Monitoring, Exposure Assessments and Related Requirements
Monitoring and Exposure Assessments
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.
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.
Processes or occupational activities at Virginia Tech 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,
If all work using formaldehyde-containing materials is performed inside a chemical fume hood or using a snorkel or similar engineering control, it is presumed that exposures over 0.1 ppm will not occur unless there is a spill outside of these controls. Similarly, if all work is performed in a Class II A2, B or C1 biosafety cabinet that is connected to the building hazardous exhaust system, and where only small quantities are used, it is presumed that exposures over 0.1 ppm will not occur. Work with minute quantities where the exposures are of very short duration (for example, opening up a small container of formalin in which to place a piece of excised tissue) are also not an exposure concern. For assistance or to arrange monitoring for suspect work exposures, please contact EHS directly.
Employee Notification
Employee(s) will be notified in writing of the results of the assessment within 15 workdays or the results will be posted in an appropriate location accessible to all affected persons.
If the result is above the STEL, AL or PEL, the notification will include the actions that are being taken to reduce the exposure to below these limits.
Regulated Areas
The university will establish regulated areas where the concentration of airborne formaldehyde exceeds either the PEL or the STEL and post and maintain legible signs bearing the following information at all entrances or access ways:
Access to the regulated area shall be limited to authorized persons who have been trained to recognize the hazards of formaldehyde.
Medical Services
Medical surveillance will be provided by EHS 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. If respirators need to be worn by an employee, the employee must be medically cleared, fitted to the respirator and trained annually by EHS.
Hazard Communication
Each histology, pathology, and human or animal anatomy laboratory, and any workgroup using formaldehyde outside of other types of laboratories, must include formaldehyde in its hazard communication program. This includes proper labeling and having a Safety Data Sheet (SDS).