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FORMALDEHYDE EXPOSURE CONTROL PLAN
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1.0 PURPOSE and APPLICABILITY
1.1 It is the policy of the University of Pennsylvania in coordination with the Office of Environmental Health and Radiation Safety to provide the University community with a safe and healthful environment. This policy is designed to minimize employee and student exposures to formaldehyde. 1.2 This policy applies to all University employees and students who may come in contact with formaldehyde- producing materials. 1.3 This policy does not apply to empoyees of the University of Pennylvania Health System who are covered by their own policies. back to top 2.0 DEFINITIONS and SCOPE 2.1 Formaldehyde - The chemical substance HCHO. Chemical Abracts Service Registry No. 50-00-0. 2.2 Formaldehyde Exposure Assessment (EA) - A quantitative determination of employee exposure to formaldehyde. Includes full shift personal samples that are representative of the monitored employee's regular, daily exposure to formaldehyde and fifteen minute short term exposure limit samples during tasks that are believed to resullt in the highest exposures. 2.3 Designated Area - A location within the laboratory where acutely toxic mutagenic, carcinogenic, or teratogenic materials are handled and stored. The areas should be demarcated with designated area caution tape of yellow tape with the words designated area written upon it. 2.4 OSHA Action Level (Al) - Under the US Department of Labor, Occupational Safety and Health Administration (OSHA) Occupatonal Exposure to Formaldehyde Standard 29 CFR 1910.1048 is defined as an exposure to an airborne, concentration of 0.50 parts per million (ppm) formaldehyde as an eight-hour time-weighed average (TWA). 2.5 OSHA Permissible Exposure Limit (PEL) - Under the US Department of Labor, Occupational Safety and Health Administration (OSHA) Occupational Exposure to Formaldehyde Standard 29 CFR 1910.1048 is defined as an exposure to an airborne concentration of 0.75 parts per million (ppm) formaldehyde as an eight-hour time-weighted average (TWA). 2.6 OSHA Short Term Exposure Limit (STEL) - Under the US Department of Labor, Occupational Safety and Health Administration (OSHA) Occupational Exposure to Formaldehyde Standard 29 CFR 1910.1048 is defined as an exposure to an airborne concentration of formaldehyde of 2.00 parts per million (ppm) over a fifteen minute duration. 2.7 Regulated Area - Any area where the concentration of airborne formaldehyde exceeds either the OSHA PEL or the STEL. back to top 3.0 ROLES and RESPONSIBILITIES 3.1 The Office of Environmental Health and Radiation Safety (EHRS) is responsible for: identifying at-risk job tasks, conducting formaldehyde exposure assessments, exposure monitoring, designing/evaluating engineering controls and safe work practices, defining regulated areas, conducting respirator fit testing, waste chemical disposal, training, and record keeping. 3.2 The Hospital of the University of Pennsylvania (HUP) Department of Occupational Medicine (OM) is responsible for all aspects of the medical surveillance program. 3.3 Supervisors are responsible for requesting formaldehyde exposure assessments for employees and notifying EHRS of unusual conditions or changes in work practices that would make formaldehyde exposure assessments non-representative. Supervisors are also responsible for: providing personal protective equipment at no cost to the employee, enrolling employees exposed to formaldehyde above the OSHA AL or STEL into a medical surveillance program, scheduling and ensuring employee attendance at annual EHRS Laboratory Safety Training and ensuring formaldehyde producing chemicals are properly labeled, stored in a “Designated Area” and that the laboratory room sign has a “Designated Area” sticker affixed to it. 3.4 Employees (for purposes of this document faculty, staff and students working in a laboratory) are responsible for participating in annual EHRS Laboratory Safety Training and the medical surveillance program if applicable. Employees are also responsible for: using assigned personal protective equipment, using prescribed engineering controls and administrative work practices, and notifying supervisors of unusual conditions or changes in work practices that would make EHRS formaldehyde exposure assessments as being non-representative. back to top 4.0 PROCEDURES 4.1 Written Formaldehyde Exposure Control Plan The Formaldehyde Exposure Control Plan outlines management practices, procedures and controls implemented by EHRS to minimize formaldehyde exposures to University employees and students. 4.2 Determination of Employee Formaldehyde Exposure EHRS will perform formaldehyde exposure assessments on all tasks having the potential to expose employees to levels of formaldehyde above the OSHA AL or STEL. The assessments shall include air monitoring and observation of work practices and engineering controls typically used for each task. EHRS shall provide the employee and supervisor with a written copy of the sampling results and findings within 15 working days of the assessment. The report will describe any required changes in work practices or engineering controls based upon EHRS observation of the task and also notify the employee of the frequency of follow-up sampling if applicable. 4.3 Waste Disposal EHRS coordinates waste disposal of formaldehyde producing materials. 4.4 Training EHRS, as part of its annual Laboratory Safety Training, shall discuss the Formaldehyde Exposure Control Plan, a Formaldehyde Material Safety Data Sheet (MSDS), and job tasks that are likely to result in exposure to formaldehyde above the OSHA Action Level. Employees will be informed of formaldehyde related services offered through EHRS. 4.5 Record Keeping EHRS maintains all documents relating to formaldehyde exposure including formaldehyde exposure assessments, air sampling data, respirator fit testing documentation and waste disposal manifests. HUP OM maintains medical records relating to the medical surveillance program. All records are kept indefinitely. back to top 5.0 KEY REFERENCES OSHA Formaldehyde Standard back to top |
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