Effective Date: 15-March Table of Contents

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1 Versin: 3 Page: 1 f 9 Table f Cntents 1.0 Intrductin Purpse Scpe Definitins Respnsibilities... 2 Envirnmental Health and Safety Office (EHSO)... 2 Campus Services... 3 Principle Investigatrs, Directrs, Supervisrs and Managers... 3 Emplyee Health Services... 3 Emplyees and Students... 3 Cntractrs Training Requirements Recrdkeeping Requirements Prgram Evaluatin Prcedures Expsure Mnitring Regulated Areas Respiratry Prtectin Persnal Prtective Equipment (PPE) Hygiene Prtectin Inspectins Preventive Maintenance Frmaldehyde Spills Medical Surveillance Hazard Cmmunicatin References List f Assciated Dcuments... 9

2 Versin: 3 Page: 2 f Intrductin 1.1 Purpse The purpse f this prgram is t prvide guidance in the prtectin f all emplyees frm elevated expsure t frmaldehyde as prescribed in the Occupatinal Safety and Health Administratin s (OSHA s) Frmaldehyde Standard 29 CFR Scpe This prgram is inclusive f Emry University emplyees, including faculty, staff, students, cntractrs, and ther peple wh wrk with r in clse prximity t regulated frmaldehyde areas. 1.3 Definitins Dermal Sensitizatin. The prcess f the skin becming sensitive r hypersensitive t a cmpund. Frced Expiratry Flw (FEF). The flw f air frm the lungs during measurement f frced vital capacity. Frced Expiratry Vlume (FEV1). The maximum vlume f air that can be expired frm the lungs in a specific time interval when starting frm maximum inspiratin. Frced Vital Capacity (FVC). The vlume f air measured with subject exhaling with maximum speed and effrt. Pulmnary Functin Test. Test that measure hw well the lungs take in and release air and hw well they mve gases such as xygen frm the atmsphere int the bdy s circulatin. Respiratry Sensitizatin. The prcess f the lungs becming sensitive r hypersensitive t a cmpund. Sensitizatin. The prcess f ne becming sensitive r hypersensitive t a cmpund. 1.4 Respnsibilities Envirnmental Health and Safety Office (EHSO) As the administrative department fr the Frmaldehyde Prgram, EHSO is respnsible fr: Develpment, implementatin, and administratin f the frmaldehyde prgram. Cnducting peridic frmaldehyde mnitring in areas where expsure t frmaldehyde is in excess f the 0.5 parts f frmaldehyde per millin parts f air (ppm) 8-hur actin level r the 2.0 ppm 15-minute Shrt Term Expsure Limit (STEL) established by OSHA. Infrming Emplyee Health Services (EHS) f emplyees wh need t be included in the medical surveillance fr frmaldehyde and prviding EHS with relevant dcumentatin f expsure as described in Sectin 6.7 f this prgram.

3 Versin: 3 Page: 3 f 9 Selectin f apprpriate respiratry and ther persnal prtective equipment (PPE) necessary fr wrk with frmaldehyde. Develpment and implementatin f inspectin prcedures t detect frmaldehyde leaks. Develpment and implementatin f emergency prcedures in the event f an emergency. Develpment and implementatin f the Frmaldehyde Training Curse. Establishment f regulated areas where frmaldehyde cncentratins are in excess f the OSHA Actin Level r STEL. Campus Services Campus Services is respnsible fr perfrming preventive maintenance (PM) n all ventilatin equipment. Principle Investigatrs, Directrs, Supervisrs and Managers The principal investigatrs, directrs, supervisrs, and managers have primary respnsibility fr the fllwing: Management and enfrcement f the Frmaldehyde Prgram in their areas; Infrming emplyees f the results f industrial hygiene mnitring within fifteen days f receipt f the results frm EHSO; and Ensuring that all cntractrs, visitrs, and students in their areas cmply with the Frmaldehyde Prgram requirements. Emplyee Health Services Emplyee Health Services (EHS) is respnsible fr cnducting medical surveillance fr emplyees included in Sectin 6.1 f this prgram. Emplyees and Students All emplyees and students are respnsible fr cmplying with the rules and guidelines set frth by this prgram. Cntractrs All cntractrs are respnsible fr cmplying with the rules and guidelines set frth by this prgram. 1.5 Training Requirements All emplyees wrking in areas where expsure t frmaldehyde is in excess f 0.1 ppm are required t receive frmaldehyde training. Frmaldehyde training is cnducted at the time f initial assignment, whenever a new expsure t frmaldehyde is intrduced int the wrk area, and annually thereafter. Frmaldehyde training includes the fllwing: A discussin f the cntents f the frmaldehyde standard and the SDS; The purpse and descriptin f the medical surveillance prgram required by this prgram; A descriptin f the ptential health hazards assciated with expsure t frmaldehyde; A descriptin f the signs and symptms f expsure t frmaldehyde;

