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OSHA 1910.1048

Formaldehyde scope and definitions

Subpart Z

50 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.1048(a), what workplaces does the formaldehyde standard cover?

The formaldehyde standard applies to all occupational exposures to formaldehyde, including formaldehyde gas, its solutions, and materials that release formaldehyde. This is stated in 1910.1048(a).

Under 1910.1048(b), how does OSHA define 'formaldehyde' for the standard?

Formaldehyde is defined as the chemical substance HCHO, Chemical Abstracts Service Registry No. 50-00-0. See the definition in 1910.1048(b).

Under 1910.1048(b), what is the 'action level' for formaldehyde and how is it measured?

The action level for formaldehyde is 0.5 parts per million (0.5 ppm) calculated as an 8-hour time-weighted average (TWA). This definition is in 1910.1048(b).

Under 1910.1048(c)(1), what is the 8-hour Permissible Exposure Limit (PEL) for formaldehyde?

The 8-hour TWA PEL for formaldehyde is 0.75 parts per million (0.75 ppm). See 1910.1048(c)(1).

Under 1910.1048(c)(2), what is the Short-Term Exposure Limit (STEL) for formaldehyde?

The STEL for formaldehyde is 2 parts per million (2 ppm) measured over a 15-minute period. See 1910.1048(c)(2).

Under 1910.1048(d)(1)(ii), when can an employer skip employee exposure monitoring using objective data?

An employer may skip monitoring if objective data document that the presence of formaldehyde or formaldehyde-releasing products cannot result in airborne concentrations at or above the action level or STEL under foreseeable conditions of use. See 1910.1048(d)(1)(ii).

Under 1910.1048(d)(1)(iii)-(iv), what does 'representative sampling' mean for formaldehyde monitoring?

Representative sampling means measurements must reflect an employee's full-shift or short-term exposure as appropriate, and you must take representative samples for each job classification in each work area for each shift unless objective data document equivalent exposures across shifts. See 1910.1048(d)(1)(iii) and 1910.1048(d)(1)(iv).

Under 1910.1048(d)(2), who must be included in initial monitoring for formaldehyde exposures?

The employer must identify all employees who may be exposed at or above the action level or the STEL and accurately determine the exposure of each employee so identified. See 1910.1048(d)(2).

Under 1910.1048(d)(2)(i), how should an employer design representative sampling instead of monitoring every employee?

If not measuring each employee, the employer must develop a representative sampling strategy and measure enough exposures within each job classification and shift to correctly characterize and not underestimate any employee's exposure within the exposure group. See 1910.1048(d)(2)(i).

Under 1910.1048(d)(2)(ii)-(iii), when must initial monitoring be repeated?

Initial monitoring must be repeated whenever there is a change in production, equipment, process, personnel, or controls that may result in new or additional exposure, and the employer must promptly monitor any employee who reports signs or symptoms associated with formaldehyde exposure. See 1910.1048(d)(2)(ii) and 1910.1048(d)(2)(iii).

Under 1910.1048(d)(3), how often must periodic monitoring be done when exposures are at or above the action level or STEL?

If initial monitoring shows exposures at or above the action level, repeat monitoring at least every 6 months; if exposures are at or above the STEL, repeat monitoring at least once a year under worst conditions. See 1910.1048(d)(3)(ii) and 1910.1048(d)(3)(iii).

Under 1910.1048(d)(4), when can an employer stop periodic monitoring for formaldehyde?

The employer may discontinue periodic monitoring if two consecutive sampling periods, taken at least 7 days apart, show employee exposure below both the action level and the STEL, with results statistically representative and consistent with the employer's knowledge of the job. See 1910.1048(d)(4).

Under 1910.1048(d)(5), what accuracy is required for formaldehyde monitoring?

Monitoring must be accurate at the 95 percent confidence level within ±25% for airborne concentrations at the TWA and STEL, and within ±35% for concentrations at the action level. See 1910.1048(d)(5).

