Formaldehyde Safety in Funeral Homes

by Mark Harrison

What Every Funeral Home Needs to Know About Formaldehyde Safety in Funeral Homes

Formaldehyde is a colorless, strong-smelling gas often found in aqueous (water- based) solutions. Commonly used as a preservative in medical laboratories and mortuaries, formaldehyde is also found in many products and chemicals. Every funeral home that uses Formaldehyde must:

  1. Test for exposure levels annually

  2. Take an necessary corrective action

  3. Label dangerous chemicals correctly

  4. Develop a Written Compliance Plan

  5. Training employees on formaldehyde safety annually

  6. Maintain and store Safety Data Sheets (SDS) correctly

The OSHA formaldehyde standard (29CFR1910.1048)

OSHA Formaldehyde Regulations

The OSHA formaldehyde standard (29CFR1910.1048), describes the requirements for controlling worker exposures to formaldehyde. Some of the requirements include:

  1.  Engineering and work practice controls  Protective equipment and clothing

  2.  Use of warning signs and labels

  3.  Air monitoring

  4.  Respiratory protection

  5.  Worker medical surveillance  Hazard communication

  6.  Training

OSHA Standard 1910.1048 (Formaldehyde) Overview

OSHA Standard 1910.1048(e)(1)(i) states that "The employer shall establish regulated areas where the concentration of airborne formaldehyde exceeds either the TWA or the STEL and post all entrances and access ways with signs bearing the following legend"


DANGER

FORMALDEHYDE

MAY CAUSE CANCER

CAUSES SKIN, EYE, AND RESPIRATORY IRRITATION

AUTHORIZED PERSONNEL ONLY

You can order signs from Certified Safety Training and learn more about the OSHA Standard 1910.1048 Formaldehyde at OSHA.gov

Time-weighted Average (TWA) and a Short-term Exposure Limit (STEL)

The OSHA Formaldehyde standard (29 CFR 1910.1048) and equivalent regulations in states with OSHA-approved state plans protects workers exposed to formaldehyde and apply to all occupa- tional exposures to formaldehyde from formalde- hyde gas, its solutions, and materials that release formaldehyde.

• The permissible exposure limit (PEL) for formaldehyde in the workplace is 0.75 parts formaldehyde per million parts of air (0.75 ppm) measured as an 8-hour time-weighted average (TWA).

• The standard includes a second PEL in the form of a short-term exposure limit (STEL) of 2 ppm which is the maximum exposure allowed dur- ing a 15-minute period.

• The action level – which is the standard’s trig- ger for increased industrial hygiene monitoring and initiation of worker medical surveillance – is 0.5 ppm when calculated as an 8-hour TWA.

Embalming Room Ventilation 

The best position for supplied air is above the head of the worker, coming down, and exhausting through the floor or near the floor. The next best option is for supplied air to come from the head of the embalming table (adding a fan may increase efficiency) and the exhaust to be at the foot of the table. Ventilation requirements for funeral home preparation rooms are not specifically addressed in current existing guidelines. However, the National Mechanical Code of the Building Officials and Code Administrators (BOCA) and the Heating, Ventilation, and Air-Conditioning Handbook of the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) specify ventilation criteria for autopsy rooms. These criteria for autopsy rooms can serve as useful guidelines for effectively ventilating funeral home preparation rooms.

BOCA requires a minimum of 12 air changes per hour for autopsy rooms. The BOCA Code also requires that the air shall be exhausted to the outdoors, at an approved location on the exterior of the building. ASHRAE recommends a minimum of 12 air changes per hour be supplied to autopsy rooms, and that at least two of the air changes per hour be outdoor air. ASHRAE also specifies that the room be negatively pressurized in relation to adjacent areas. The New Jersey Funeral Directors Association recommends, as an accepted industry practice, 10-15 air changes per hour for preparation rooms. A source of makeup air should also be provided in preparation rooms to prevent excessive negative pressurization and to improve air mixing within the room.