4 Versin: 3 Page: 4 f 9 Instructins t immediately reprt the develpment f any adverse signs and symptms that the emplyee suspects are attributable t frmaldehyde expsure. Descriptin f peratins in the wrk area where frmaldehyde is present and an explanatin f the safe wrk practices apprpriate fr limiting expsure t frmaldehyde in each jb; The purpse fr, prper use f, and limitatins f persnal prtective clthing and equipment; Instructins fr the handling f spills, emergencies, and clean-up prcedures; An explanatin f the imprtance f engineering and wrk-practice cntrls fr emplyee prtectin and any necessary instructin in the use f these cntrls; and A review f emergency respnse prcedures including specific duties r assignments f each emplyee in the event f an emergency. 1.6 Recrdkeeping Requirements Recrds pertaining t frmaldehyde will be retained as fllws: Industrial hygiene expsure mnitring recrds will be retained by EHSO indefinitely. Where EHSO has determined that mnitring is nt necessary, a recrd f the bjective data used is retained by EHSO indefinitely. Medical surveillance recrds are retained by EHS indefinitely. Respiratry fit testing recrds are retained in EHSO s central file until replaced by a mre recent recrd. Training recrds are retained in EHSO until replaced by a mre recent recrd. 1.7 Prgram Evaluatin The written Frmaldehyde Prgram is re-evaluated annually and revised as necessary. 2.0 Prcedures 2.1 Expsure Mnitring EHSO is respnsible fr cnducting peridic expsure mnitring fr frmaldehyde in areas identified as having expsures in excess f the OSHA limits (i.e. embalmers, necrpsy). Emplyees are ntified f mnitring results within fifteen days f receipt f the results. 2.2 Regulated Areas The entrances int areas identified as having expsures in excess f the OSHA Permissible Expsure Limit (PEL) f 0.75 ppm and STEL are cnsidered regulated. The entrances and access ways t these areas have the fllwing signage: DANGER FORMALDEHYDE IRRITANT AND POTENTIAL CANCER HAZARD AUTHORIZED PERSONNEL ONLY

5 Versin: 3 Page: 5 f Respiratry Prtectin Respiratry prtectin is required t be wrn in areas identified as having frmaldehyde expsures in excess f the OSHA PEL and STEL. Only the fllwing types f respiratrs are permitted t be wrn: Full Face Respiratr equipped with frmaldehyde cartridges r canisters. Pwered Air-Purifying Respiratrs equipped with frmaldehyde cartridges r canisters. Unless the frmaldehyde cartridge has an end-f-service-life-indicatr (ESLI) that shws when breakthrugh ccurs, the frmaldehyde cartridge must be replaced after every three hurs f use r at the end f the wrk shift, whichever cmes first. In wrk areas where airbrne frmaldehyde cncentratin is up t 7.5 ppm, unless the frmaldehyde canister has an ESLI that shws when breakthrugh ccurs, the canister must be replaced every fur hurs f use r at the end f the wrk shift, whichever cmes first. Emplyees must cmply with Emry s Respiratry Prtectin Prgram. 2.4 Persnal Prtective Equipment (PPE) The fllwing PPE is required t be wrn in areas having expsure t frmaldehyde in excess f the OSHA AL r STEL: Respiratrs as described in Sectin 2.3 f this prgram; Dispsable gwn; and Nitrile Glves. The fllwing PPE is required t be wrn by members f the EHSO Spill Team during the cleanup f a frmaldehyde spill: Dispsable cveralls; and Nitrile Glves 2.5 Hygiene Prtectin If emplyees' skin may becme splashed with slutins cntaining ne percent r greater frmaldehyde, fr example, because f equipment failure r imprper wrk practices, quick drench shwers are prvided. If there is any pssibility that an emplyee's eyes may be splashed with slutins cntaining 0.1 percent r greater frmaldehyde, eyewash facilities are prvided. 2.6 Inspectins The supervisr is respnsible fr ensuring inspectins are cnducted in the areas identified as having expsure t frmaldehyde in excess f the OSHA expsure limits. EHSO is respnsible fr validating the inspectins annually. The purpse f inspectins is t detect leaks and spills as well as t ensure prper strage f frmaldehyde cntaining material. 2.7 Preventive Maintenance Campus Services is respnsible fr cnducting annual preventive maintenance n ventilatin equipment in areas using frmaldehyde.

