Department of Homeland Security

Office of Inspector General 

FEMA Response to Formaldehyde in Trailers 


(Redacted)
 

Notice: The Department of Homeland Security, Office of the Inspector General, has redacted this report for 

public release. 

OIG-09-83 June 2009 
 

Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 25028 

June 26, 2009 

Preface 

The Department of Homeland Security Office of Inspector General was established by 

the Homeland Security Act of 2002 (Public Law 107-296) by amendment to the Inspector 

General Act of 1978. This is one of a series of audit, inspection, and special reports 

prepared as part of our oversight responsibilities to promote economy, efficiency, and 

effectiveness within the department. 

This report addresses the strengths and weaknesses of the Federal Emergency 

Management Agency’s decision making, policy, and procedures related to the issue of 

formaldehyde in trailers purchased by the agency to house victims of the 2005 Gulf Coast 

hurricanes. It is based on interviews with employees and officials of relevant agencies 

and institutions, direct observations, and a review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust that this report will result in more effective, efficient, and economical operations. 

We express our appreciation to all of those who contributed to the preparation of this 

report. 

Richard L. Skinner 


Inspector General 

10 

20 

30 

40 

50 

Table of Contents/Abbreviations 


EXECUTIVE SUMMARY ................................................................................... 1
 

INTRODUCTION AND BACKGROUND............................................................... 4
 

FEMA Trailers................................................................................................................ 5 


Formaldehyde ................................................................................................................. 7 


Effects of Formaldehyde................................................................................................. 9 


Formaldehyde Standards...............................................................................................
 

CAUSES OF FORMALDEHYDE PROBLEMS IN FEMA TRAILERS .................. 12
 

Conclusions................................................................................................................... 14
 

Recommendations......................................................................................................... 14 


FEMA RESPONSES TO THE DEVELOPING FORMALDEHYDE PROBLEM ..... 15
 

Early Indications of Formaldehyde Problems............................................................... 15 


FEMA Officials’ Reactions to the Formaldehyde Issue ............................................... 16 


FEMA Policies on Addressing Formaldehyde Problem Cases.....................................
 

FEMA Efforts to Assist Trailer Residents With Formaldehyde Complaints ............... 23 


Effects of FEMA’s Initial Responses to Formaldehyde ............................................... 25 


Conclusions................................................................................................................... 26
 

Recommendations......................................................................................................... 26 


FORMALDEHYDE TESTING EFFORT FOR UNOCCUPIED TRAILERS ............. 27
 

Initiation of a FEMA Formaldehyde Testing Program................................................. 27 


Analysis of Formaldehyde Tests of Unoccupied Units ................................................
 

Recommendation ..........................................................................................................
 

Conduct of Testing of Unoccupied Units ..................................................................... 29 


Problems With the Initial Analysis Report ................................................................... 31 


Role of the FEMA Attorney in the Formaldehyde Testing Program............................ 33 


Effects of the FEMA Attorney’s Role in the Program ................................................. 35 


Effects of Testing Unoccupied Units Rather Than Occupied Units............................. 36 


Causes of the Manner in Which the Testing Program Was Managed .......................... 36 


Conclusions................................................................................................................... 39
 

FORMALDEHYDE TESTING EFFORT FOR OCCUPIED TRAILERS.................. 41
 

Initiation of the Testing Program for Occupied Trailers .............................................. 41 


FEMA Delays in Obtaining Testing Assistance From CDC ........................................ 44 


Testing Program for Occupied Trailers Commences.................................................... 46 


FEMA Officials Stop the Testing Program for Occupied Trailers............................... 46 


Testing Effort for Occupied Trailers Gets Completed..................................................
 

Causes of Delay in the Testing Effort for Occupied Units ........................................... 54 


Conclusions................................................................................................................... 57
 

Recommendations......................................................................................................... 58 

Table of Contents/Abbreviations 


EPILOGUE – ACTIONS AND EFFORTS RELATED TO FORMALDEHYDE IN 

TRAILERS AFTER THE FEBRUARY 14, 2008, NEWS CONFERENCE.............. 59 

Conclusions................................................................................................................... 62
 