It is likely that a qualified HVAC contractor could correct these ventilation problems without a great deal of expense, and it is recommended that modifications be implemented to keep your exposures to formaldehyde as low as possible. A general notion of the ventilation system recommended is given in the diagram below, taken from a design for embalming tables from the National Institute for Occupational Safety and Health, NIOSH.

Regardless of what specifications you use for your ventilation system, it is very important that the air flow is designed so that any vapors are pulled away from the employees’ breathing zone. Therefore, having adequate exhaust air capacity below the work surface is critical to reducing exposures to formaldehyde. If modifications are made to the ventilation system within the preparation room, ensure that ventilation testing is conducted to ensure that adequate air velocity and direction is maintained when the system is operating.

OSHA vs. National Institute for Occupational Safety and Health (NIOSH) Formaldehyde Standards

Scenario: A set of air quality reports was obtained by your employer after testing three separate areas of a new modular building. The air quality tests were conducted in response to building occupants' complaints of symptoms consistent with formaldehyde exposure. The building air was tested for formaldehyde, acetaldehyde, acetone, and total volatile organic compounds (VOCs). The reports revealed that while the air quality measurements for formaldehyde were within OSHA's permissible exposure limit (PEL), they were above the recommended exposure limits of NIOSH and other agencies listed in the report of the air testing company.

Question 1: Why does OSHA's formaldehyde permissible exposure limit differ from the exposure limits of these other agencies?

Response: NIOSH is a research agency for occupational safety and health that publishes recommended exposure limits (RELs). The NIOSH RELs are not for enforcement purposes. OSHA's PELs are legal limits that are enforceable in workplaces covered under the Occupational Safety and Health Act of 1970. OSHA promulgated the PEL in its health standard for formaldehyde, 29 CFR 1910.1048, through a public rulemaking process that included a systematic review of occupational exposure data, epidemiology and animal studies, as well as considerations of engineering and work practice control measures that are economically and technologically feasible. The formaldehyde PEL was established in a final rule in 1992 (57 Fed. Reg. 22290, May 27, 1992) and has not been updated since then. At this time, a revision to the formaldehyde standard is not on OSHA's regulatory agenda.

You may be interested in a similar study of building air quality that was recently conducted by investigators at NIOSH and published this year on their public website. In this study*, NIOSH investigators collected samples for formaldehyde, VOCs, and other air contaminants, and they included a detailed discussion of the interpretation of the sample results. You may also be interested in a recent NIOSH report* published after an investigation of formaldehyde exposures to workers in a hair salon, wherein NIOSH provided a detailed discussion of their REL for formaldehyde and its proper interpretation on page 3 of the report. We have enclosed copies of these two NIOSH reports for your information.

Question 2: How should a worker decide to return to employment where known carcinogens exist at levels where the allowable limit is in question?

Response: The question as to whether you should return to work should be discussed with your employer and your physician. If you feel you are being exposed to serious safety or health hazards at your place of employment, you may file a complaint at www.osha.gov or you may contact the local OSHA office directly at:

Learn more about OSHA's Formaldehyde PEL compared to NIOSH's Formaldehyde REL at OSHA.gov

Formaldehyde exposure and ergonomic hazards in the embalming/funeral home industry.

OSHA's standard for occupational exposure to formaldehyde, 29 CFR 1910.1048, applies to formaldehyde exposures employees receive due to embalming conducted by funeral homes, as well as to all other occupational exposures to formaldehyde. This regulation requires the employer to provide engineering controls to reduce and maintain employee exposures to formaldehyde to below the permissible exposure limit of 0.75 parts per million (ppm) as an 8-hour time weighted average exposure. In addition, the rule requires the employer to ensure that no employee is exposed to an airborne concentration of formaldehyde exceeding 2ppm as a 15-minute short-term exposure limit (STEL). The standard also obligates the employer to monitor employee exposures and provide adequate personal protective equipment to assist in the protection of employees from formaldehyde exposures during work operations. In addition, employers must provide employee information and training regarding the potential hazards associated with formaldehyde exposures. Learn more about formaldehyde exposure and ergonomic hazards in the funeral home industry at OSHA.gov.
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