Under 1910.1048(d)(6), how and when must employers notify employees of monitoring results?

The employer must notify each affected employee of monitoring results within 15 working days after receiving the results, either individually in writing or by posting the results in an accessible location; if exposure exceeds a PEL, the employer must also describe corrective actions being taken. See 1910.1048(d)(6).

Under 1910.1048(d)(7), what rights do employees or their representatives have to observe exposure monitoring and what must employers provide if observation requires PPE?

Affected employees or their designated representatives must be given an opportunity to observe any required monitoring. If observation requires entry into areas where protective clothing or equipment is required, the employer must provide and require the observer to use the necessary clothing and equipment and ensure compliance with other safety procedures. See 1910.1048(d)(7) and 1910.1048(d)(7)(ii).

Under 1910.1048(e)(1), what signage is required for regulated areas where formaldehyde exceeds the TWA or STEL?

Employers must post signs at all entrances to regulated areas with the legend: DANGER FORMALDEHYDE MAY CAUSE CANCER CAUSES SKIN, EYE, AND RESPIRATORY IRRITATION AUTHORIZED PERSONNEL ONLY. See 1910.1048(e)(1)(i).

Under 1910.1048(e)(1)(ii), what alternative sign was allowed before June 1, 2016?

Prior to June 1, 2016, employers could use the alternate legend: DANGER FORMALDEHYDE IRRITANT AND POTENTIAL CANCER HAZARD AUTHORIZED PERSONNEL ONLY. See 1910.1048(e)(1)(ii).

Under 1910.1048(e)(2)-(3), who may enter regulated areas and what must employers do at multiemployer worksites?

Access to regulated areas must be limited to authorized persons who have been trained to recognize formaldehyde hazards, and employers who establish regulated areas at multiemployer worksites must communicate access restrictions and locations to other employers at the site. See 1910.1048(e)(2) and 1910.1048(e)(3).

Under 1910.1048(f)(1)-(2), when must engineering and work-practice controls be used and when are respirators allowed?

Employers must use engineering and work-practice controls to reduce formaldehyde exposures to at or below the TWA and STEL; if feasible controls cannot achieve those limits, employers must apply feasible controls to the extent possible and supplement with respirators that meet the standard. See 1910.1048(f)(1) and 1910.1048(f)(2).

Under 1910.1048(g), what are the main respirator requirements and when must the employer provide them?

The employer must provide appropriate respirators and a respiratory protection program for employees who need respirators during periods necessary to install controls, for operations where controls are not feasible (e.g., maintenance, vessel cleaning), when controls are not yet sufficient to meet PELs, and for emergencies. See 1910.1048(g)(1) and 1910.1048(g)(2)(i).

Under 1910.1048(g)(2)(ii) and 1910.1048(g)(3), what are the cartridge replacement and respirator selection rules for formaldehyde?

When using air-purifying respirators with cartridges or canisters that lack end-of-service-life indicators (ESLIs), employers must replace cartridges per 1910.134(d)(3)(iii)(B)(1)-(2) or at the end of the workshift, whichever comes first; employers must select respirators listed in 1910.134(d)(3)(i)(A), equip full facepiece air-purifying respirators with canisters/cartridges approved for formaldehyde, and provide approved escape respirator options including SCBA or full facepiece respirator with an approved formaldehyde canister. See 1910.1048(g)(2)(ii) and 1910.1048(g)(3).

Under 1910.1048(g)(3)(ii)-(iii), when can a half-mask be used and what alternatives must be provided to employees who cannot use negative-pressure respirators?

An air-purifying half-mask respirator with a cartridge approved for formaldehyde may be substituted for a full facepiece respirator if the employer also provides effective gas-proof goggles. Employees who cannot use negative-pressure respirators must be provided powered air-purifying respirators that afford adequate protection against formaldehyde. See 1910.1048(g)(3)(ii) and 1910.1048(g)(3)(iii).

