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OSHA Training: Hazard Communication vs. Formaldehyde

As funeral home professionals, we are all familiar with OSHA’s Hazard Communication Standard, 1910.1200. The Hazard Communication Standard’s (HAZCOM) overall intent is to ensure employees understand the hazards of the chemicals they work with and how to protect themselves. Items such as safety data sheets (SDS), chemical labeling, personal protective equipment (PPE), and proper disposal are examples of what is covered within HAZCOM. So, how do employees learn about the hazards of the chemicals for which they work? Training of course.

The HAZCOM standard requires initial training of employees about any type of specific chemical hazards in the workplace. Safety data sheets are often the most utilized resource when HAZCOM training is conducted. Funeral home management must ensure all personnel be trained initially before assignment to work activities involving hazardous chemicals. This training is generally a “one-time” only training unless new chemicals are introduced into the funeral home. For example, if a new embalming fluid is introduced in to the funeral home with new chemical hazards, then additional training of embalmers about the hazards of the new embalming fluid is required before beginning to use.

From a funeral home operations perspective, at a minimum, it is recommended that time be spent on training applicable personnel about the primary hazards of handling embalming fluids. The primary chemical hazards in the embalming process are generally formaldehyde, methanol, and glutaraldehyde. Of course, there are other hazardous chemicals associated with other embalming chemical products and it is recommended that their SDS be referenced as part of the training. However, considerable focus should be given to formaldehyde, methanol, and glutaraldehyde.

So here in lies the compliance question “am I required to offer detailed and specific formaldehyde training as outlined by OSHA’s Formaldehyde Standard, 1910.1048” or “will a simple session on formaldehyde hazards suffice as part of general HAZCOM training”?

Answer: Formaldehyde specific training is required annually for embalmers per OSHA 1910.1048, formaldehyde.

It is a common misconception that simple one-time HAZCOM training satisfies formaldehyde training requirements. Sure, formaldehyde is a chemical hazard that must be communicated. But there is much information that must be shared, and this is clearly outlined in the OSHA formaldehyde standard. OSHA’s formaldehyde standard states that if it is possible for employee exposures to be 0.1 ppm or greater in the work setting, then annual training is required. This exposure risk exists in every embalming room in the country. So, be aware that applicable employees must be trained annually on the hazards of formaldehyde.

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