EPA’s Formaldehyde Regs: No Need To Rush Into
Story by Rich Donnell,
The latest development in EPA’s proposed formaldehyde regulations is that Composite Panel Assn. and the Federal Wood Industry Coalition filed a petition with the EPA asking for an extension of the public comment time beyond what EPA had granted, due to the complexity of the proposed rules.
EPA’s proposed rules fundamentally align with the requirements for composite wood products set by the California Air Resources Board (CARB), putting in place national standards for companies that manufacture or import hardwood plywood, MDF and particleboard. EPA’s proposals also encourage switching to no-added formaldehyde resins.
Some of the concerns on industry’s part include the disclosure of confidential business information, the handling of non-complying lots, definitions of hardboard and laminated products for purposes of exemption, treatment of ULEF and NAF, and various obligations of third party certifiers.
CPA has favored national standards to level the playing field, but if it needs more time, so be it. After all, the formaldehyde emissions issue has been with us for more than three decades, and even longer if you go back to the early 1970s; that’s when the technical director of National Particleboard Assn. (which became CPA) called up the NPA legal counsel and said somebody had raised the question about whether the off-gassing of formaldehyde was something individual companies should be concerned about because it might violate the federal law that prohibited shipment of chemicals or items that might cause chemical-related problems. NPA chose to send out a notice to its member companies giving them a heads-up.
The issue really took hold in the late 1970s, when some manufactured home occupants complained about irritation; also, a study by the Chemical Industry Institute of Technology found high levels of inhaled formaldehyde (15.0 ppm-parts per million) for a two-year period caused nasal cancer in lab rates; and Consumer Products Commission investigated a few installation problems with urea formaldehyde foam insulation in retrofit projects in older homes, generating widespread media coverage.
As CPA is today, it was then highly proactive along with the adhesive suppliers, and by the mid 1980s product emissions had been reduced by more than 75%.
EPA first jumped into the fray in 1983, looking at worst-case scenarios and suggesting home occupants could develop cancer, though numerous independent studies kept indicating such evidence was lacking.
In the mid 1990s, NPA even put up nearly a half million dollars toward the construction of a test home, and the ensuing studies showed formaldehyde levels lower than what the EPA models had predicted. In the test house as a whole, formaldehyde concentrations did not exceed .070 ppm, and the highest level was .076 ppm in the kitchen.
Today’s CARB regulations and those proposed by EPA call for 0.09 ppm for particleboard, 0.11 for MDF and 0.13 for thin MDF, as well as 0.05 ppm for hardwood plywood with veneer or composite core. EPA should thank the composite board industry for its amazing accomplishments.