April 4, 2017
This month I have invited Dr. Kimberly White, Senior Director, Chemical Products and Technology Division of the American Chemistry Council (ACC) and representative of the ACC Formaldehyde Panel, to update us on recent formaldehyde activities and challenges ahead in the United States.
The ACC Formaldehyde Panel represents producers, suppliers and users of formaldehyde and formaldehyde products, as well as trade associations representing key formaldehyde applications. The primary activities of the ACC Formaldehyde Panel include scientific research, regulatory and legislative advocacy, and outreach.
Dr. Kimberly White
ACC Formaldehyde Panel
As Kimberly explains…
“2016 was a pivotal time for formaldehyde makers and users as the U.S Congress passed the Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA), which comprehensively updated the Toxic Substances Control Act, the primary U.S. law regulating chemicals in commerce. Under the LCSA, the U.S. Environmental Protection Agency (EPA) is charged with developing the rules and procedures it will use to prioritize, evaluate and manage all chemicals in commerce. In addition to this monumental update to chemical regulations, the EPA also finalized national standards for formaldehyde emissions from composite wood products. As the second quarter of 2017 begins, we continue to prepare for more chemical assessment activity, including an update of occupational threshold limit values for formaldehyde by the American Conference of Governmental Industrial Hygienists (ACGIH). We also anticipate activity by the EPA on its revised draft Integrated Risk Information System (IRIS) human health assessment of formaldehyde.
COMPOSITE WOOD RULE
In 2016, EPA nationalized standards for formaldehyde emissions from composite wood products. The products covered by the rule include hardwood plywood, medium-density fiberboard and particleboard as well as household and other finished goods containing these products. The EPA’s regulation requires that composite wood products sold, supplied, offered for sale, manufactured, or imported in the U.S. be labeled as TSCA Title VI compliant. The regulation also includes provisions for product testing, labeling, recordkeeping, and third-party certification. These standards take effect in March 2017, with compliance with many provisions required by December 2017. While the finalization of these standards is a positive step in ensuring consistent US emission standards for composite wood products, there is still work to be done to ensure the rule applies consistent criteria for formaldehyde-based and no-added-formaldehyde-based resins according to the best available science and technological information.
In the fall of 2017, EPA may release its revised draft IRIS assessment of formaldehyde. U.S. federal and state regulatory decision-makers rely heavily on EPA’s IRIS values to develop emission limits, clean-up standards and human health exposure values. EPA’s previous draft IRIS assessment was highly criticized by the National Academy of Sciences (NAS), a well-respected scientific institution in the U.S. As such, a key focus of the ACC Formaldehyde Panel’s activities has been to generate new information to help fill data gaps, clarify interpretive ambiguities, and address scientific deficiencies identified by the NAS. This has included the re-analysis of underlying data from two pivotal studies used by EPA in its previous draft IRIS assessment. The most recent re-analysis, published in 2017, calls into question previous conclusions that occupational exposure to formaldehyde causes chromosomal abnormalities and increases the chance of leukemia. This new research and other science published over the past several years challenges the previous IRIS assessments classifications.
OCCUPATIONAL THRESHOLD LIMIT VALUES
In March 2017, ACGIH finalized the adoption of lower threshold limit values (TLV) for occupational exposure to formaldehyde. The levels are 0.1 ppm for 8-hour time-weighted average TLV and 0.3 ppm for Short Term Exposure Limit.
Considerable work remains ahead of us in 2017 and we believe these challenges can best be addressed through sound fact-based science, effective advocacy, and clear communication with regulators policymakers, and the stakeholder community.”
Formacare and the ACC regularly discuss and share our communications and science programmes. While the regulations are different in the US, the science, of course, is the same, and we continue to identify, and where appropriate jointly fund, key scientific projects yielding benefits to both parties.