Formaldehyde controls in medical school anatomy laboratories

May 16, 1990

Douglas E. Kelly, Ph.D.
Associate Vice President for Biomedical Research
Association of American Medical Colleges
[Recipient address omitted]
Dear Dr. Kelly:

Thank you for your inquiry of April 2 concerning the application of the Occupational Safety and Health Administration (OSHA) formaldehyde standard to private medical school personnel (e.g., faculty, graduate teaching assistants, and morgue technicians) working at gross anatomy laboratories.

As you note, OSHA promulgated a standard for formaldehyde in December 1987. This standard addresses employee protection from the health risks associated with formaldehyde exposure. The main health effects are respiratory cancer, dermatitis, sensory irritation (eye, nose, throat) and sensitization. In addition to the inhalation hazard, solutions of formaldehyde (such as the formalin used as a tissue preservative) can damage skin and eye tissue immediately upon contact. For this reason the standard requires effective protective equipment to prevent skin and eye contact, as well as eyewashes and showers if there is the possibility of splashes to eyes and body. There is a wide selection of effective protective equipment available which will prevent skin and eye contact to formaldehyde while allowing for relative comfort and ease of work. Your staff should consult with a safety and health professional to find specific equipment which will meet work requirements and reduce the hazard. Handling and storage procedures might also be modified to eliminate or reduce splash hazards.

As part of the standard development process, OSHA identified the types of establishments using formaldehyde, the levels of exposure, and numbers of employees exposed. Comments and testimony were solicited from all affected groups, and based on this information, the Agency made a determination of whether compliance with all the provisions of the standard are feasible in each of the types of user establishments. Agency economists also projected the costs of compliance. The formaldehyde record contains a good deal of information about control of formaldehyde hazards in histology, pathology and anatomy laboratories, and the agency's conclusion is that control of these hazards is feasible, both technically and economically.

Industrial hygienists and other health and safety experts have indicated that formaldehyde exposures are greatly reduced when ventilation rates exceed 15 room changes per hour. In addition, work practices should be developed that control sources of formaldehyde such as elimination of open containers and utilization of laboratory hoods where work permits. Where dilution ventilation and other measures are not sufficient, downdraft anatomy tables or local exhaust ventilation may be necessary. The National Institute for Occupational Safety and Health (NIOSH) has developed some ventilation designs for embalming tables that may be appropriate for your laboratories. If the use of such controls is infeasible in a particular application, or while controls are being installed, use of respirators is permitted, provided the respiratory protection requirements of the standard (paragraph g) have been met.

Many institutions have instituted effective programs of hazard control, including exposure monitoring, employee training and use of appropriate protective equipment, and are in compliance with the requirements of the formaldehyde standard. It might be valuable to contact other medical schools to obtain information on means of employee protection and hazard control which have been found to be effective.

We hope this information is helpful.

Sincerely,

Gerard F. Scannell
Assistant Secretary

[See also 06/22/90 letter to Douglas E. Kelly.]

[Requester letter reproduced on OSHA page; omitted here.]