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CPL 02-00-035 - CPL 2.35 CH-15 - Changes to the Regulatory and General Industry (SAVEs Manual) for "Occupational Exposure to Formaldehyde." |
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Record Type: | Instruction |
Directive Number: | CPL 02-00-035 |
Old Directive Number: | CPL 2.35 CH-15 |
Title: | Changes to the Regulatory and General Industry (SAVEs Manual) for "Occupational Exposure to Formaldehyde." |
Information Date: | 02/18/1991 |
Standard Number: | 1910.1047; 1910.1048(m)(1); 1910.1048(m)(4) |
U.S. Department of Labor Occupational Safety and Health Administration
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance Subject: Changes to the Regulatory and General Industry Standard Alleged Violation Elements (SAVEs) Manual A. Purpose. This instruction transmits revised and new pages to the Regulatory and General Industry SAVEs Manual for "Occupational Exposure to Formaldehyde." B. Scope. This instruction applies OSHA-wide. C. Action. Regional Administrators and Area Directors shall ensure that all compliance personnel:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance D. Background. Final rule and regulations for 29 CFR 1910.1047, Occupational Exposure to Formaldehyde, were published in the Federal Register, Vol. 52, No. 233, on December 4, 1987.
E. State Plan States. Regional Administrators shall advise State designees of the action required by this instruction and encourage their participation in the SAVEs program. Patricia K. Clark, Director Directorate of Compliance Programs DISTRIBUTION: National, Regional, and Area Offices Compliance Officers State Designees Area Office Clericals 11(c)/405 Programs NIOSH Regional Program Directors
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(c)(1): Employees were exposed to an airborne concentration of formaldehyde which exceeded one part formaldehyde per million parts of air (1 ppm), as an 8-hour TWA:
2 29 CFR 1910.1048(c)(2): Employees were exposed to an airborne concentration of formaldehyde which exceeded two parts formaldehyde per million parts of air (2 ppm) as a 15-minute STEL:
3 29 CFR 1910.1048(d)(1)(i): Employees of a workplace covered by this standard were not monitored to determine their exposure to formaldehyde:
OPTION 1 4 29 CFR 1910.1048(d)(1)(iii): Sampling measurements used to determine an employee's exposure were not representative of the employee's full shift exposure to formaldehyde:
OPTION 2 1 29 CFR 1910.1048(d)(1)(iii): Sampling measurements used to determine an employee's exposure were not representative of the employee's short-term exposure to formaldehyde:
OPTION 1 2 29 CFR 1910.1048(d)(1)(iv): Representative samples of formaldehyde were not taken for each job classification in each work area for each shift when the employer could not document with objective data that the exposure levels for a given job classification were equivalent for different work shifts:
3 29 CFR 1910.1048(d)(2): Employees were not identified who may be exposed at or above the action level, or at or above the STEL and the exposure was not accurately determined of each employee so identified:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(d)(2)(i): A representative sampling strategy was not developed and sufficient exposures of each employee to formaldehyde was not measured within each job classification for each workshift to correctly characterize and not underestimate the exposure of any employee within each exposure group:
2 29 CFR 1910.1048(d)(2)(ii): The initial monitoring process was not repeated each time there was a change in production, equipment, process, personnel, or control measures which could have resulted in new or additional exposure to formaldehyde:
3 29 CFR 1910.1048(d)(3)(i): The employer did not periodically measure and accurately determine exposure to formaldehyde for employees shown by the initial monitoring to be exposed at or above the action level, or at or above the STEL:
1 29 CFR 1910.1048(d)(3)(ii): When the last monitoring results for formaldehyde revealed employee exposure at or above the action level, monitoring of employees was not repeated at least every 6 months,
2 29 CFR 1910.1048(d)(3)(iii): When the last monitoring results for formaldehyde revealed employee exposure at or above the STEL, monitoring of employees was not repeated at least once a year under worst conditions:
3 29 CFR 1910.1048(d)(4): The employer discontinued periodic monitoring for employees on the basis of sampling results that were not statistically representative and consistent with the employer's knowledge of the job and work operation:
OPTION 1 4 29 CFR 1910.1048(d)(5): Monitoring was not accurate, at the 95 percent confidence level, to within plus or minus 25 percent for airborne concentrations of formaldehyde at the TWA and the STEL:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.1048(d)(5): Monitoring was not accurate, at the 95 percent confidence level, to within plus or minus 35 percent for airborne concentrations of formaldehyde at the action level:
OPTION 1 2 29 CFR 1910.1048(d)(6): Employees were not notified within 15 working days of receiving the results of exposure monitoring of formaldehyde, in writing, either by distributing copies of the results to the employees or by posting the results:
OPTION 2 3 29 CFR 1910.1048(d)(6): When employee exposure to formaldehyde was over either PEL, the employer did not develop and implement a written plan to reduce employee exposure to or below both PELs, and did not give written notice to the employees:
OPTION 3 1 29 CFR 1910.1048(d)(6): When employee exposure to formaldehyde was over either PEL, the written notice to employees of the plan developed by the employer to reduce employee exposure did not contain a description of the corrective action being taken by the employer to decrease exposure:
2 29 CFR 1910.1048(d)(7)(i): The employer did not provide affected employees or their designated representatives an opportunity to observe any monitoring of employee exposure to formaldehyde required by this standard:
3 29 CFR 1910.1048(d)(7)(ii): When observation of the monitoring of employee exposure to formaldehyde required entry into an area where the use of protective clothing or equipment was required, the employer did not provide the clothing and equipment to the observer, nor require the observer to use such clothing and equipment, and did not ensure that the observer complied with all other applicable safety and health procedures:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.1048(e)(1): The employer did not establish regulated areas where the concentration of airborne formaldehyde exceeded either the TWA or the STEL:
OPTION 2 2 29 CFR 1910.1048(e)(1): The employer did not post all entrances and accessways of established regulated areas with warning signs bearing the following information:
3 29 CFR 1910.1048(e)(2): The employer did not limit access to regulated areas to authorized persons who have been trained to recognize the hazards of formaldehyde:
1 29 CFR 1910.1048(e)(3): Access restrictions and locations of regulated areas at a multi-employer worksite were not communicated to other employers with work operations at that worksite:
2 29 CFR 1910.1048(f)(1): Engineering controls and work practices were not instituted to reduce and maintain employee exposures to formaldehyde at or below the TWA and the STEL: (a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS) (DESCRIBE CONDITIONS INCLUDING EXPOSURE LEVELS) OPTION 1 3 29 CFR 1910.1048(f)(2): Whenever the employer had established that feasible engineering and work practice controls would not reduce employee exposure to or below either of the PELs, the employer did not apply these controls to reduce employee exposures to the extent feasible:
OPTION 2 4 29 CFR 1910.1048(f)(2): The employer established that feasible engineering and work practice controls cannot reduce employee exposure to or below either of the PELs and did not supplement them with respirators which satisfy this standard:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.1048(g)(1): Where respiratory protection is required that would reduce the concentrations of formaldehyde inhaled by the employees to at or below both the TWA and the Stel, respirators were not provided at no cost to the employees:
OPTION 2 2 29 CFR 1910.1048(g)(1): Where respiratory protection is required and used, the employer did not ensure that they were properly used by employees:
OPTION 3 3 29 CFR 1910.1048(g)(1): Respiratory protection being used by the employees did not comply with this standard nor did the respiratory protection reduce the concentration of formaldehyde inhaled by the employees to at or below both the TWA and the STEL:
4 29 CFR 1910.1048(g)(1)(i): Respirators that reduce the concentrations of formaldehyde inhaled by the employee to at or below both the TWA and the STEL were not used by the employees during the interval necessary to install or implement feasible engineering and work practice controls:
1 29 CFR 1910.1048(g)(1)(ii): Respirators that reduce the concentration of formaldehyde inhaled by the employee to at or below both the TWA and the STEL were not used in work operations such as maintenance and repair activities or vessel cleaning, for which the employer established that engineering and work practice controls were not feasible:
2 29 CFR 1910.1048(g)(1)(iii): Respirators that reduce the concentration for formaldehyde inhaled by the employee to at or below both the TWA and STEL were not provided to the employees in work situations where feasible engineering and work practice controls were not yet sufficient to reduce exposure to or below the PELs:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(g)(1)(iv): Respirators that reduce the concentration of formaldehyde inhaled by the employee to at or below both the TWA and the STEL were not provided to the employees in emergencies:
2 29 CFR 1910.1048(g)(2)(i): Appropriate respirators were not selected from those jointly approved as acceptable for protection against formaldehyde by the Mine Safety and Health Administration (MSHA) and by the National Institute for Occupational Safety and Health (NIOSH) under the provisions of 30 CFR Part 11:
3 29 CFR 1910.1048(g)(2)(ii): The employer did not make available a powered air purifying respirator meeting the specifications in "Table 1. Minimum Requirements for Respiratory Protection Against Formaldehyde" to any employee who experienced difficulty wearing a negative pressure respirator to reduce exposure to formaldehyde:
1 29 CFR 1910.1048(g)(3)(i): A respiratory protection program in accordance with 29 CFR 1910.134(b), (d), (e), and (f) was not instituted where respiratory protection was required for employees exposed to formaldehyde:
2 29 CFR 1910.1048(g)(3)(ii): The employer did not perform either quantitative or qualitative face fit tests in accordance with the procedures in Appendix E of this standard, at the time of initial fitting and at least annually thereafter for all employees required by this standard to wear negative pressure respirators:
3 29 CFR 1910.1048(g)(3)(ii)(A): Respirators were not selected from those exhibiting the best facepiece fit:
4 29 CFR 1910.1048(g)(3)(ii)(B): The employer did not ensure that respirators chosen would not potentially permit the employee to inhale formaldehyde at concentrations in excess of either the TWA or the STEL:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(g)(3)(iii): Where air purifying chemical cartridge respirators were used that did not contain a NIOSH-approved end-of-service indicator to show where breakthrough occurs, the cartridges were not replaced after three hours of use or at the end of the workshift, whichever was sooner:
OPTION 1 2 29 CFR 1910.1048(g)(3)(iv): Canisters that did not contain a NIOSH-approved end-of-service-life indicator to show when breakthrough occurs, were used in atmospheres up to 10 ppm and not replaced every 4 hours:
OPTION 2 3 29 CFR 1910.1048(g)(3)(iv): Industrial canisters that did not contain a NIOSH-approved end-of-service-life indicator to show when breakthrough occurs, were used in atmospheres up to 100 ppm and not replaced every two hours or at the end of the workshift, whichever was sooner:
1 29 CFR 1910.1048(g)(3)(v): The employer did not permit employees to leave the work area to wash their faces and respirator facepieces as needed to prevent skin irritation from respirator use:
2 29 CFR 1910.1048(h): Appropriate protective equipment or clothing was not provided at no cost to the employee, and the employee did not ensure that the employee wore them:
3 29 CFR 1910.1048(h)(1): The employer did not select protective clothing and equipment based upon the form of formaldehyde that would be encountered, the conditions of use, and the hazard to be prevented:
4 29 CFR 1910.1048(h)(1)(i): All contact of the eyes and skin with liquids containing 1 percent or more formaldehyde was not prevented by the use of chemical protective clothing made of material impervious to formaldehyde and the use of other personal protective equipment, such as goggles and face shields, as appropriate to the operation:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(h)(1)(ii): Contact with irritating or sensitizing materials was not prevented to the extent necessary to eliminate the hazard:
2 29 CFR 1910.1048(h)(1)(iii): Chemical safety goggles were not required where a face shield was worn and there was a danger of formaldehyde reaching the area of the eye:
4 29 CFR 1910.1048(h)(2)(i): The employer did not ensure that the protective equipment and clothing that had become contaminated with formaldehyde was cleaned or laundered before its reuse:
