Ref: AFAC Industry Safety Advice – 23 February, 2015 (the complete document can be downloaded using the pdf link below)
A group of SA Country Fire Service (CFS) volunteers who are Work Health and Safety (WHS) representatives prepared a discussion paper in February 2014, that raised concerns about the possible levels of contamination found in wildland personal protective clothing (PPC).
The CFS brought the issue to the attention of AFAC Council, as there are potential national implications, particularly if a problem was determined to exist. The AFAC Board subsequently approved funding for independent testing to be undertaken by the CSIRO to ascertain if there is an issue.
Issue 1 – Release of formaldehyde from PROBAN® treated fabric into the atmosphere.
- Breathing formaldehyde vapours can result in irritation of the nerves in the eyes and nose, which may cause burning, stinging or itching sensations, a sore throat, teary eyes, blocked sinuses, runny nose and sneezing. These symptoms are often experienced when smoke is encountered and can be caused by a range of substances.
- A test conducted by the CSIRO using an in-house process was designed to simulate the storage of a uniform in an enclosed space. This test indicated that after twenty-four hours of storage in a confined space the levels of formaldehyde emitted were found to be of concern with six of the seven samples, including the control sample, exceeding the allowable time weighted average, (TWA), exposure level of 1ppm with three of those samples also exceeding the allowable short term exposure level, (STEL), of 2ppm.
- The testing undertaken whilst reflecting exposure of PPC being removed from a kit-bag does not reflect exposures likely to be experienced by personnel wearing the garments. Safe Work Australia Guideline limits (TWA & STEL) are based on ambient air concentrations as opposed to the static area sampling used by CSIRO which is not acceptable for determining compliance with exposure standards.
A Bushfire CRC research program identifying air toxins in bushfire smoke took readings of air toxins via a monitor worn on PPC. This testing was undertaken in accordance with Safe Work Australia Guidelines. A review of this research indicates extremely low levels of formaldehyde exposure whilst wearing PROBAN® treated garments.
- Agencies advise members of the dangers of breathing in fumes that are emitted from PROBAN® treated PPC that has been stored in a confined space, e.g. a kit bag. Wherever possible, PROBAN® treated PPC should be stored in a well-ventilated environment but if this is not possible precautions should be taken to avoid breathing in the fumes (gases) emitted when opening the confined space.
- Wherever PROBAN® treated PPC is stored in a sealed or confined space, ensure that it is opened in a well-ventilated area and allow a short time to pass before removing.
Issue 2 –Formaldehyde in the fabric
- Formaldehyde is a potential skin irritant and skin sensitizer.
- Skin contact with formaldehyde can cause skin rashes and allergic skin reactions. The levels of exposure which may cause these allergic reactions will vary significantly between individuals.
- There is no legal limit on the level of formaldehyde permitted in textiles within Australia but the Australian Competition & Consumer Commission, (ACCC), has adopted an interim reference figure of 100 parts per million, (ppm), for garments contacting the skin and 300ppm for other garments and fabrics.
- A test conducted by the CSIRO using an internationally recognised testing process, (ISO14184-1) was used to determine what formaldehyde existed in the fabric.
- The highest concentration of formaldehyde detected was 300ppm which was found in the control garment. The remaining six garments had readings ranging from 66ppm to 280ppm.
- In most instances the level of concentration of formaldehyde dropped significantly after washing with the control sample dropping from 300ppm to 130ppm. The remaining six garments had readings from 64ppm to 150ppm.
- Agencies instruct personnel to wash separately PROBAN® treated cotton garments before they are worn for the first time and after each use.
- Agencies advise members that direct skin contact with PROBAN® treated PPC may cause skin irritation. The known incidence of skin irritation time (over 30 years) that PROBAN® treated cotton has been used in Australia is minimal. Where there is evidence that skin irritation is occurring when a PROBAN® treated over-garment is being worn, individuals should wear long sleeve shirts and long pants underneath these garments.
Issue 3 – Accumulation of respirable particles
- Safe Work Australia has issued limits on respirable limits for six specific substances which are quartz, cristabolite, tridymite, fumed silica, coal dust and soapstone. Where no specific standard applies and the substance is inherently low toxicity and free from toxic impurities dust exposure should be maintained below 10mg/m3 over an 8 hour TWA.
- CSIRO used an in in house “beating test” described as the equivalent of shaking a garment to determine particulate content. Airborne concentrations were then calculated.
- Two garments, one of which was the control garment did not release any particulates of concern. Only one of the five remaining garments which came in at 11mg/m3 exceeded the 8 hour TWA.
- Agencies instruct personnel not to shake firefighting garments as a means of removing dust and particulates before washing.
- Agencies instruct personnel to wash separately PROBAN® treated cotton garments after each use so as to minimise the amount of dust and particulate matter trapped in uniforms.
PROBAN® treated cotton has been in use by Australian emergency services agencies for in excess of thirty years without any significant issues or concerns being identified. The Australian Firefighters’ Health study provides some reassurance that records indicate the incidence of cancers associated with formaldehyde are not elevated for Australian firefighters.
What the testing conducted by the CSIRO has done is raise concerns about how the PPE is stored and handled. The unexpected issue is the amount of formaldehyde both retained and given-off by the PROBAN® treated cotton which is at levels outside the product manufacturers stated release levels. This warrants further investigation. AFAC will pursue this through the engagement of the AFAC PPE Technical Group.
Each agency will need to make its own assessment however the AFAC review team is of the view that making users aware of the need to adopt appropriate handling and laundering procedures will address the issues raised in the CSIRO report.
RFS response to the AFAC Industry Safety Advice.
The RFS issued a Health and Safety Alert on 26 February 2015.
PROBAN® treated fabrics used by the NSW RFS, including PPC are tested and certified according to Oeko-Tex Standard 100. This certification demonstrates associated products satisfy the human-ecological requirements of the standard for products with direct contact to skin.
It should also be noted that the Australian Firefighters Health Study recently conducted by Monash University examined cancer and causes of death amongst 232,871 current and former career and volunteer firefighters. The study found there are no statistically significant elevated incident rates of cancers linked to formaldehyde compared to incident rates in the general Australian population.
The NSW RFS and AFAC member agencies participated in a National teleconference this afternoon to discuss the safety advice. A National meeting of AFAC member Health Safety and Welfare and PPE specialist personnel will be convened early next week to explore in greater detail the research and analysis associated with the AFAC safety advice as well as implications for the industry and its members. NSW RFS will provide further information as it becomes available.
Until further notice, NSW RFS members should follow the AFAC recommendations contained in the attached Industry Safety Advice.
You can download the RFS Health and Safety Alert using the pdf link (below)