OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

March 13, 1998

Mr. G. Curtis Hoskins, MD
Box 140828
Dallas, Texas 75214

Dear Dr. Hoskins:

This is in response to your letter to Mrs. Donna Shalala at the Department of Health and Human Services, dated November 4, 1997. Your letter was forwarded to the Occupational Safety and Health Administration (OSHA) for response. We apologize for the long delay. In your letter you have stated that it is your opinion that the OSHA standard for formaldehyde is "insane" and you believe that your exposure and that of your colleague's to formaldehyde does not pose a risk for cancer.

A brief history of the formaldehyde rulemaking may be helpful in presenting OSHA's position with regard to occupational exposure to formaldehyde. After extensive rulemaking, OSHA issued a comprehensive regulation covering occupational exposure to formaldehyde, 29 CFR 1910.1048. This rule reduced the permissible exposure limits (PELs) to 1 part formaldehyde per million parts of air (ppm) as an 8-hour time-weighted average (TWA) and a short-term exposure limit (STEL) of 2 ppm for a 15 minute time period. The rule was based on a wide range of evidence including animal bioassays and epidemiological evidence. OSHA recognizes formaldehyde as a potential occupational carcinogen. In addition, formaldehyde exposure is regulated for its irritating and sensitizing effects. Following the publication of the final rule, the standard was challenged in the U.S. Court of Appeals by both industry and labor. It was the court's belief that the standard was not set low enough to eliminate risk from employees. In response to the court an amendment to the final rule was issued by OSHA which reduced the permissible exposure limit to 0.75 parts formaldehyde per million parts of air (0.75 ppm) for the 8 hour TWA. There are no current plans to change the formaldehyde standard to increase the permissible exposure limit.

I hope you have found this information useful. Thank you for your interest in occupational safety and health. If you have further questions, please call Ms. Wanda Bissell of my staff at (202) 219-8036, Ext. 41.


John B. Miles, Jr.
Directorate of Compliance Programs