Under 1910.1048(h)(1)(i)-(iv), what personal protective clothing and equipment must employers provide for skin or eye contact with formaldehyde?

Employers must prevent all contact of the eyes and skin with liquids containing ≥1% formaldehyde by providing chemical protective clothing impervious to formaldehyde and using appropriate PPE such as goggles and face shields; prevent contact with irritating or sensitizing materials as needed; require goggles when a face shield is used and full-body protection for entry into areas above 100 ppm or for emergency reentry. See 1910.1048(h)(1)(i)-(iv).

Under 1910.1048(h)(2), how must employers maintain and store protective equipment and contaminated clothing?

Employers must clean or launder formaldehyde-contaminated protective clothing before reuse, and when ventilating contaminated items they must establish storage areas to minimize employee exposure; signs may be required for such storage areas. See 1910.1048(h)(2) and 1910.1048(h)(2)(ii)(A).

Under 1910.1048(d)(6) and (d)(7), what must an employer do if an employee's exposure results are above the PEL and observers watch monitoring?

If exposure exceeds a PEL, the employer must notify affected employees within 15 working days and provide a description of corrective actions; if observers enter areas requiring PPE to watch monitoring, the employer must supply and require appropriate protective clothing and ensure compliance with safety procedures. See 1910.1048(d)(6) and 1910.1048(d)(7)(ii).

Under 1910.1048(h)(2)(ii)(B), what exact wording must I put on labels for containers of formaldehyde-contaminated clothing and equipment?

The label must read: "DANGER FORMALDEHYDE-CONTAMINATED [CLOTHING] EQUIPMENT MAY CAUSE CANCER CAUSES SKIN, EYE, AND RESPIRATORY IRRITATION DO NOT BREATHE VAPOR DO NOT GET ON SKIN." This wording is required by 1910.1048(h)(2)(ii)(B) and labels must also be consistent with the Hazard Communication Standard 1910.1200.

Under 1910.1048(h)(2)(ii)(C), can employers use an older label legend and, if so, until when?

Yes — employers could use an alternate legend prior to June 1, 2016. Specifically, the older permitted legend was: "DANGER FORMALDEHYDE-CONTAMINATED [CLOTHING] EQUIPMENT AVOID INHALATION AND SKIN CONTACT." This allowance is described in 1910.1048(h)(2)(ii)(C).

Under 1910.1048(h)(2)(ii)(D), could employers include the alternate label text before June 1, 2015, for protective clothing and equipment?

Yes — prior to June 1, 2015 employers were allowed to use the shorter legend "DANGER FORMALDEHYDE-CONTAMINATED [CLOTHING] EQUIPMENT AVOID INHALATION AND SKIN CONTACT" on containers of protective clothing and equipment in lieu of the full labeling in (h)(2)(ii)(B). This is stated in 1910.1048(h)(2)(ii)(D).

Under 1910.1048(h)(2)(iii), who is allowed to remove formaldehyde-contaminated clothing or equipment from storage for cleaning or disposal?

Only persons trained to recognize the hazards of formaldehyde may remove contaminated clothing or equipment from storage for cleaning, laundering, or disposal. This requirement is in 1910.1048(h)(2)(iii).

Under 1910.1048(h)(2)(iv), can employees take home clothing or equipment contaminated with formaldehyde?

No — the employer must assure that no employee takes home equipment or clothing contaminated with formaldehyde. This prohibition is explicit in 1910.1048(h)(2)(iv).

Under 1910.1048(h)(2)(v) and (vi), who must pay for repair or replacement of contaminated protective clothing, and what must employers tell laundries or repair services?

The employer must repair or replace required protective clothing and equipment as necessary to assure its effectiveness, and must inform any person who launders, cleans, or repairs such items about formaldehyde's hazards and safe handling procedures. These obligations appear in 1910.1048(h)(2)(v) and 1910.1048(h)(2)(vi).

Under 1910.1048(i)(1), when must I provide change rooms for employees exposed to formaldehyde?