MANAGEMENT COMMENTS AND OIG ANALYSIS ........................................ 63
 

APPENDIX A: PURPOSE, SCOPE, AND METHODOLOGY.........................64 

APPENDIX B: TIMELINE OF KEY EVENTS............................................66 

APPENDIX C: CONSOLIDATED LIST OF RECOMMENDATIONS ..............71 

APPENDIX D: MANAGEMENT COMMENTS TO THE DRAFT REPORT......73 

APPENDIX E: REPORT DISTRIBUTION..................................................78 

APPENDIX F: OIG CONTRIBUTORS......................................................79 

Abbreviations 

ASHRAE American Society of Heating, Refrigerating and Air-Conditioning 

Engineers 

ATSDR Agency for Toxic Substances and Disease Registry 

CDC Centers for Disease Control and Prevention 

CFO Chief Financial Officer 

CMO Chief Medical Officer 

COTR Contracting Officer’s Technical Representative 

DHS Department of Homeland Security 

DOJ Department of Justice 

EA External Affairs 

EPA Environmental Protection Agency 

FCO Federal Coordinating Officer 

FEMA Federal Emergency Management Agency 

FOIA Freedom of Information Act 

HHS Department of Health and Human Services 

HUD Department of Housing and Urban Development 

IAA interagency agreement 

IARC International Agency for Research on Cancer 

JFO Joint Field Office 

KO Contracting Officer (more commonly abbreviated as CO) 

MH mobile home (or manufactured housing) 

MHOPS Mobile Homes Operations 

NASA National Aeronautics and Space Administration 

NIOSH National Institute for Occupational Safety and Health 

OCC Office of Chief Counsel (FEMA) 

OGCR Office of Gulf Coast Recovery 

OHA Office of Health Affairs (DHS) 

OSHA Occupational Safety and Health Administration 
Table of Contents/Abbreviations 


ppb 

ppm 

QA 

QC 

RVIA 

SOW 

STEL 

THU 

TRO 

TT 

TWA 

USPHS 

VOC 

parts per billion 

parts per million 

quality assurance 

quality control 

Recreation Vehicle Industry Association 

Statement of Work 

Short-Term Exposure Limit 

temporary housing unit 

Transitional Recovery Office 

travel trailer 

Time-Weighted Average 

United States Public Health Service 

volatile organic compound 
OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

Nearly one-third of the trailers provided to victims of hurricanes 

Katrina and Rita were eventually projected to have significant 

potential formaldehyde problems. Federal Emergency 

Management Agency (FEMA) officials, in our opinion, did not 

take sufficiently prompt and effective action to determine the 

extent of the formaldehyde problem in the emergency housing 

units once they were aware that such a problem might exist. 

FEMA officials let nearly a year pass while working with other 

agencies to analyze which of two methods for reducing 

formaldehyde levels in never-occupied units was most effective. 

At the end of that year, they had learned that ventilation was more 

effective than temperature control at reducing formaldehyde levels, 

but that both were effective – information that was already widely 

known, including by FEMA officials, before the study began. 

The FEMA study of unoccupied units not only failed to address the 

occupied units that were of most concern, but its results were not 

fully disclosed. Although FEMA subsequently arranged for the 

Centers for Disease Control and Prevention (CDC) to perform a 

study of formaldehyde levels in occupied trailers, FEMA caused 

delays that blocked the study’s progress on two occasions. In 

general, in our opinion, FEMA did not display a degree of urgency 

in reacting to the reported formaldehyde problem, a problem that 

could pose a significant health risk to people who were relying on 

FEMA’s programs. 

Furthermore, FEMA did not have a formal policy or procedure to 

deal with resident complaints about health problems caused by 

formaldehyde in trailers. This caused confusion and 

inconsistencies in the manner in which complaints were treated. 

In the absence of a formal policy, an informal policy of providing 

used trailers to those who complained evolved. However, without 

an effective testing program, the needs of occupants who were 

FEMA Responses to Formaldehyde in Trailers 

Page 1 
reluctant to complain would not surface. Also, without test results 

indicating which type of trailer was lowest in formaldehyde, 

FEMA could inadvertently replace one problematic trailer with 

another problematic unit. Had FEMA known the details that a 

study of formaldehyde in occupied units would have produced, 

they could have opted to replace all high-formaldehyde-emitting 

units with better types of units (park models, mobile homes, or 

travel trailers from better-performing manufacturers). 

