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 25, 1998

Ryan Hopper
457 East 800 North
Logan, UT 84321

Dear Mr. Hopper:

This is in response to the letter you sent President Clinton by electronic mail on August 9, 1997, concerning regulations issued by the Occupational Safety and Health Administration (OSHA) that affect embalming conducted by funeral homes.

There is an OSHA formaldehyde standard, 29 CFR 1910.1048, that applies to formaldehyde exposures employees receive due to embalming conducted by funeral homes as well as to all other occupational exposures to formaldehyde. Your description of the protective clothing required by the standard seems inaccurate. We have enclosed a copy of the formaldehyde standard's requirements for protective clothing and equipment for your review. Please note the conditions requiring full body protection are either: (1) The formaldehyde air concentration exceeds 100 ppm; or (2) an emergency reentry is being made into an area of unknown formaldehyde air concentration. Please refer to (h)(1)(iv) of the enclosure.

The purpose of the protective equipment and clothing provisions presented at 29 CFR 1910.1048(h) is to afford employees eye and skin protection. The severity of reactions to eye contact with formaldehyde solutions depends on the concentration of formaldehyde in solution and the amount of time lapsed before emergency and medical intervention. Concentrations of formaldehyde between 0.05 ppm and 0.5 ppm produce a sensation of irritation in the eyes with burning, itching, redness, and tearing. Increased rate of blinking and eye closure generally protects the eye from damage at these low levels, but these protective mechanisms may interfere with some workers' work abilities. Tolerance can occur in workers continuously exposed to concentrations of formaldehyde in this range. Accidental splashing of human eyes with aqueous solutions of 37 percent formaldehyde (formalin) has produced a wide range of ocular injuries including corneal opacities and blindness.

Skin contact with formaldehyde solutions can cause irritation of the skin and allergic contact dermatitis. These skin diseases and disorders can occur at levels well below those encountered by many formaldehyde workers. Symptoms include erythema, edema, and vesiculation or hives. Exposure to liquid formalin or formaldehyde vapor can provoke skin reactions in sensitized individuals even when airborne concentrations of formaldehyde are well below 1 ppm.

We appreciate the opportunity to provide you with this information. Should you have further questions, please contact the Office of Health Compliance Assistance at (202) 219-8036.


John B. Miles, Jr.
Directorate of Compliance Programs