You must provide change rooms when employees are required to change from work clothing into protective clothing to prevent skin contact with formaldehyde. This hygiene-protection requirement is set out in 1910.1048(i)(1) and refers to the change-room provisions in 1910.141.

Under 1910.1048(i)(2), when are quick-drench showers required for formaldehyde exposure?

Quick-drench showers must be provided and used immediately when employees' skin may become splashed with solutions containing 1 percent or greater formaldehyde, for example from equipment failure or improper work practices. This requirement is in 1910.1048(i)(2).

Under 1910.1048(i)(3), when must eyewash facilities be provided for formaldehyde hazards?

Acceptable eyewash facilities must be provided within the immediate work area when there is any possibility that an employee's eyes may be splashed with solutions containing 0.1 percent or greater formaldehyde. This is specified in 1910.1048(i)(3).

Under 1910.1048(j), what housekeeping measures must employers take for operations that use formaldehyde liquids or gas?

Employers must conduct a program to detect leaks and spills, including regular visual inspections, perform preventative maintenance, contain and decontaminate spills, promptly repair leaks and clean spills with trained employees wearing suitable protective equipment, and place contaminated waste and debris in sealed, labeled containers. These duties are set out across 1910.1048(j) and its subsections including 1910.1048(j)(1), 1910.1048(j)(2), 1910.1048(j)(3), and 1910.1048(j)(4).

Under 1910.1048(j)(4) and (m), how must formaldehyde-contaminated waste from leaks or spills be prepared for disposal?

Formaldehyde-contaminated waste and debris from leaks or spills must be placed in sealed containers bearing labels warning of formaldehyde’s presence and hazards, with the labels meeting the labeling rules of paragraph (m). See 1910.1048(j)(4) and 1910.1048(m).

Under 1910.1048(l)(1)(i), who must be enrolled in a medical surveillance program for formaldehyde exposure?

Employers must institute medical surveillance for all employees exposed at or above the action level or exposed above the STEL (short-term exposure limit). This coverage requirement is stated in 1910.1048(l)(1)(i).

Under 1910.1048(l)(1)(ii), when must medical surveillance be made available for employees with signs or symptoms of formaldehyde overexposure or after emergencies?

Medical surveillance must be made available to employees who develop signs or symptoms of overexposure and to all employees exposed to formaldehyde in emergencies, and employers may rely on the fact that signs and symptoms are unlikely when airborne exposure is below 0.1 ppm and material concentrations are below 0.1 percent. See 1910.1048(l)(1)(ii).

Under 1910.1048(l)(3)(i) and (ii), what medical surveillance procedures must be done before assignment and annually?

Before assignment and annually thereafter, employers must provide a medical disease questionnaire (such as appendix D) and a physician must determine from that questionnaire whether a medical examination is necessary for employees not required to wear respirators. These medical-surveillance steps are in 1910.1048(l)(3)(i) and 1910.1048(l)(3)(ii).

Under 1910.1048(l)(4), what must be included in medical examinations for employees exposed to formaldehyde (including respirator wearers)?

Medical exams must include a physical exam emphasizing evidence of skin and respiratory irritation or sensitization, baseline and annual pulmonary function tests (FVC, FEV1, FEF) for respirator wearers, any other tests the physician deems necessary, and counseling about conditions aggravated by formaldehyde. See 1910.1048(l)(4)(i), 1910.1048(l)(4)(ii), and 1910.1048(l)(4)(iii).

Under 1910.1048(l)(5) and (l)(6), what must an employer provide to the physician when examining employees exposed to formaldehyde, including emergency exposures?

The employer must provide the physician a copy of the standard and appendices A, C, D, and E, a description of the employee's job duties and representative exposure level, information about personal protective equipment and respirators used, and prior medical exam results; in emergencies the employer must also provide a description of how the emergency occurred and the exposure received as soon as possible. See 1910.1048(l)(6)(i)-(vi) and the emergency-exposure requirement in 1910.1048(l)(5).

