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OSHA 1926.1148

Formaldehyde requirements

Subpart Z

22 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1148, when does the formaldehyde standard apply on a construction site?

Yes. Under 1926.1148 the formaldehyde requirements apply to construction work that involves formaldehyde exposures and are identical to the requirements in 1910.1048. Employers must follow the 1926.1148 rule for any construction activities that create formaldehyde exposures (for example cutting, sanding, or installing materials that release formaldehyde).

Under 1926.1148, what exposure limits for formaldehyde must employers control?

Employers must control exposures to formaldehyde to meet the limits set in 1910.1048. The standard defines an Action Level (AL) of 0.5 ppm as an 8-hour TWA, a Permissible Exposure Limit (PEL) of 0.75 ppm as an 8-hour TWA, and a Short-Term Exposure Limit (STEL) of 2 ppm over 15 minutes.

  • Use engineering and work-practice controls first; if those cannot keep exposures at or below the PEL and STEL, provide respirators and other protections as required by the standard. See 1910.1048 for the full definitions and requirements.

Under 1926.1148, when must an employer perform exposure monitoring for formaldehyde?

Employers must begin monitoring when they have reason to believe that any employee may be exposed at or above the Action Level (0.5 ppm) or the STEL (2 ppm); they must also conduct initial monitoring to determine employee exposures and periodic follow-up monitoring as required by 1910.1048.

  • If monitoring shows exposures below the AL with adequate confidence, employers can reduce monitoring frequency per the schedules in 1910.1048.

Under 1926.1148, what methods can employers use to measure formaldehyde exposure?

Employers must use accurate, validated sampling and analytical methods to measure formaldehyde exposure as described in 1910.1048. Approved methods include recognized air-sampling techniques and laboratory analysis capable of determining time-weighted averages and 15-minute samples for STEL determination.

  • Document sampling procedures and results per the monitoring and recordkeeping requirements in 1910.1048.

Under 1926.1148, when must an employer establish a regulated area for formaldehyde?

Yes. Employers must establish a regulated area when airborne formaldehyde concentrations exceed the PEL, STEL, or the ceiling limits in 1910.1048. The regulated area must limit access to authorized personnel and use appropriate warning signs and controls.

  • See 1910.1048 for specific requirements on defining and marking regulated areas.

Under 1926.1148, what training must be provided to employees exposed to formaldehyde?

Employers must provide initial and annual refresher training to employees who are or may be exposed to formaldehyde at or above the Action Level, and to employees who work in regulated areas, per 1910.1048. Training must cover the health hazards of formaldehyde, exposure limits, protective measures (engineering controls, PPE, hygiene), and how to use equipment and read labels.

  • Document training content, dates, and attendees per the recordkeeping rules in 1910.1048.

Under 1926.1148, when is medical surveillance required for employees exposed to formaldehyde?

Employers must provide medical surveillance when an employee is exposed at or above the Action Level for 30 or more days per year, or is exposed above the STEL, or if the employee develops signs or symptoms of formaldehyde-related health effects, as required in 1910.1048.

  • Medical surveillance includes medical exams and tests specified in 1910.1048 and must be provided at no cost and during paid time.

Under 1926.1148, what information must employers give to the medical professional performing formaldehyde exams?

Employers must provide the healthcare professional with specific information as required by 1910.1048, including a description of the employee's duties as they relate to exposure, the employee’s anticipated exposure level, a description of personal protective equipment used, and relevant medical and work history (including previous exposures).

  • This information enables an appropriate medical evaluation and is specified in 1910.1048.

Under 1926.1148, can employers use respirators instead of engineering controls to comply with exposure limits?

No. Employers must use feasible engineering and work-practice controls to reduce formaldehyde exposures to the lowest feasible level; where such controls cannot reduce exposures to or below the PEL and STEL, respirators are allowed as supplemental protection as specified in 1910.1048.

  • Respirator selection and program requirements must comply with 29 CFR 1910.134 (Respiratory Protection) as referenced by 1910.1048.

Under 1926.1148, what warning signs and labels are required where formaldehyde exposures occur?

Employers must post warning signs at the boundaries of regulated areas and label containers and pipes that hold formaldehyde in accordance with the labeling requirements in 1910.1048. Signs must include the word 'DANGER' when appropriate and specify the hazard and required protective measures.

  • See 1910.1048 for specific wording, format, and placement rules.

Under 1926.1148, how long must formaldehyde exposure and medical records be kept?

Employers must maintain exposure monitoring records and medical records for the durations specified in 1910.1048. Typically, exposure-monitoring records must be kept for at least 30 years and medical records must be maintained for the duration required by the medical recordkeeping provisions in 1910.1048.

  • Check 1910.1048 for exact retention periods and record content requirements.

Under 1926.1148, what actions must employers take when monitoring shows formaldehyde levels above the STEL?