As shown in the following timeline, information concerning the 

extent of formaldehyde in occupied FEMA units was not available 

until February 2008, more than 2 years after many of the affected 

residents moved into FEMA housing units. Effective action to 

obtain such information commenced only after the media reaction 

to formaldehyde in FEMA trailers grew to disturbing levels, 

causing senior DHS management to involve the medical 

professionals of DHS’ Office of Health Affairs (OHA) and the 

CDC. Unfortunately, delays in producing a necessary authorizing 

letter and the lack of existing agreements between FEMA and the 

CDC resulted in more than 6 months of negotiations and 

preparations before a study could be undertaken. Moreover, just as 

the CDC contractor was about to start testing the trailers, FEMA 

became concerned that it did not have a public communications 

strategy for the Congress, media, and trailer occupants once the 

study results were announced. Instead of addressing this issue 

while the study was being conducted, FEMA officials had CDC 

stop the contract before testing began. This caused another 2­

month delay. The formaldehyde testing was finally conducted in 

late December 2007 and early January 2008. Because of the 

delays, the test results may have underestimated the extent of 

formaldehyde exposure that residents had experienced in the 

trailers. Most of the units were 2 years old by the time of the 

testing, and the testing was conducted during the winter months 

when formaldehyde levels are lowest. 

FEMA Responses to Formaldehyde in Trailers 

Page 2 
Since the results of the formaldehyde testing were announced, 

FEMA officials have continued their efforts to develop safer 

emergency housing. Also, FEMA and CDC have promoted 

ongoing efforts to address the causes and effects of excessive 

formaldehyde in trailers. 

For the future, FEMA needs to: (1) design and implement better 

policies and procedures for identifying and correcting health and 

safety issues as they develop; (2) ensure management officials 

properly coordinate with professional staff and have access to 

relevant information; (3) establish agreements to obtain needed 

medical advice and testing and analysis assistance for health and 

safety problems; and, (4) establish policies that require and enable 

responsible FEMA officials to address health and safety issues in a 

timely manner. 

FEMA Responses to Formaldehyde in Trailers 

Page 3 
Introduction and Background 


On February 14, 2008, approximately 29 months after Hurricane Katrina victims 

were first placed in FEMA trailers, the FEMA Administrator and the CDC 

Director held a joint press conference to announce the preliminary results of 

FEMA-sponsored CDC testing of FEMA travel trailers and mobile homes in 

Louisiana and Mississippi. At that conference, the CDC Director stated they had 

found approximately one-third of the housing units had formaldehyde levels that 

could cause irritation and symptoms such as runny nose, cough, or even breathing 

problems for those residents who were vulnerable to formaldehyde, such as very 

young children, older people, or individuals who already had airway diseases. 

Furthermore, formaldehyde levels in around 5% of the FEMA units were so high 

that even residents without such vulnerabilities could experience formaldehyderelated respiratory symptoms. The FEMA Administrator then announced: 

“As a result of these preliminary findings, FEMA is going to continue 

our aggressive action to provide for the safety and well-being of the 

residents of these travel trailers by finding alternative housing.” 

In addition, in response to a question about future emergency housing plans, he 

stated: 

“We will not ever use trailers again. We may use mobile homes...But we 

will not use trailers again.” 

The CDC study, which was released in its final version on July 2, 2008, found 

that while travel trailers generally had significantly higher average formaldehyde 

levels than park models and mobile homes, some units of all three types of 

emergency housing tested at more than 100 parts per billion (ppb) of 

formaldehyde, and the overall mean for the units tested was 77 ppb. The study 

noted that formaldehyde readings tend to decrease as a trailer ages and be higher 

during warmer weather. As a result, the CDC study’s results–which were 

measured during the winter and after the trailers had been lived in for about 2 

years–may under-represent the long-term exposure levels of FEMA trailer 

residents. The report concluded: 

“On the basis of the data reported here and in previous scientific reports 

and publications about adverse health effects associated with exposure to 

elevated formaldehyde levels, CDC recommended that FEMA relocate 

Gulf Coast residents displaced by hurricanes Katrina and Rita and still 

living in trailers.” 

FEMA Responses to Formaldehyde in Trailers 

Page 4 
A FEMA Trailer Group Site 

FEMA Trailers 

As a result of hurricanes Katrina and Rita, which struck the Gulf Coast in 

late August and September 2005, more than 300,000 homes were 

destroyed and approximately 700,000 people were displaced. Some of the 

displaced were able to move back into residences after minor repairs. 