6 Versin: 3 Page: 6 f Frmaldehyde Spills If a frmaldehyde spill ccurs emplyees are t: Stp the spill, if pssible; Leave the wrk area; Clse the dr behind them; and Pst a ntice n the dr stating that the area is clsed ff due t a frmaldehyde spill. In the case f a frmaldehyde spill: Cntact EHSO at ,during nrmal business hurs; Call 911 r , if the spill ccurs after business hurs r during the weekend; Reprt the name, size and lcatin f the chemical that was spilled. EHSO is respnsible fr ensuring prper clean-up f the spill and mnitring the air t ensure that the frmaldehyde levels in the area are at an acceptable level. EHSO will give the all clear that allws emplyees re-entry int the affected area. Frmaldehyde-cntaminated waste and debris resulting frm leaks r spills are placed fr dispsal in sealed cntainers bearing a label warning f frmaldehyde s presence and the hazards assciated with frmaldehyde. 3.0 Medical Surveillance Medical surveillance is made available t: All emplyees expsed t frmaldehyde in excess f the OSHA AL r STEL; Any emplyee wh develps signs and symptms f verexpsure t frmaldehyde; and Any emplyee expsed t frmaldehyde in emergencies. All medical prcedures, including administratin f medical disease questinnaires, are perfrmed by r under the directin f a licensed physician and are prvided withut cst t the emplyee, withut lss f pay, and at a reasnable place and time. The physician determines, based n the evaluatin f the questinnaire, whether a medical examinatin is necessary fr emplyees nt required t wear respiratrs. Medical examinatins are given t any emplyee wh the physician feels, based n infrmatin in the medical disease questinnaire, may be at increased risk frm expsure t frmaldehyde and at the time f initial assignment and at least annually thereafter t all emplyees required t wear a respiratr t reduce expsure t frmaldehyde. Medical examinatins include: A physical examinatin with emphasis n evidence f irritatin r sensitizatin f the skin, respiratry system, shrtness f breath, r eyes. Labratry examinatins fr respiratr wearers cnsisting f baseline and annual pulmnary functin tests. As a minimum, these tests cnsist f frced vital capacity (FVC), frced expiratry vlume in ne

7 Versin: 3 Page: 7 f 9 secnd (FEV1), and frced expiratry flw (FEF). Any ther test which the examining physician deems necessary t cmplete the written pinin. Cunseling f emplyees having medical cnditins that wuld be directly r indirectly aggravated by expsure t frmaldehyde n the increased risk f impairment f their health. Examinatins fr emplyees expsed in an emergency. Medical examinatins are made available as sn as pssible t all emplyees wh have been expsed t frmaldehyde in an emergency. Examinatins include a medical and wrk histry with emphasis n any evidence f upper r lwer respiratry prblems, allergic cnditins, skin reactin r hypersensitivity, and any evidence f eye, nse, r thrat irritatin. Other examinatins cnsist f thse elements cnsidered apprpriate by the examining physician. Infrmatin prvided t the physician EHSO is respnsible fr prviding the fllwing infrmatin t EHS: A cpy f the Frmaldehyde Standard and Appendix A, C, D and E f the Frmaldehyde Standard; A descriptin f the affected emplyee s jb duties as they relate t the emplyee s expsure t frmaldehyde; The representative expsure level fr the emplyee s jb assignment; Infrmatin cncerning any persnal prtective equipment and respiratry prtectin used r t be used by the emplyee; and In the event f a nn-rutine examinatin because f an emergency, the physician is prvided with a descriptin f hw the emergency ccurred and the expsure the victim may have received. Physician s written pinin. Fr each examinatin required under this standard, a written pinin frm the physician is btained. This written pinin cntains the results f the medical examinatin except that it des nt reveal specific findings r diagnses unrelated t ccupatinal expsure t frmaldehyde. The written pinin includes: The physician s pinin as t whether the emplyee has any medical cnditin that wuld place the emplyee at an increased risk f material impairment f health frm expsure t frmaldehyde. Any recmmended limitatins n the emplyee s expsure r change in the use f PPE r respiratr. EHS is respnsible fr prviding a cpy f the physician s written pinin t the affected emplyee within fifteen (15) days f receipt. Medical Remval The prvisins f this sectin apply when an emplyee reprts significant irritatin f the mucsa f the eyes r f the upper airways, respiratry sensitizatin, dermal irritatin, r dermal sensitizatin attributed t wrkplace frmaldehyde expsure.