Employers must immediately take steps to reduce exposures when monitoring shows concentrations above the STEL in 1910.1048, including implementing or strengthening engineering controls, work practices, and—if necessary—providing appropriate respiratory protection until controls reduce exposures to compliant levels.

  • The employer must also inform affected employees, establish or maintain regulated areas, and provide medical surveillance as required by 1910.1048.

Under 1926.1148, are labeling and safety data sheet (SDS) requirements for formaldehyde governed by another OSHA standard?

Yes. In addition to labeling requirements in the formaldehyde standard itself, employers must follow the Hazard Communication Standard for SDS and labeling obligations, as incorporated and cross-referenced in 1910.1048 and the general 1910 requirements.

  • Ensure employees have access to SDSs and training on hazards and labels as part of your hazard communication program.

Under 1926.1148, how should employers handle employees who develop symptoms of formaldehyde exposure?

Employers must remove employees who develop signs or symptoms of formaldehyde-related health effects from exposure until a physician or licensed healthcare professional determines it is safe to return, as required by 1910.1048. The employer must also provide medical evaluation and follow-up as part of the medical surveillance program.

  • See 1910.1048 for specific removal, evaluation, and return-to-work requirements.

Under 1926.1148, what housekeeping and decontamination measures must be taken when working with formaldehyde-containing materials?

Employers must implement housekeeping and decontamination procedures to prevent unnecessary exposure and contamination as described in 1910.1048. This includes cleaning surfaces, disposing of contaminated materials safely, and providing facilities for washing and changing clothes when needed.

  • Follow the engineering controls, work-practice, and PPE guidance in 1910.1048 to minimize contamination.

Under 1926.1148, how must employers protect workers on multi-employer construction sites where other contractors create formaldehyde exposures?

Employers on multi-employer construction sites must coordinate with other employers to ensure exposures are controlled and that affected workers are protected when formaldehyde exposures are present, consistent with the duties described in 1910.1048 and general OSHA multi-employer enforcement principles. Each employer must make sure its employees receive required monitoring, training, and medical surveillance if exposures meet the thresholds.

  • Communicate about hazards, regulated areas, and protective measures among contractors to avoid gaps in protection.

Under 1926.1148, are employers required to provide medical removal protection or job placement for workers affected by formaldehyde exposure?

Employers must follow the medical removal and return-to-work provisions in 1910.1048, which require removal of employees from exposure if medically necessary and provide for appropriate follow-up and job placement consistent with medical advice. Employers must not allow a worker to return until cleared by a physician or licensed healthcare professional as specified in 1910.1048.

  • Check the specific requirements and timing details in 1910.1048.

Under 1926.1148, what recordkeeping must employers keep of employee exposure measurements?

Employers must keep accurate records of all employee exposure measurements in accordance with the monitoring and recordkeeping provisions in 1910.1048. Records must include sampling dates, methods, results, sampling and analytical procedures, and identities of the employees represented.

  • Maintain these records for the retention periods specified in 1910.1048 and make them available to employees or their representatives as required.

Under 1926.1148, are fit tests and respirator medical evaluations required when respirators are used for formaldehyde?

Yes. When respirators are required to protect employees from formaldehyde exposures, employers must implement a respiratory protection program that includes medical evaluations and fit testing as required by 29 CFR 1910.134 and as referenced in 1910.1048.

  • Ensure the respirators selected are appropriate for formaldehyde (e.g., cartridges or supplied-air) and that all program elements in 29 CFR 1910.134 are met.

Under 1926.1148, what specific steps must be taken before assigning an employee to a job with potential formaldehyde exposure?

Employers must evaluate the job for potential formaldehyde exposure, perform initial monitoring when needed, provide hazard communication and training, ensure appropriate engineering controls and PPE, and enroll the employee in medical surveillance if exposures meet the thresholds—all as required in 1910.1048.

  • Also ensure any required respirator medical evaluation and fit testing per 29 CFR 1910.134 are completed before assignment.

Under 1926.1148, how should employers respond to employee requests for formaldehyde exposure information or records?

Employers must provide employees or their representatives access to exposure monitoring data, medical records, and training records as required by 1910.1048. Requests should be handled promptly, and records provided according to the access and confidentiality provisions in the standard.

  • Keep copies of what was provided and document requests and responses per recordkeeping practices in 1910.1048.

Under 1926.1148, are there special requirements for emergency procedures involving formaldehyde releases on a construction site?

Yes. Employers must have emergency procedures for spills or accidental releases of formaldehyde that cover evacuation, medical care, decontamination, and cleanup, following the emergency response and medical surveillance provisions in 1910.1048. Employers should also coordinate with local emergency responders and ensure employees are trained in those procedures.

  • If respirators or other PPE are required during emergency response, follow the requirements in 29 CFR 1910.134.