Many others returned to find homes and apartments that had been 

obliterated or severely damaged by wind and water, which would require 

months to repair. FEMA immediately began moving emergency housing 

of shelters and into 

trailers that were 

located either on 

homeowners’ lots or 

in FEMA group 

sites or commercial 

“trailer parks” for 

many former 

renters. Some 

homeowners 

relocated to the 

group sites and 

commercial trailer 

parks, just as some 

former renters 

relocated in FEMA trailers placed on private land that they or others 

owned. Meeting the needs of the displaced Gulf Coast residents was a 

massive task. FEMA used most of its existing usable inventory of 

housing, purchased existing unused trailers from dealers throughout a 

large part of the country, and contracted for the construction of new units 

to be built to FEMA specifications. The first FEMA trailers were moved 

into the Gulf Coast region on September 3, 2005, and the first unit was 

occupied on September 10, 2005. By August 2006, FEMA had procured 

approximately 144,000 travel trailers, park models, and mobile homes. 

Combining these with prior purchases, FEMA had about 203,000 units in 

its inventory, most of which were used in the Gulf Coast states. 

units into the Gulf 

Coast states to allow 

individuals and 

families to move out 

FEMA Responses to Formaldehyde in Trailers 

Page 5 
FEMA had three basic emergency housing unit types (referred to, in the 

aggregate, as “trailers” for the purposes of this report) for the victims of 

hurricanes Katrina and Rita: 

Mobile Homes (MH) These are more formally called “manufactured housing,” 

but will be referred to as mobile homes throughout this 

report to avoid confusion with other types of housing that 

are manufactured in factories. The mobile homes are 

wider than 8 feet or longer than 40 feet for a total area of 

more than 320 square feet. FEMA mobile homes are 

typically 14 x 60 feet, a total of 840 square feet, and have 

three bedrooms. Mobile homes are designed as permanent 

housing and are regulated by the U.S. Department of 

Housing and Urban Development (HUD). 

Travel Trailers (TT) 

These are trailers designed to provide temporary living 

quarters for recreational purposes. They have size limits, 

such as 8 feet wide and up to 35 feet long, or 280 square 

FEMA-spec (government contract) travel 

trailer 

feet, and are designed to be towed by a private vehicle. 

Travel trailers are considered vehicles rather than 

residences, are usually regulated by state transportation 

authorities, and therefore do not fall under HUD 

regulations. FEMA travel trailers typically have one 

bedroom and a small sleeping alcove. 

Off the Lot (commercial) travel trailer 

Park Models 

These are in-between travel trailers and mobile homes in 

character. They are generally more than 320 square feet. 

They may be regulated by state transportation authorities, 

but are not governed by HUD standards. FEMA Park 

Models are typically 12 x 36 feet, a total of 432 square 

feet, and have two bedrooms. 

FEMA Responses to Formaldehyde in Trailers 


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Formaldehyde 

Formaldehyde (H2CO) can be a health problem in 

some trailers and also has been found to be a 

problem in other types of residences. 

Formaldehyde is a colorless strong-smelling gas 

that is found in nature and is even produced in 

small amounts by the human body as a normal part 

of metabolism. It is also an important and widely 

used industrial chemical in the production of fertilizer, some paper 

products, plywood, and a variety of household items including permanent 

press fabrics, some household cleaners, and cosmetics. Gas cookers and 

open fireplaces produce formaldehyde, as does cooking fish and, 

especially, smoking. Most people are exposed to a major source of 

formaldehyde in the air pollutants we breathe, with automobile exhaust 

being a primary source. 

Many building products that contain formaldehyde resins can “off-gas” 

(emit) formaldehyde gas for years, although the off-gassing decreases over 

time. Building materials that can produce formaldehyde include 

particleboard used as subflooring or shelving, fiberboard used in cabinets 

and furniture, and plywood wall panels. Some types of urea formaldehyde 

foam insulation, which are now seldom used, are heavy emitters of 

formaldehyde. Trailers, especially new units, can expose people to higher 

levels of formaldehyde, because formaldehyde gas is emitted by some of 

the materials used in these units and some trailers have less effective 

ventilation and air-exchange systems than conventional homes. In 1984, 

HUD instituted limits on the formaldehyde off-gassing that is permitted in 

materials used in mobile homes. The goal at the time was to have mobile 

homes with formaldehyde levels that were less than 400 ppb resulting 

from these restrictions. HUD restrictions on mobile homes do not apply to 

the manufacture of travel trailers and park models, but some 

manufacturers of such units have said that they follow the HUD standard 

for materials in constructing their units. It has long been recognized that 

higher concentrations of formaldehyde emissions occur in residences that 

have relatively stagnant air, high temperatures, or high humidity. 