Under 1910.1048(l)(7) and (l)(7)(iii), what must the physician's written opinion include and when must the employer give it to the employee?

The physician's written opinion must state whether the employee has any medical condition placing them at increased risk from formaldehyde exposure, any recommended exposure limits or PPE changes, and that the employee was informed of conditions aggravated by exposure; the employer must provide a copy to the affected employee within 15 days of receiving it. See 1910.1048(l)(7)(i)-(iii).

Under 1910.1048(l)(8) and related paragraphs, when does medical removal apply for formaldehyde-related irritation or sensitization, and what thresholds affect presumptions about causation?

Medical removal provisions apply when an employee reports significant mucosal or upper-airway irritation, respiratory sensitization, dermal irritation, or dermal sensitization attributed to workplace formaldehyde exposure, but dermal removal does not apply if the product contains less than 0.05% formaldehyde and the physician will presume non-attribution if products contain less than 0.1% formaldehyde absent contrary evidence. These rules are in 1910.1048(l)(8), 1910.1048(l)(8)(ii)-(vi), and 1910.1048(l)(8)(v).

Under 1910.1048(m)(2)(i)-(iii), when must an employer label a material "May Cause Cancer" versus using a less specific label for formaldehyde-containing products?

Employers must use the label wording "May Cause Cancer" on products that can release formaldehyde at levels above 0.5 ppm; for products that release 0.1–0.5 ppm the label must at minimum identify that the product contains formaldehyde and provide the responsible party and where hazard information (SDS) is available.

  • The requirement to use the phrase "May Cause Cancer" for materials capable of releasing formaldehyde above 0.5 ppm is in 1910.1048(m)(2)(i).
  • For materials that release formaldehyde between 0.1 ppm and 0.5 ppm, labels must at least state the product contains formaldehyde, list the responsible party's name/address, and state that hazard information is available from the employer and SDSs per 1910.1048(m)(2)(ii).
  • Note: employers could, prior to June 1, 2015, use the phrase "Potential Cancer Hazard" in place of "May Cause Cancer" as allowed in 1910.1048(m)(2)(iii).

Under 1910.1048(m)(1)(iv) and (m)(1)(v), when can an employer rely on objective data instead of monitoring to show exposures are below 0.1 ppm?

An employer may rely on objective data to show employees are not exposed to formaldehyde at or above 0.1 ppm when that data demonstrates the extent of potential formaldehyde release under reasonably foreseeable conditions of use.

  • The scope for relying on objective data is set out in 1910.1048(m)(1)(iv).
  • The employer may base determinations of anticipated release levels on objective data (for example, reliable manufacturer test data, validated literature, or prior monitoring under comparable conditions) as described in 1910.1048(m)(1)(v).
  • If the employer relies on objective data to avoid monitoring, the employer must keep a record of the objective data relied upon per 1910.1048(o)(2).

Practical tips: document the data source, conditions it covers, why those conditions are reasonably foreseeable at your site, and how the data supports the <0.1 ppm conclusion.

Under 1910.1048(n)(2) and (n)(3), how often must training on formaldehyde be given and what topics must it cover?

Employers must train affected employees at initial assignment, whenever a new formaldehyde exposure is introduced, and at least annually; the training must cover the regulatory text, the SDS, medical surveillance, hazards, signs and symptoms, safe work practices, PPE, spill/emergency procedures, and engineering controls.

Under 1910.1048(l)(8)(vii)-(viii) and 1910.1048(l)(9), what must an employer do when an employee is medically removed because of formaldehyde exposure and what are the employee's rights to a second or third physician review?

When an employee is medically removed because of formaldehyde exposure the employer must maintain the employee's earnings, seniority and other benefits for up to six months (or until return or permanent removal is determined), arrange a follow-up medical exam within six months, may reduce benefits to the extent the employee receives other compensation, and must notify the employee of the right to seek a second physician review and follow the multiple physician review procedures if disagreements arise.

