehyde Standard Triggering Events
Part I. Airborn Levels
A. Below AL and STEL Btu Above .1 ppm
1. Exposure Determination.
2. Recordkeeping.
3. Training (initial).
4. Medical Surveillance for Signs and Symptoms.B. Above AL or STEL
1. Initial Monitoring.
2. Periodic Monitoring.a. At or Above AL .Every 6 months.
b. At or Above STEL . Once a year.3. Medical Surveillance.
4. Training (annual).
5. Applicable provisions in A. above.C. Above TWA or STEL
1. Regulated Areas.
2. Methods of Compliance.
3. Respiratory Protection.
4. Applicable provisions are in A., B., and C. above.D. Greater than 100 ppm
1. Full Body Protection.
2. Applicable provisions are in A., B., and C above.
Part II. Eye or Skin Contact
A. Greater than or Equal to 1% Formaldehyde Solution
1. PPE.
2. Hygiene Protection.a. Change Rooms.
b. Quick Drench Showers.B. Greater than or Equal to .1% Formaldehyde Solution
1. Eye Wash Facilities.
2. PPE.C. Irritating or Sensitizing Formaldehyde Materials
1. PPE.
2. Change Rooms.
Part III. Liquid or Gas.
A. Housekeeping
1. Leak Detection.
2. Preventative Maintenance.
3. Spill Clean-up.
Part IV. Possibility of Emergency
A. Emergencies.
B. Respiratory Protection.
C. Medical Surveillance.
D. Training.
APPENDIX E
Considering SAEs for Exposure to Mixtures
Often an employee is simultaneously exposed to a variety of chemical substances in the workplace. Synergistic toxic effects on a target organ are common for such exposures in many construction and manufacturing processes. This type of exposure can also occur when impurities are present in single chemical operations.
New permissible exposure limits (PELs) for mixtures, such as the resent welding fume standard (5mg/m3), addresses the complex problem of synergistic exposures and their health effects. In addition, WAC 296-62-07507 contains a computational approach to assess exposure to a mixture. This calculation should be used to protect worker health.
Whether using a single PEL or the mixture calculation, the sampling and analytical error (SAE) of the individual constituents must be considered before arriving at a final compliance decision. These SAEs can be pooled and weighed to give a control limit for the synergistic mixture. To illustrate this control limit, the following example using the mixture calculation is shown:
The mixture calculation is expressed as:
Em= C1/L1 + C2/L2 + ····· (Cn/Ln) (1)
Where:
Em = equivalent exposure for the mixture (Em should be #1 for compliance)
C = concentration of a particular substance
L = PEL
As an example, and exposure to three different byt synergistic substances:
| Material | Actual Concentration of Material 8-hr. Exposure (ppm) | 8-hr. TWA PEL (ppm) | SAE |
| Substance 1 | 500 | 1000 | 0.089 |
| Substance 2 | 80 | 200 | 0.11 |
| Substance 3 | 70 | 200 | 0.18 |
Using equation (1) above:
Em = 500/1000 + 80/200 + 70/200 = 1.25
Since Em > 1 overexposure appears to have occurred; however, SAE for each substance also needs to be considered:
Exposure ratio (for each substance) Yn = Cn/Ln
Ratio to total exposure R1 = Y1/Em, ····· Rn = Yn/Em
The SAEs (95% confidence) of the substances comprising the mixture can be pooled by:
RSt [R1)2 x (SAE1)2 + (R2)2 x (SAE2)2 + (Rn)2 x (SAEn)2)2]1/2
The mixture Control Limit (CL) is equivalent to: 1 + RSt
If Em < CL then overexposure has not been established at the 95% confidence level; further sampling may be necessary.
If Em > 1 and Em > CL then overexposure has occurred (95% confidence).
Using the mixture data above:
| Y1 = 500/1000, | Y2 = 80/200, | Y3 = 70/200 |
| Y1 = 0.5, | Y2 = 0.4, | Y3 = 0.35 |
| R1 = Y1/Em = 0.4, | R2 = 0.32 | R3 = 0.28 |
| RSt2 = (0.4)2 (0.089)2 + (0.32)2 (0.11)2 + (0.28)2 (0.18)2 | ||
| RSt = (RSt2)1/2 = 0.071 | ||
| CL = 1 + RSt = 1.071 | ||
| Em = 1.25 | ||
Therefore, Em > CL and an overexposed has occurred within 95% confidence limits.
This calculation is also
used when considering a PEL such as the one for total welding fumes. An
executable computer program is available which will calculate a control
limit for any synergistic mixture. The program will run on any IBM
compatible personal computer. For questions, contact Rick Cee or Mike
Shulsky from the OSHA Salt Lake City Laboratory.
