Formaldehyde

EPA finds formaldehyde an ‘unreasonable risk,’ industry says evaluation flawed

By Larry Adams

January 6, 2025 | 7:16 am CST

WASHINGTON, D.C. — The U.S. Environmental Protection Agency (EPA) released Jan. 2 the final risk evaluation for formaldehyde conducted under the Toxic Substances Control Act (TSCA). EPA has determined that formaldehyde presents an unreasonable risk of injury to human health, specifically to workers and consumers, under its conditions of use (COUs).  

The American Chemical Council, on the other hand, said the EPA’s evaluation process was flawed and was not based on the best available science. The ACC warned that the EPA’s Final TSCA Risk Evaluation for Formaldehyde potentially jeopardizes domestic production and critical American industries.

According to the EPA, studies in people demonstrate that exposure to formaldehyde for a short periods, such as for 15 minutes (called an acute exposure) cause sensory irritation such as eye and respiratory inflammation. Sensory irritation effects go away when exposure stops. Inhaling formaldehyde for longer ‘chronic’ periods can reduce lung function and increase asthma and allergy-related conditions, and cancer. Skin contact with products containing formaldehyde can also cause allergic reactions.  Formaldehyde is not expected to persist in water or soils based on its physical and chemical properties; therefore, it is not expected in groundwater or surface water used for drinking water.

EPA’s risk evaluation focused on formaldehyde sources involved in the manufacturing, processing, distribution in commerce, use, and disposal of formaldehyde and formaldehyde-containing products and articles that are subject to TSCA. These may include composite wood furniture or other articles, plastics, paints, adhesives, and sealants. The highest releases of formaldehyde from articles occur when new.

EPA assessed human exposure for 63 TSCA conditions of use of formaldehyde. Of these, 58 conditions of use (50 occupational and 8 consumer) significantly contribute to the unreasonable risk determination. Workers who are in workplaces where formaldehyde is used are at the most risk from formaldehyde exposure, particularly if workers are not wearing personal protective equipment. Workers may be exposed to formaldehyde in air during manufacturing, processing, or use of formaldehyde and products and articles containing formaldehyde. Workers can also be exposed to formaldehyde by making skin contact with formaldehyde-containing materials. Most of the risk to workers is because of acute inhalation and dermal exposures. Cancer risk to workers under many conditions of use also supports the risk determination.

EPA also found some risk from chronic exposure to ambient air for people living near facilities that release formaldehyde. EPA did not determine that ambient air contributes significantly to the unreasonable risk determination.  

Industry objects

The American Chemistry Council’s Formaldehyde Panel issued the following statement on the U.S. Environmental Protection Agency’s (EPA) completion of the final risk evaluation for formaldehyde under the Toxic Substances Control Act (TSCA):

“While ACC acknowledges EPA made several important adjustments in the final risk evaluation, concerns remain about the agency’s continued disregard for statutory requirements on scientific quality, peer reviews, and engagement with public and interagency comments. TSCA requires that EPA reviews and regulates a chemical based on the best available science. This risk evaluation relies on a flawed assessment by EPA’s Integrated Risk Information System (IRIS) program – a program that has never been authorized by Congress, lacks transparency, and is out of step with the best available science and methods. EPA should go back to the scientific drawing board on formaldehyde instead of pursuing unaccountable lame duck actions that threaten the U.S. economy and key sectors that support health, safety and national security.

“Government agencies like Department of Defense, Department of Agriculture, the Centers for Disease Control and Prevention, and the Small Business Administration and EPA-selected expert peer reviewers have raised concerns about the shortened timeline, scientific shortcomings, and potential devastating effects of a flawed TSCA risk evaluation. Ignoring these concerns could result in overly restrictive regulation of this building block chemistry, handicapping America’s economy and creating reliance on overseas production.

“Despite minor improvements, EPA’s final evaluation concludes that virtually all conditions of use contribute to ‘unreasonable risk’ under TSCA. This includes 58 of 63 subcategories of formaldehyde uses, including subjecting all manufacturing, import, processing, distribution in commerce, recycling, disposal, and industrial use of formaldehyde and formaldehyde-derived products to potential bans or difficult-to-meet standards for some uses.

“EPA’s suggested starting place for workplace limits continue to be inconsistent with the best available science and ignore practices that are already in place to protect workers, including the use of personal protective equipment. These workplace limits are significantly lower than the recently updated European Union occupational limits.

“Any assessment of formaldehyde must begin with the best available science. Formaldehyde is a natural part of our world and, through decades of responsible innovation and regulation, is essential to critical applications for housing, agriculture, transportation, healthcare, and national security. Formaldehyde technologies have broad roles in the economy, supporting over 1.5 million jobs and $1.6 trillion in manufacturing shipments and other economic output in 2023 in the United States.

“Effective implementation of the TSCA program has been plagued with challenges, and the final risk evaluation does not meet EPA’s requirement to use the best available science. If EPA continues on its current path during the two-year risk management phase, formaldehyde manufacturing and many of its downstream uses could be severely restricted or potentially banned in the United States.

“Formaldehyde is integral to modern life, and businesses and families rely on the important products it enables. Without robust formaldehyde manufacturing in the United States, we could face increased product prices, reduced economic output, and a loss of the U.S.’s competitive edge. In the coming months, we will collaborate with formaldehyde users to engage the next Administration and safeguard access to this essential chemical building block.”

https://www.woodworkingnetwork.com/news/woodworking-industry-news/epa-finds-formaldehyde-unreasonable-risk-industry-says-evaluation

It’s interesting how the ACC defends formaldehyde and yet promotes MDI for certain end-uses.