Formaldehyde protection in gross anatomy laboratories

June 22, 1990

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

This is in further response to your letter of May 23, concerning the application of the Occupational Safety and Health Administration's (OSHA) formaldehyde standard, 29 CFR 1910.1048, to private medical school personnel (e.g., faculty, graduate teaching assistants) and morgue technicians working at gross anatomy laboratories.

OSHA relies on information submitted by the public, as well as staff research, when formulating standards. The standard-setting process is designed so that interested parties have ample opportunity to provide initial input, review regulatory proposals, and provide comments. The record of submissions for the formaldehyde standard is quite extensive and contains material on exposures in a variety of settings, including gross anatomy laboratories. Enclosed are two such submissions. One from Dr. Melvin First, an OSHA expert witness, primarily addresses methods of compliance and feasibility of controls. The other is a report of a Health Hazard Evaluation (HHE) or on-site investigation, conducted by the National Institute for Occupational Safety and Health (NIOSH) at the gross anatomy laboratory of the University of Colorado Medical School. This report describes the evaluation methods, the existing conditions, and the recommendations for improvements.

In your mention of the special needs of the technical staff, you have recognized that each function has different hazard potentials and different requirements and that it is reasonable to provide protection accordingly. The formaldehyde standard only requires personal protective equipment (PPE) which is appropriate to the hazards of the operation, based on conditions of use. The level of protection required is limited by the degree of hazard. Dermatitis was one of the conditions noted in the NIOSH HHE section on medical surveillance, and the wearing of gloves is recommended as an effective prevention measure. While rubber gloves are mentioned, butyl and nitrile are the most effective barriers against formaldehyde. A 0.3 mm thickness of these materials resists chemical breakthrough for over 8 hours, and thinner gloves might be adequate for your needs. The newer polyethylene laminate disposable gloves have been tested to provide over 4 hours of effective protection with a thickness of 0.08mm. These materials are also available as aprons and arm coverings. Aprons or laboratory coats made of polyethylene or similar material may also provide effective body splash protection for students and faculty, if a hazard potential exists. If there is no potential for eye splash, based on experience and evaluation of the potential exposure, then eye protection would not be required. If there is splash potential, chemical goggles may provide sufficient protection.

If there is the possibility that formaldehyde can be splashed in the eye or on the body, equipment suitable for flushing contaminated body parts must be provided. If quantities are small or spills are limited to a small area, a full shower may not be necessary. Once again, the hazards in embalming areas may require a greater degree of protection so that showers may be necessary in these areas but not throughout the laboratory.

After reviewing the information provided, if you still feel that the use of PPE is infeasible, then it would be advisable for you to meet with OSHA staff to discuss how employee protection can be achieved. David Smith, Director of Health Compliance Assistance can be reached at 523-8036. You may also want to contact NIOSH. Its Hazard Evaluations and Technical Assistance Branch can be reached at (513) 841-4428.

Sincerely,
Gerard F. Scannell
Assistant Secretary

Enclosures

[May 23 requester letter and copies of earlier correspondence reproduced on OSHA page; omitted here.]