Formaldehyde labels on medical waste containers

September 13, 1993

Mr. Edward Krisiunas MT (ASCP),
CIC Infection Control Coordinator
Safe Way Disposal Systems
[Recipient address omitted]
Dear Mr. Krisiunas:

Thank you for your letter of May 19, requesting interpretation of the Occupational Safety and Health Administrations Formaldehyde Standard (29 CFR 1910.1048). We regret the delay in responding to your inquiry. In your letter you question whether the Formaldehyde Standard requires labeling of the outer containers containing sealed red bags of pathological waste, i.e. tissues and other body parts, that were soaked in Formalin.

OSHA does not regulate the outer shipping container of hazardous material. The hazard warning labeling requirement is only enforced and limited to the actual container holding the hazardous substance, i.e. bottle, bag, can, jar, etc. OSHA has no requirement for hazardous warning labels on the outer shipping container. If the shipping container itself is the actual container holding the hazardous substance then it would have to be labeled in accordance with the requirements of the Formaldehyde Standard.

OSHA's Formaldehyde standard requires employers to assure that a label is affixed to all containers of materials that meet the following requirements: Formaldehyde gas, all mixtures or solutions composed of greater than 0.1% formaldehyde, and materials capable of releasing formaldehyde into the air, under reasonably foreseeable conditions of use, at levels of 0.1 ppm to 0.5 ppm.

These labels shall identify that the product contains formaldehyde, list the name and address of the responsible party, and state that the physical and health hazard information is readily available from the employer and from MSDS. At levels above 0.5 ppm, the label shall include the words "Potential Cancer Hazard" and warn of all other hazards as defined in Appendices A and B of 29 CFR 1910.1200.

Enclosed for your reference are two pamphlets, "Exposure to Hazardous Chemicals in Laboratories" and "Occupational Exposure to Bloodborne Pathogens" which summarize other standards that may be relevant to your work operations

We hope this information is useful to you.

Sincerely,
Ruth E. McCully, Director
Office of Health Compliance Assistance

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