Posted: July 27, 2012
An OSHA Local Emphasis Program (LEP) to reduce workplace exposure to formaldehyde in SIC Code 7261 industries, funeral service and crematories, went into effect October 1, 2010. The LEP focused on OSHA Region IV, which includes the states of Georgia, North Carolina, South Carolina, Tennessee, Alabama, Mississippi and Florida. Unless it is extended by OSHA, it is scheduled for completion on October 1, 2012.
The genesis of the LEP was OSHA's finding that formaldehyde is a genotoxic, and its association with cancers of the lung, nasopharynx and oropharynx and nasal passages. At the time the LEP was established, OSHA stated, as an example, that 18 to 21.1 percent of funeral homes in the state of Georgia exceeded OSHA formaldehyde limits and that another 52 percent did not complete the required sampling or did not sample per OSHA requirements for formaldehyde exposure on both STEL and PEL level.
The LEP inspections were based on a compilation of employers in the 7261 SIC Code by the Atlanta-West OSHA Office and specifically included funeral establishments with fewer than 10 employees. If, at the time of the inspection of the funeral home, the employer was determined to use formaldehyde products, the OSHA compliance officer was to establish a time to return to the facility and perform both STEL and TWA sampling. The compliance officer was also directed that operations that utilized formaldehyde be evaluated to ensure safe flammable liquid handling/storage practices and for possible chemical incompatibility, and reaction to oxidizers, alkalis, acids, phenols, and urea. The OSHA safety and health protocols instituted at the time of the beginning of the LEP emphasized that safety precautions would include adequate ventilation, eye protection, body protection and gloves made of nitrile, neoprene, natural rubber or PVC.
There is no indication that OSHA has determined whether it will extend this LEP, nor has an initial summary of the program results been released. The final results of this program, will, no doubt, be contained in a memorandum and will help shape nationally OSHA's future enforcement in this area as well as contribute to its consideration of revising and possibly reducing allowable formaldehyde exposure levels.
NFDA urges its members, if they have not already done so, to complete the required sampling for formaldehyde to confirm that the formaldehyde levels in the preparation room are within the allowable OSHA limits of .75 parts per million for an 8 hour time weighted average and 2 parts per million for a short term exposure limit. Relatively inexpensive test kits for formaldehyde sampling are available through preparation chemical suppliers. To further reduce exposure levels to formaldehyde in the preparation room, NFDA members are also urged to follow the NFDA Formaldehyde Best Management Practices and review the NFDA Prep Room Ventilation Study.
Measures to reduce formaldehyde levels, in the preparation room atmosphere, include improvement in ventilation by measures such as lowering the preparation room's exhaust vent to below the breathing zone, insuring that all exhaust vents are unblocked, the use of formaldehyde containing products strictly by the manufacturer's instructions, the substitution of formaldehyde containing preparation products with reduced or formaldehyde free products wherever possible, and simple measures such as keeping the lid on the embalming machine, immediately cleaning up any spills, the use of drain tubes and covering the flush sinks.
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