OPTION 1 1 29 CFR 1910.1048(h)(2)(ii): When ventilating formaldehyde-contaminated clothing and equipment, the employer did not establish a storage area so that employee exposure was minimized:
OPTION 2 2 29 CFR 1910.1048(h)(2)(ii): Containers for contaminated clothing and equipment and storage areas did not have appropriate labels and signs containing the following information:
3 29 CFR 1910.1048(h)(2)(iii): The employer did not ensure that only persons trained to recognize the hazards of formaldehyde remove the contaminated material from the storage area for the purposes of cleaning, laundering, or disposal:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(h)(2)(iv): The employer did not ensure that no employee took home equipment or clothing that was contaminated with formaldehyde:
2 29 CFR 1910.1048(h)(2)(v): The employer did not repair or replace all required protective clothing and equipment for each affected employee as necessary to ensure its effectiveness:
3 29 CFR 1910.1048(h)(2)(vi): The employer did not inform any person who launders, cleans, or repairs required protective clothing or equipment of formaldehyde's potentially harmful effects and of procedures to safely handle the clothing and equipment:
4 29 CFR 1910.1048(i)(1): The employer did not provide change rooms, as described in 29 CFR 1910.141 for employees who were required to change from work clothing into protective clothing to prevent skin contact with formaldehyde:
1 29 CFR 1910.1048(i)(2): When employees' skin could have become splashed with solutions containing 1 percent or greater formaldehyde, the employer did not provide conveniently located quick drench showers and ensure that affected employees used those facilities immediately:
2 29 CFR 1910.1048(i)(3): When there was a possibility that an employee's eyes could be splashed with solutions containing 0.1 percent or greater formaldehyde, the employer did not provide acceptable eyewash facilities within the immediate work area for emergency use:
3 29 CFR 1910.1048(j): For operations involving formaldehyde liquids or gas, the employer did not conduct a program to detect leaks and spills, including regular visual inspections:
4 29 CFR 1910.1048(j)(1): For operations involving formaldehyde liquids or gas, the employer did not conduct preventative maintenance of equipment, including surveys for leaks, at regular intervals:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(j)(2): In work areas where spillage may occur, the employer did not make provisions to contain the spill, to decontaminate the work area, and to dispose of the waste:
2 29 CFR 1910.1048(j)(3): The employer did not ensure that all leaks were repaired and spills were cleaned promptly by employees wearing suitable protective equipment and trained in proper methods for cleanup and decontamination:
3 29 CFR 1910.1048(j)(4): Formaldehyde-contaminated waste and debris resulting from leaks or spillage was not placed for disposal in sealed containers bearing a label warning of formaldehyde presence and of the hazards associated with formaldehyde:
1 29 CFR 1910.1048(k): When there was the possibility of an emergency involving formaldehyde, the employer did not ensure that appropriate procedures were adopted to minimize injury and loss of life and implemented in the event of an emergency:
2 29 CFR 1910.1048(l)(1)(i): The employer did not institute medical surveillance programs for all employees exposed to formaldehyde at concentrations at or exceeding the action level or exceeding the STEL:
OPTION 1 3 29 CFR 1910.1048(l)(1)(ii): The employer did not make medical surveillance available for employees who developed signs and symptoms of overexposure to formaldehyde:
OPTION 2 4 29 CFR 1910.1048(l)(1)(ii): The employer did not make medical surveillance available for employees exposed to formaldehyde in emergencies:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.1048(l)(2): Medical procedures, including administration of medical disease questionnaires, were not performed by or under the supervision of a licensed physician:
OPTION 2 2 29 CFR 1910.1048(l)(2): Medical procedures were not provided without cost to the employee, without loss of pay, and at a reasonable time and place:
3 29 CFR 1910.1048(l)(3): The employer did not administer a medical disease questionnaire, such as in Appendix D of this standard, designed to elicit information on work history, smoking history, any evidence of eye, nose, or throat irritation; chronic airway problems or hyperreactive airway disease; allergic skin conditions or dermatitis; and upper or lower respiratory problems, to employees prior to assignment to a job where formaldehyde exposure was at or above the action level or above the STEL and annually thereafter:
1 29 CFR 1910.1048(l)(3)(i): The employer did not promptly administer a medical disease questionnaire, such as in Appendix D of this standard, designed to elicit information on work history, smoking history, any evidence of eye, nose, or throat irritation; chronic airway problems or hyperreactive airway disease; allergic skin conditions or dermatitis; and upper or lower respiratory problems, upon determining that an employee was experiencing signs and symptoms indicative of possible overexposure to formaldehyde:
2 29 CFR 1910.1048(l)(3)(ii): A determination by the physician, based on evaluation of the medical disease questionnaire administered to employees, was not made of whether a medical examination was necessary for employees not required to wear respirators to reduce exposure to formaldehyde:
3 29 CFR 1910.1048(l)(4): Medical examinations were not given to any employee who the physician determined, based on evaluation of the medical disease questionnaire, could be at increased risk from exposure to formaldehyde, and at the time of initial assignment and at least annually thereafter to all employees required to wear a respirator to reduce exposure to formaldehyde:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(l)(4)(i): The medical examination did not include a physical examination with emphasis on evidence of irritation or sensitization of the skin and respiratory system, shortness of breath, or irritation of the eyes:
2 29 CFR 1910.1048(l)(4)(ii): The medical examination did not include laboratory examinations for respirator wearers consisting of baseline and annual pulmonary function tests, which consisted of forced vital capacity (FVC), forced expiratory volume in one second (FEV1), and forced expiratory flow (FEF):
3 29 CFR 1910.1048(l)(4)(iii): The medical examination did not include any other test which the examining physician deemed necessary to complete the written opinion:
4 29 CFR 1910.1048(l)(4)(iv): The medical examination did not include counseling of employees having medical conditions that would be directly or indirectly aggravated by exposure to formaldehyde on the increased risk of impairment of their health:
1 29 CFR 1910.1048(l)(5): The employer did not make medical examinations available as soon as possible to all employees who had been exposed to formaldehyde in an emergency:
2 29 CFR 1910.1048(l)(5)(i): The medical examination to employees exposed to formaldehyde did not include a medical and work history with emphasis on any evidence of upper or lower respiratory problems, allergic conditions, skin reaction or hypersensitivity, and any evidence of eye, nose, or throat irritation:
3 29 CFR 1910.1048(l)(5)(ii): Other examinations to employees exposed to formaldehyde did not consist of those elements considered appropriate by the examining physician:
4 29 CFR 1910.1048(l)(6)(i): The employer did not provide a copy of the formaldehyde standard, 29 CFR 1910.1048, and Appendices A, C, D, and E, to the examining physician:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(l)(6)(ii): The employer did not provide a description of the affected employee's job duties as they relate to the employee's exposure to formaldehyde to the examining physician:
2 29 CFR 1910.1048(1)(6)(iii): The employer did not provide the representative exposure level of formaldehyde for the employee's job assignment to the examining physician:
3 29 CFR 1910.1048(l)(6)(iv): The employer did not provide information concerning any personal protective equipment and respiratory protection for exposure to formaldehyde used or to be used by the employee to the examining physician:
4 29 CFR 1910.1048(l)(6)(v): The employer did not provide information from previous medical examinations of the affected employee within the control of the employer to the examining physician:
5 29 CFR 1910.1048(l)(6)(vi): In a nonroutine examination because of an emergency, the employer did not provide the physician as soon as possible a description of how the emergency occurred and the exposure to formaldehyde the victim may have received:
1 29 CFR 1910.1048(l)(7)(i): For each examination required under this standard, the employer did not obtain a written opinion from the examining physician containing the results of the medical examination and excluding specific findings or diagnoses unrelated to occupational exposure to formaldehyde:
2 29 CFR 1910.1048(l)(7)(i)(A): The written opinion did not include the physician's opinion as to whether the employee had any medical condition that would place the employee at an increased risk of material impairment of health from exposure to formaldehyde:
3 29 CFR 1910.1048(l)(7)(i)(B): The written opinion did not include any recommended limitations on the employee's exposure to formaldehyde or changes in the use of personal protective equipment, including respirators:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(1)(7)(i)(C): The written opinion did not include a statement that the employee had been informed by the physician of any medical conditions which would be aggravated by exposure to formaldehyde, whether these conditions may have resulted from past formaldehyde exposure or from exposure in an emergency, and whether there was a need for further examination or treatment:
2 29 CFR 1910.1048(l)(7)(ii): The employer did not provide for retention of the results of the medical examination and tests for exposure to formaldehyde conducted by the physician:
3 29 CFR 1910.1048(l)(7)(iii): The employer did not provide a copy of the physician's written opinion to the affected employee within 15 days of its receipt:
1 29 CFR 1910.1048(n)(1): The employer did not ensure that all employees who were assigned to workplaces where there was a health hazard from formaldehyde participated in a training program:
2 29 CFR 1910.1048(n)(2)(i): The employer did not provide employees with information and training on formaldehyde at the time of their initial assignment and wherever a new hazard from formaldehyde was introduced into their work area:
3 29 CFR 1910.1048(n)(2)(ii): The employer did not provide appropriate information and training at least annually for all employees exposed to formaldehyde concentrations at or above the action level or the STEL:
4 29 CFR 1910.1048(n)(3): The training program for all employees exposed to formaldehyde was not conducted in a manner which the employee was able to understand:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(n)(3)(i): The training program for all employees exposed to formaldehyde did not include a discussion of the contents of this formaldehyde regulation and the contents of the Material Safety Data Sheet:
2 29 CFR 1910.1048(n)(3)(ii): The training program for all employees exposed to formaldehyde did not include the purpose for and a description of the medical surveillance program required by this formaldehyde standard:
3 29 CFR 1910.1048(n)(3)(ii)(A): The training program did not include a description of the potential health hazards associated with exposure to formaldehyde and a description of the signs and symptoms of exposure to formaldehyde:
4 29 CFR 1910.1048(n)(3)(ii)(B): The training program did not include instructions to immediately report to the employer the development of any adverse signs or symptoms that the employee suspected was attributable to formaldehyde exposure:
1 29 CFR 1910.1048(n)(3)(iii): The training program on formaldehyde did not include a description of operations in the work area where formaldehyde was present and an explanation of the safe work practices appropriate for limiting exposure to formaldehyde in each job:
2 29 CFR 1910.1048(n)(3)(iv): The training program on formaldehyde did not include the purpose for, proper use of, and limitations of personal protective clothing and equipment:
3 29 CFR 1910.1048(n)(3)(v): The training program for formaldehyde did not include instructions for the handling of spills, emergencies, and clean-up procedures:
4 29 CFR 1910.1048(n)(3)(vi): The training program for formaldehyde did not include an explanation of the importance of engineering and work practice controls for employee protection and any necessary instruction in the use of these controls:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(n)(3)(vii): The training program for formaldehyde did not include a review of emergency procedures including the specific duties or assignments of each employee in the event of an emergency:
2 29 CFR 1910.1048(n)(4)(i): The employer did not inform all affected employees of the location of written training materials on formaldehyde and did not make these materials readily available, without cost, to the affected employees:
3 29 CFR 1910.1048(o)(1): The employer did not establish and maintain an accurate record of all measurements taken to monitor employee exposure to formaldehyde:
4 29 CFR 1910.1048(o)(1)(i): The record of all measurements taken to monitor employee exposure to formaldehyde did not include the date of measurement:
1 29 CFR 1910.1048(o)(1)(ii): The record of all measurements taken to monitor employee exposure to formaldehyde did not include the operation being monitored:
2 29 CFR 1910.1048(o)(1)(iii): The record of all measurements taken to monitor employee exposure to formaldehyde did not include the methods of sampling and analysis and evidence of their accuracy and precision:
3 29 CFR 1910.1048(o)(1)(iv): The record of all measurements taken to monitor employee exposure to formaldehyde did not include the number, durations, time, and results of samples taken:
4 29 CFR 1910.1048(o)(1)(v): The record of all measurements taken to monitor employee exposure to formaldehyde did not include the types of protective devices worn:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(o)(1)(vi): The record of all measurements taken to monitor employee exposure to formaldehyde did not include the names, job classifications, social security numbers, and exposure estimates of the employees whose exposures were represented by the actual monitoring results:
2 29 CFR 1910.1048(o)(2): When it was determined that no monitoring was required under this standard, the employer did not maintain a record of the objective data relied upon to support the determination that no employee was exposed to formaldehyde at or above the action level:
3 29 CFR 1910.1048(o)(3): The employer did not establish and maintain an accurate record of exposure to formaldehyde for each employee subject to medical surveillance under this standard:
4 29 CFR 1910.1048(o)(3)(i): The record of exposure to formaldehyde for each employee subject to medical surveillance did not include the name and social security number of the employee:
1 29 CFR 1910.1048(o)(3)(ii): The record of exposure to formaldehyde for each employee subject to medical surveillance did not include the physician's written opinion:
2 29 CFR 1910.1048(o)(3)(iii): The record of exposure to formaldehyde for each employee subject to medical surveillance did not include a list of any employee health complaints that could be related to exposure to formaldehyde:
3 29 CFR 1910.1048(o)(3)(iv): The record of exposure to formaldehyde for each employee subject to medical surveillance did not include a copy of the medical examination results, including medical disease questionnaires and results of any medical tests required by the standard or mandated by the examining physician:
4 29 CFR 1910.1048(o)(4)(i): The employer did not establish and maintain accurate records of exposure to formaldehyde for employees subject to negative pressure respirator fit testing required by this standard:
OSHA Instruction CPL 2.35 CH-15 FEB 18 1991 Office of General Industry Compliance Assistance 1 29 CFR 1910.1048(o)(4)(ii)(A): The record of exposure to formaldehyde for employees did not include a copy of the protocol selected for respirator fit testing:
2 29 CFR 1910.1048(o)(4)(ii)(B): The record of exposure to formaldehyde for employees did not include a copy of the results of any fit testing performed:
3 29 CFR 1910.1048(o)(4)(ii)(C): The record of exposure to formaldehyde for employees did not include the size and manufacturer of the types of respirators available for selection:
4 29 CFR 1910.1048(o)(4)(ii)(D): The record of exposure to formaldehyde for employees did not include the date of the most recent fit testing, the name and social security number of each tested employee, and the respirator type and facepiece selected:
1 29 CFR 1910.1048(o)(5)(i): The employer did not retain exposure to formaldehyde records and determinations for at least 30 years:
2 29 CFR 1910.1048(o)(5)(ii): The employer did not retain medical records of employees exposed to formaldehyde for the duration of employment, plus 30 years:
3 29 CFR 1910.1048(o)(5)(iii): The employer did not retain respirator fit testing records of employees exposed to formaldehyde until replaced by a more recent record:
4 29 CFR 1910.1048(o)(6)(ii): The employer did not make employee exposure to formaldehyde records, including estimates made from representative monitoring available upon request for examination and copying to the subject employee, or former employee, and employee representatives in accordance with 29 CFR 1910.20(a)-(e) and (g)-(i):
5 29 CFR 1910.1048(o)(6)(iii): Employee medical records for exposure to formaldehyde required by this standard were not provided upon request for examination and copying, to the subject employee or former employee or to anyone having the specific written consent of the subject employee or former employee:
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