  • Maintenance of earnings/seniority/benefits and the six‑month follow-up exam requirement are in 1910.1048(l)(8)(vii) and the benefit-reduction rule is in 1910.1048(l)(8)(viii).
  • The employee may designate a second physician to review the initial physician's findings as described in 1910.1048(l)(9)(i), and the employer must promptly notify the employee of that right per 1910.1048(l)(9)(ii).
  • If the employer conditions its participation in paying for the review, the employee must inform the employer of intent and initiate making an appointment within 15 days as set out in 1910.1048(l)(9)(iii) and subparts (A) and (B) (1910.1048(l)(9)(iii)(A) and 1910.1048(l)(9)(iii)(B)).
  • If the two physicians disagree, they should try to resolve it; failing quick resolution, a third specialist is designated to review and decide as described in 1910.1048(l)(9)(iv)-(vi).

Practical point: document the removal, provide the required follow-up exam within six months, notify employees of second-opinion rights promptly, and follow the multi-physician review steps and timelines in the regulation.

Under 1910.1048(o)(1)-(3) and (o)(5), what specific exposure and medical surveillance records must an employer keep and for how long?

Employers must keep accurate exposure measurement records (including date, operation, sampling methods, sample results, protective devices used, and employee names/job classifications represented) and medical surveillance records (employee name, physician's written opinion, health complaints related to formaldehyde, and exam/test results); exposure records must be retained at least 30 years and medical records for the duration of employment plus 30 years.

  • Required elements of exposure records are listed in 1910.1048(o)(1)(i)-(vi), including date, operation, sampling methods and evidence of accuracy, number and duration of samples, protective devices worn, and names/classifications of employees represented.
  • Medical surveillance record elements are in 1910.1048(o)(3)(i)-(iv), including physician's written opinion and copies of medical examination results.
  • Retention periods are in 1910.1048(o)(5)(i)-(ii): exposure records at least 30 years; medical records for the duration of employment plus 30 years.
  • Employers must also make exposure and medical records available to employees, former employees, and representatives in accordance with 1910.1048(o)(6)(ii)-(iii) and 1910.1048(o)(6)(iii), which reference the employee access provisions of 1910.1020.

Under 1910.1048(o)(4) and (o)(4)(ii), what respirator fit testing records must an employer keep for employees required to use negative-pressure respirators?

Employers must keep fit testing records that include the test protocol used, the results of fit tests, the size and manufacturer of respirators available, and the date of the most recent fit test plus the names of tested employees and the respirator type/facepiece selected.

  • The requirement to maintain fit testing records is in 1910.1048(o)(4).
  • The specific record items are listed in 1910.1048(o)(4)(ii)(A)-(D): protocol copy, fit test results, respirator sizes/manufacturers, and most recent fit test date with employee names and facepiece selected.
  • Per 1910.1048(o)(5)(iii), respirator fit testing records must be kept until replaced by a more recent record.

Under 1910.1048(m)(1)(i) and 1910.1048(m)(1)(iii), are chemical manufacturers and employers required to follow the Hazard Communication Standard for formaldehyde and include it in their hazard communication program?

Yes. Chemical manufacturers, importers, distributors and employers must comply with all requirements of the Hazard Communication Standard for formaldehyde and must include formaldehyde in their hazard communication program, provide labels and SDSs, and train employees per the HCS and 1910.1048.

  • The requirement to comply with the Hazard Communication Standard is stated in 1910.1048(m)(1)(i).
  • Employers must include formaldehyde in their hazard communication program and ensure each employee has access to container labels and safety data sheets and is trained in accordance with the HCS and 1910.1048(n) as required by 1910.1048(m)(1)(iii).
  • Paragraph 1910.1048(m)(1)(iv) clarifies this applies to formaldehyde gas, mixtures/solutions >0.1% formaldehyde, and materials that can release formaldehyde at or above 0.1 ppm.