As we all know, formaldehyde has been and continues to be the primary tissue preservation chemical used in the embalming process. Formaldehyde has long been known to be a potential carcinogen and severe skin irritant and as a result is regulated by the Occupational Safety and Health Administration (OSHA). In fact, the vast majority of OSHA compliance obligations associated with embalming operations stem from OSHA’s formaldehyde regulation, 1910.1048. While protecting one’s skin, eyes, nose and mouth from contact with embalming fluids containing formaldehyde is extremely important, the more difficult risk to manage is the inhalation of formaldehyde. The inhalation of excessive concentrations of formaldehyde can potentially lead to respiratory system cancers and other health problems.
The risk of respiratory cancer among embalmers is very real. Every day these professionals work with formaldehyde and may inhale various concentrations of the chemical into their bodies. Unfortunately, this risk is often misunderstood and as a result, these exposures go uncharacterized or are not well-defined. Many factors play into one’s exposure to formaldehyde via inhalation. Variables include formaldehyde concentration of the fluid, embalming room ventilation efficiency, time of exposure, individual embalming procedure work practices, and others. To help protect embalmers from excessive inhalation exposure to formaldehyde, OSHA established a set of permissible exposure limits (PEL) in 1987 with the original promulgation of the Formaldehyde Standard, 1910.1048. In 1991, OSHA lowered its’ previously-established PELs for formaldehyde and these are still in force today 26 years later. The problem with the existing set of OSHA PELs for formaldehyde (like many other OSHA chemical PELs) is the fact that they arguably may not reflect the latest scientific research and may not be protective enough in the prevention of known health effects such as respiratory cancer.
By comparison, other industry and governmental organizations have established inhalation exposure recommendations for formaldehyde. Organizations such as the American Conference of Governmental Industrial Hygienists (ACGIH) and the National Institute of Occupational Safety and Health (NIOSH) have considerably lower exposure limits for formaldehyde based upon their review of more current research on risks.
So what does all-of-this mean and what actions should be taken?
Step 1 – Accurately Assess Exposures
The first thing funeral home management must do is take steps to accurately assess their embalmer’s exposures to formaldehyde during embalming operations. While this sounds straight forward, there are many variables and intricacies associated with properly conducting personal exposure monitoring and consultation with an experienced industrial hygienist is recommended. One critical item to keep in mind is that there is big difference between conducting “area” sampling versus “personal” sampling. OSHA 1910.1048, Appendix B – Strategy and analytical methods for formaldehyde is an excellent reference.
Step 2 – Control Exposures to Below the OSHA PELs
First and foremost, embalmer exposures to formaldehyde must be below the established OSHA PELs. If personal exposure monitoring results reveal excessive exposures, then take steps to analyze what may be causing the excessive exposures. Is it lack of adequate ventilation? Is it undesirable work practices? Take steps to lower the worker exposures to levels below the OSHA PELs immediately. Placing personnel in respiratory protection may be necessary while engineering or work practice controls measures are being taken.
Step 3 – Establish a Monitoring Program
It is not uncommon for funeral homes to have only one set of embalmer formaldehyde exposure monitoring results that are several years old and in some cases decades old. This is simply not enough information in many cases to have an “accurate” depiction of embalmer exposure to formaldehyde as required by OSHA. Embalmers come and go over time and the funeral home should not apply their personal exposure results to new embalmers they hire. When a new embalmer is hired, they will have unique, personal exposures that are a reflection of their work practices. Additionally, the funeral home may change embalming fluids over time which also can result in different embalmer exposures. The same is true for embalming room re-designs, ventilation performance degradation, and other physical attribute changes that may take place over time.
Having an established, regularly-occurring formaldehyde monitoring program will allow the funeral home to better understand embalmer exposures to formaldehyde. It will place the funeral home in a better position to comply with OSHA’s PELs for formaldehyde while also better protecting embalmer’s health. But what to do about the other established exposure limits recommended by ACGIH and NIOSH? It is recommended that “feasible” steps be taken to lower and maintain embalmer exposures to formaldehyde to as low as reasonably attainable. It is entirely possible that OSHA may lower the PELs for formaldehyde in the future like they did in 1991. The bottom line is that we all want to protect the health of our embalming professionals and managing the risks associated with the inhalation of formaldehyde during embalming procedures is critical in doing that.