I’ve been doing some work with the nice folks in the Mortuary Science department at the University of Minnesota in Minneapolis. They had questions about the implementation of Federal OSHA’s Hazard Communication regulation (Haz. Comm.) here in Minnesota and how it’s replacing Minnesota Employee Right to Know Act or MERTKA. For a refresher on this change, you can read my blog on this topic here.
Mortuaries and funeral homes who provide embalming have extensive OSHA requirements. There are at least five major OSHA requirements that apply, and many more that are of lesser importance.
The first is the Federal Hazard Communication (haz. comm.) regulation, which applies to any employee who has routine exposure to a hazardous chemical. In some states, such as here in Minnesota, there is also coverage for employee who have exposure to harmful physical agents, such as heat, noise or radiation, and infectious agents, such as Tuberculosis. Employees who work in embalming have significant exposure to chemicals including Formaldehyde. Thus, they are covered by the regulation. Haz. Comm. is a key compliance area, as it is nearly always one of the most frequently-cited regulations. Employers who are covered by the rule are required to develop and implement a formal, written compliance program that address how hazards will be communicated through chemical labeling, Safety Data Sheets (formerly Material Safety Data Sheets), and employee training.
Second is the Bloodborne Pathogens regulation (29 CFR 1910.1030). Because employees involved in embalming have exposure to human blood, tissues, and Other Potentially Infectious Materials (OPIM) they are covered by the OSHA BBP regulation. It matters not that the exposures are from a cadaver. As I’ve discussed in other blog posts, the Bloodborne Pathogens rule requires the employer to develop and implement a formal, written exposure control plan that is intended to reduce or eliminate the likelihood of exposure incidents, as defined in the regulation. Some of the key components of the written procedure include a determination or identification of the jobs and tasks that have exposure, employee training (at time of initial assignment and annually thereafter), engineering controls, and the offering of the Hepatitis B vaccination series to exposed employees.
The third OSHA regulation to discuss is one I don’t discuss very often; the Formaldehyde standard, which you can find here. Employees who perform embalming and other related activities have significant exposures to Formaldehyde, both in liquid and vapor phases. It is very common for employees to be exposed to levels of Formaldehyde well in excess of the regulations established in the OSHA rule. Like most air contaminants, the first step in complying with the rule is to evaluate your employees’ actual exposure to determine if it is likely to exceed applicable limits and guidelines. You can contact a trained professional like an industrial hygienist to develop and carry out a sampling strategy, but there are also some fairly reliable “do-it-yourself” type approaches available, such as 3M vapor diffusion badges. If results show that there might be an issue, a variety of requirements will come into play. The most important requirement will be to implement feasible engineering controls such as the installation of local ventilation. Down draft table have been shown to be a very attractive option in this application. Employee training, postings, and even medical surveillance might be required.
The fourth requirement is Personal Protective Equipment and the closely related topic of Respiratory Protection. OSHA’s general Personal Protective Equipment requirements require the employer to survey and document (in writing) the hazards that are likely to exist in the workplace. When/If those hazards can be controlled by PPE, the employer must select the proper types, styles, and sizes of PPE, provide it to employees (in nearly all cases it must be provided free of charge), train them on its use, and require it to be worn. Since Formaldehyde is a corrosive liquid, eye protection becomes the most important concern. A tight-fitting eye protectors, such as goggles, would be required.
In the case of respiratory protection, it’s important to remember that ANY use of respirators will trigger the need for some level of formal, written respiratory protection program, even when that use is voluntary. The one and only exception to this would be an employee whose only use of a respirator is the voluntary use of a filtering facepiece respirator. In summary, there will be two, or perhaps three requirements under the Respiratory Protection standard; (1) Employee training. All employees who are required to wear a respirator, or permitted to wear one voluntarily, will require training, although the training requirements for voluntary users are quite simple and brief. Training for mandatory users is much more comprehensive and frequent. (2) Medical evaluations and approval. All respirator users, both voluntary and mandatory, must be medically cleared for respirator use. (3) Employees who are required to wear a respirator with a tight-fitting facepiece will require annual fit tests to ensure the respirator fits properly.
The fifth, and final requirement is for an ANSI-approved emergency eyewash. Again, Formaldehyde is corrosive and extremely injurious to the eyes and other tissues. An ANSI-358 compliant eyewash must be provided in the immediate work area. This is generally defined as; within 10 feet, on the same level, with no obstructions. There should be no need go up or down stairs, through doors,or navigating around obstructions.
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