NIOSH Hazard Review: Carbonless Copy Paper/Recommendations

6 Recommendations

6.1 Historical Recommendations in the Scientific Literature

The earliest recommendations for eliminating or reducing symptoms associated with CCP exposures originated in Sweden from the National Swedish Board of Occupational Safety and Health [1976]. These recommendations and those that were echoed or expanded by various authors [Andanson et al. 1979; Messite and Fannick 1980; Harris 1983; Messite and Baker 1984], the Danish Branch Safety Council for Offices and Administration [1988], the Cornell University Chemical Hazard Information Program [CHIP 1988], Wattendorf [1988], and Öko-Test Magazin [1990] are enumerated below (not prioritized):

• Ensure adequate environmental conditions (including ventilation, temperature, and humidity control) in office, paper storage, and filing areas.
• Avoid ingesting CCP chemicals by minimizing hand-to-mouth contact.
• Do not rub eyes when handling CCP.
• If symptoms occur, select a CCP with a different composition.
• Substitute a mechanical-type paper (e.g., carbon paper) for a chemical-type paper (i.e., CCP).
• Limit contact with CCP by spreading CCP-related work over a longer period or by reducing the amount used and/or stored in the workspace.
• Employ proper housecleaning and good hand-hygiene procedures (including, occasionally, the use of protective gloves and/or hand creams).
• Inform workers about the symptoms that have been noted by workers who handle CCP.
• If you are a CCP manufacturer or importer, give exact data about the substances used and provide quality certificates for auxiliary substances, additives, and intermediate products used for each lot of CCP.

The Danish Branch Safety Council for Offices and Administration [1988] also recommended use of the following checklist to evaluate complaints received when working with CCP:

• Why do you think that the discomforts can be traced to CCP work?
• How many persons suffer discomfort in connection with work using this kind of paper?
• Who suffers from the discomforts?
• Have there been complaints in connection with work with CCP?
• Has the paper quality been recently changed or has a new delivery of CCP been made?
• Have any of the following discomforts developed: —Irritation of mouth, eyes, nose, or throat —Skin problems of the face, hands, or arms —Headache, vertigo, or exhaustion
• How long have the person(s) affected suffered from the symptoms?
• Do the symptoms disappear during weekends and/ or vacations?
• Do the symptoms develop especially in certain departments or at some special function?
• How much CCP is handled, separately or in total?
• Does the consumption of CCP vary during the course of a month?
• Is there any connection between the amounts of CCP and the complaints?
• How long have you worked with the CCP that you believe to be the cause of your symptoms?
• Have similar symptoms occurred among fellow workers who do not work with CCP?
• Is the indoor climate (temperature, relative humidity, quality of the air, etc.) satisfactory?
• What is the extent of cleaning?
• Who produces the CCP?
• Who prints the CCP?
• Have the symptoms following work with CCP been reported?

6.2 NIOSH Recommendations

NIOSH recognizes that it may occasionally be necessary to limit CCP exposure in certain workers through administrative controls (such as job rotation). But in most cases, implementing normal precautions and recommendations for maintaining acceptable indoor air quality should be adequate to reduce or eliminate symptoms. Good industrial hygiene and work practices are likely to prevent symptoms from potent irritants (such as formaldehyde) that may be emitted from CCP. These include adequate ventilation, humidity, and temperature controls; proper housekeeping; minimal hand-to-mouth and hand-to-eye contact; and periodic cleansing of hands.

In addition, NIOSH recommends the following:

• CCP manufacturers and their suppliers are encouraged to follow best practices, such as the Product Stewardship Code of Management Practices [American Chemistry Council 2000]; they should also consider enhancing their product guidance to reflect that published studies indicate that irritative symptoms appear to increase with increasing exposure to CCP.
• CCP manufacturers and their suppliers should also consider how human test procedures (e.g., RIPT) can be modified by the use of standardized protocols that include proper controls (e.g., bond paper), tests that mimic high-use situations, and meaningful criteria for scoring and interpreting these tests to assess safety from skin contact (e.g., ASTM D 6355–98) [ASTM 1999]. Current best practices in the field of product testing may not be sensitive enough to identify mild skin irritants.
• As part of ongoing surveillance, CCP manufacturers and their suppliers may want to evaluate the frequency and severity of irritation in workers using CCP.