Triazine study as formaldehyde objective data

March 22, 1995

Haward J. Cohen, Ph.D, CIH
University of New Haven
[Recipient address omitted]
Dear Dr. Cohen:

Thank you for your letter of December 28, 1994, addressed to Thomas Galassi of my staff concerning clarification of the agency's position on the application of your Triazine Joint Venture (JV) study to the Formaldehyde Standard (29 CFR 1910.1048). This letter serves as a response to your letter and a follow up to my December 1, 1994 letter and the September 30, 1994 meeting between representatives of the Independent Lubricating Manufacturing Association (ILMA) and the Occupational Safety and Health Administration (OSHA). In your recent letter you specifically requested a written response to clarify issues related to the JV study and its use as objective data under the Formaldehyde Standard.

Given the extensive communications between the interested parties, we feel it would be useful to recount the pertinent activities. The following is a brief description of the OSHA's participation in the review of the JV study. On July 19, 1994, Mr. Ike Tripp of the ILMA, sent a letter to OSHA requesting evaluation of your Joint Venture study. A meeting was held at OSHA's National Office on September 30, 1994, with yourself, members of the ILMA, and Dr. Edward Stein and Thomas Galassi of OSHA. Following a coordinated review by various branches of OSHA, we sent a letter to Mr. Tripp on December 1, 1994, that summarized our review of the JV study. Based on that review it appeared to us that it demonstrated formaldehyde release from the biocide "Triazine" in excess of 0.1 ppm (8-hour time weighted average), and we stated that in our letter. You have provided additional information to the agency in your December 28, 1994, letter and you stated that: "It would be my opinion that the use of concentrated Triazine, as specified in the study, will not result in detectable employee exposures to formaldehyde and that such exposures would be below 0.1 ppm as an eight-hour time weighted average."

OSHA's policy on this issue is that the determination of the presence and extent of any associated hazard is always the responsibility of the chemical manufacturer or importer of the formaldehyde product. This evaluation must assess the hazards associated with actual or potential worker exposures, including all routes of entry, that may occur under reasonably foreseeable conditions. In terms of the Formaldehyde Standard, it is the responsibility of the manufacturer and/or importer to establish what the level of formaldehyde release is (i.e., greater than 1%) and label, train and develop MSDS accordingly.

Therefore, the course of action described in your letter is consistent with the provisions of the Formaldehyde Standard. However, OSHA compliance personnel may at their discretion during an inspection evaluate the "Triazine" containing cutting fluids for formaldehyde hazards at individual worksites.

In response to the misuse of the term "ceiling" in our letter, the 0.1 ppm level specified in paragraph 29 CFR 1910.1048(m) of the formaldehyde standard is an eight hour time weighted average and not a ceiling level as we indicated. Given its meaning in the OSHA regulations, we regret the use of the word "ceiling" within the context of that Paragraph.

We hope this response meets your needs.

Sincerely,

John B. Miles, Jr., Director
Directorate of Compliance Programs

Enclosure

[Requester correspondence and earlier OSHA letters reproduced on OSHA page; omitted here.]

[Corrected 12/6/2024]