8 Versin: 3 Page: 8 f 9 Medical remval prvisins d nt apply in the case f dermal irritatin r dermal sensitizatin when the prduct suspected f causing the dermal cnditin cntains less than 0.05 percent frmaldehyde. If the Emry physician determines that a medical examinatin is nt necessary, there is a tw week evaluatin and remediatin perid t permit EHSO t ascertain whether the signs r symptms subside untreated r with the use f creams, glves, first aid treatment r persnal prtective equipment. The emplyee will be referred immediately t a physician prir t the expiratin f the tw week perid if the signs r symptms wrsen. If the signs and symptms have nt subsided r been remedied by the end f the tw week perid, r earlier if signs r symptms warrant, the emplyee will be examined by an Emry physician. The physician will presume, absent cntrary evidence, that bserved dermal irritatin r dermal sensitizatin are nt attributable t frmaldehyde when prducts t which the affected emplyee is expsed cntains less than 0.1 percent frmaldehyde. Medical examinatin will be cnducted in cmpliance with Sectin 6.5 f this prgram. If the physician finds that the emplyee s cnditin frm expsure t frmaldehyde in the wrkplace warrants restrictins r remval, the emplyee will be remved and transferred t wrk having n r significantly less expsure t frmaldehyde. When an emplyee is remved pursuant t paragraph , he/she will be transferred t a cmparable wrk area fr which the emplyee is qualified r can be trained in a shrt perid (up t six mnths) where frmaldehyde expsure is less than the frmaldehyde actin level. The remved emplyee will retain his/her current earnings, senirity, and ther benefits until: The emplyee is determined t be unable t return t wrkplace frmaldehyde expsure; The emplyee is determined t be able t return t the riginal jb status; r A perid f six mnths, whichever cmes first. NOTE: Earnings, senirity, and benefits are nt altered during the tw-week evaluatin perid. A fllw-up medical examinatin will be prvided within six mnths after the emplyee has been remved. The purpse f the fllw-up examinatin is t determine if the emplyee can return t the riginal jb status, r if the remval is permanent. Multiple Physician Review: The Medical Review Prgram will meet the requirements f the OSHA Frmaldehyde Standard. 4.0 Hazard Cmmunicatin Cmmunicatins f the hazards assciated with frmaldehyde in the wrkplace are gverned by Sectin 4.0 f this prgram.

9 Versin: 3 Page: 9 f 9 The fllwing are subject t the hazard cmmunicatin requirements f this sectin: Frmaldehyde gas; All mixtures r slutins cmpsed f greater than 0.1 percent frmaldehyde; and Materials capable f releasing frmaldehyde int the air, under reasnable freseeable cnditins f use, at cncentratins reaching r exceeding 0.1 ppm. Hazard warning labels must be affixed t all frmaldehyde cntainers as indicated in Sectin 4.0 that enter Emry University campus. At a minimum labels will: Identify that the prduct cntains frmaldehyde; Include the wrd Danger ; Cntain a Pictgram Carcingen; Indicate dermal and respiratry system hazard; List the name and address f the manufacturer; and Include the wrd Carcingen All damaged labels will be replaced. Secndary frmaldehyde cntainers are labeled frmaldehyde, frmalin, r parafrmaldehyde. Safety Data Sheets can be accessed frm SDS Online, lcated n the EHSO website. 5.0 References OSHA FORMALDEHYDE STANDARD Emry University Frmaldehyde Training Emry University Respiratry Prtectin Prgram 6.0 List f Assciated Dcuments Frmaldehyde Fact Sheet Frmaldehyde Questinnaire

Effective Date: 27-April Table of Contents

Effective Date: 27-April Table of Contents Versin: 5 Page: 1 f 10 Table f Cntents 1.0 Intrductin... 2 1.1 Purpse... 2 1.2 Scpe... 2 1.3 Definitins... 2 1.4 Respnsibilities... 3 Emry Envirnmental Health and Safety Office (EHSO)... 3 Supervisrs and