Formaldehyde

August 21, 2026 RE: Comments on the proposed rule on Formaldehyde To: Occupational Safety and Health Administration The American Industrial Hygiene Association (AIHA) Respiratory Protection Committee agrees with OSHA's proposal of removing provisions of OSHA's Formaldehyde standard (29 CFR 1910.1048) that are duplicative with the requirements of the Respiratory Protection standard, which is consistent with OSHA's intent, when it published the revised Respiratory Protection standard (29 CFR 1910.134), to use it as a foundation for respirator selection in substance-specific standards. The OSHA formaldehyde regulation 29 CFR 1910.1048 contains the following: 1910.1048(g)(2)(ii) "When employees use air-purifying respirators with chemical cartridges or canisters that do not contain end-of-service-life indicators approved by the National Institute for Occupational Safety and Health, employers must replace these cartridges or canisters as specified by paragraphs (d)(3)(iii)(B)(1) and (B)(2) of 29 CFR 1910.134, or at the end of the work shift, whichever condition occurs first." The OSHA Respiratory Protection regulation 29 CFR 1910.134 contains the following: 1910.134(d)(3)(iii)(B)(2) "If there is no ESLI appropriate for conditions in the employer's workplace, the employer implements a change schedule for canisters and cartridges that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life. The employer shall describe in the respirator program the information and data relied upon and the basis for the canister and cartridge change schedule and the basis for reliance on the data." Cross-referencing 29 CFR 1910.134(a)(2) in 1910.1048(g)(1) correctly captures all the material that was previously specified in paragraphs (g)(1)(i) (iv) of 1910.1048. As a real-life example, based on the conditions of temperature, humidity, and formaldehyde levels expected in a member's facility, formaldehyde cartridge respirator change schedules were created for several air-purifying respirators based on service life calculators provided by manufacturers. The results for projected service life for expected formaldehyde exposure conditions and selected respirators ranged from 25 hours to more than 100 hours. If our members were to follow 29 CFR 1910.1048, they would need to install a new formaldehyde respirator cartridge after each work shift. On the other hand, based on expected conditions and respirators selected, if they were to follow 29 CFR 1910.134, they would be changing formaldehyde respirator cartridges only every 3-12 (or more work) shifts and would not decrease worker safety. Since air-purifying respirator cartridges are expensive, it presents a significant burden to employers to purchase new formaldehyde respirator cartridges for each shift when a change is technically necessary only every 3rd or 12th shift. In addition, it would reduce used respirator cartridge waste. Technology is always advancing, and it appears that 29 CFR 1048 may have been written at a time when respirator cartridges were less capable than they are today. 29 CFR 1910.134 seems to be a more performance-based rule that allows employers to better adapt to ongoing improvements in respirator technology. Thank you for considering AIHA's comments. Sincerely, Jeremy Robinson Senior Manager, Government Relations American Industrial Hygiene Association