Past studies by the CDC and others have shown that people encounter a 

wide range of formaldehyde levels and exposure. In an outdoor rural 

setting, an individual might be exposed to no more than .2 ppb of 

formaldehyde. This rises to 2–6 ppb in suburban outside air, and an 

individual who lives in a heavily populated area or near industries can be 

faced with outside air having 10–20 ppb formaldehyde. Outside air in the 

FEMA Responses to Formaldehyde in Trailers 

Page 7 
vicinity of a traffic jam can have levels of formaldehyde exceeding 50 

ppb. Because formaldehyde is released from many home components and 

home products, there is usually more formaldehyde present indoors than 

outdoors. However as the following table shows, concentrations of 

formaldehyde also vary widely in indoor air.

 Past Formaldehyde Findings in Housing Studies 

Year Housing Studied Average 

(ppb) 

High 

(ppb) 

1985 Conventional homes 40 140 

1985 Apartments and condos 84 290 

1999 Arizona homes 17 332 

2000 Manufactured homes 34 unknown 

2000 Site-built homes 36 unknown 

2005 Conventional homes 17 unknown 

2005 Mobile homes 16-25 unknown 

Formaldehyde levels in typical residences likely have declined since the 

1980s, when the first two studies were performed and when HUD 

standards for mobile homes were set. The factors that would contribute to 

such a reduction include the reduced presence of urea formaldehyde foam 

insulation and reduced emissions levels from the types of composite wood 

products now being used. The 1999 study of 189 homes in Arizona found 

a much lower formaldehyde level of 17 ppb with a high of 332 ppb. The 

2000 study found mean formaldehyde levels of 34 ppb in new 

“manufactured homes” and 36 ppb in new “site-built homes.” The 2005 

study of 184 single-family homes in three cities found mean formaldehyde 

levels of 3 ppb in ambient air, 17 ppb in conventional homes, and 16-25 

ppb in mobile homes. 

FEMA Responses to Formaldehyde in Trailers 

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Effects of Formaldehyde 

Regardless of the level of exposure, formaldehyde exposure can be a 

health threat. One of the possibilities is the risk of cancer. As the CDC 

reported in the July 2, 2008, study of FEMA trailers: 

“The carcinogenicity of formaldehyde has been extensively studied during the last 30 

years. In June 2004, the International Agency for Research on Cancer (IARC) 

reclassified formaldehyde from ‘probably carcinogenic to humans’ to ‘carcinogenic to 

humans.’ IARC has concluded that formaldehyde exposure causes nasopharyngeal 

cancer. However, the National Institutes of Health Toxicology Program has not adopted 

IARC’s classification change and continues to classify formaldehyde as ‘reasonably 

anticipated to be a carcinogen in humans’ and states that ‘How to quantitatively relate 

measured air levels of formaldehyde to cancer risk is uncertain. Because many other 

factors play a role in the development of cancer and because formaldehyde is ubiquitous 

in the environment, no definitive level can be established that places humans in a “highrisk” category. The safest way to reduce risk for cancer is to limit exposure.’” 

CDC officials told us that the risk of cancer from formaldehyde is not a 

threat that has a plateau below which one is safe and above which one is 

vulnerable; rather, it is a threat that just steadily increases with exposure. 

One CDC official has been quoted as saying that there is no safe level of 

exposure to formaldehyde in trailers: 

“Any level of exposure to formaldehyde may pose a cancer risk, 

regardless of duration.” 

However, given the ubiquitous nature of formaldehyde in an industrialized 

nation, such a warning statement only lets people know that there is no 

residence, and in fact no place, where they can be guaranteed safe from 

formaldehyde’s potential long-term effects. While accepting the above 

warnings, we have had to focus this review on the more quantifiable acute 

health effects of formaldehyde. 

The shorter-term acute health effects of formaldehyde exposure vary by 

individual, but overall are more definable than the chronic risk of cancer. 

CDC described these risks in its July 2, 2008, report of formaldehyde in 

FEMA trailers: 

FEMA Responses to Formaldehyde in Trailers 

Page 9 
“Symptoms from acute exposure to formaldehyde commonly manifest as irritation of the 

throat, nose, eyes, skin, and upper respiratory tract. This upper respiratory tract irritation 

can exacerbate symptoms of asthma and other respiratory illnesses.... Acute and chronic 

health effects of exposure to formaldehyde vary by individual. At 800 ppb, nearly 

everyone develops some acute irritative symptoms; however, formaldehyde-sensitive 

persons have reported symptoms at levels around 100 ppb. Additional studies have found 

health effects at 100 ppb in sensitive persons chronically exposed to formaldehyde.” 

The CDC report also said that most individuals detect the odor of 

formaldehyde only when concentrations reach 500 ppb; therefore, some 

individuals can experience symptoms without being able to detect the odor 

of formaldehyde. 

Some experts believe that 300 ppb is another possible decision point in the 

evaluation of formaldehyde in residences. In trailers that are above that 

level, the CDC director stated “even people without vulnerability might 

experience some respiratory symptoms if they spent time in those homes.” 

Formaldehyde Standards 

Although workplace standards and recommendations for allowable 

exposures to formaldehyde have been implemented to protect workers 

who are exposed to formaldehyde, there is far less guidance as to what 

levels should be avoided in residences. The only federal standard for 

formaldehyde is the Occupational Safety and Health Administration 

(OSHA) “allowable time-weighted average” for allowable exposure to 

formaldehyde in workplaces, which is 750 ppb for 8 hours. 

There are no standards for formaldehyde exposure in residences. A 

standard that is acceptable in the workplace could be inappropriate for a 

residential setting, where there are more likely to be children, the elderly, 

and persons who are not healthy, and where most individuals spend more 

hours each day than in their workplace. HUD standards governing the 

materials that are acceptable in mobile homes had a 1984 target of keeping 

formaldehyde exposures in mobile homes below 400 ppb. However, HUD 

standards do not apply to travel trailers or park models, and a 400 ppb 

level is far higher than many experts currently recommend. Apart from 

these limited standards, there are some recommendations and guidance 

from federal agencies but they tend to vary widely. 

FEMA Responses to Formaldehyde in Trailers 

Page 10 
 

 

The following table sums up some of the opinions and recommendations 

concerning formaldehyde published by federal agencies: 

Federal Government
 

Formaldehyde Goals, Standards and Targets
 

Occupational Regulatory Agencies 

Department of Labor, Occupational Safety and Health Administration 

(standards) 

� 0.75 parts per million (ppm) (750 ppb)–Time Weighted Average 

(TWA) for 8 hours exposure to formaldehyde. 

� 2.0 ppm (2000 ppb) – Short-Term Exposure Limit (STEL) for 15 

minutes without suffering health effects. 

Environmental Regulatory Agencies 

U.S. Environmental Protection Agency (recommendations) 

� 0.1 ppm (100 ppb) and above of formaldehyde exposure will cause 

watery eyes; burning sensations in the eyes, nose and throat; nausea; 

coughing; chest tightness; wheezing; skin rashes; and allergic 

reactions.

� 0.9 ppm (900 ppb) or above formaldehyde exposure for more than 8 

hours in a lifetime is dangerous. 

Consumer Regulatory Agencies 

U.S. Consumer Product Safety Commission (recommendation) 

� Formaldehyde exposures above 0.1 ppm (100 ppb) will cause watery 

eyes; burning sensations in the eyes, nose and throat; nausea; 

coughing; chest tightness; wheezing; skin rashes; and allergic 

reactions. 

Housing Regulatory Agencies 

Department of Housing and Urban Development, Office of Manufactured 

Housing (targeted goal and standards for components) 

� 0.4 ppm (400 ppb) – Targeted maximum for ambient levels of 

formaldehyde in manufactured housing.. 

Scientific/Public Health Agencies 

Department of Health and Human Services, National Institute of 

Occupational Safety and Health (recommendations) 

� .016 ppm (16 ppb) TWA for 8 hours exposure to formaldehyde. 

FEMA Responses to Formaldehyde in Trailers 


Page 11 

Causes of Formaldehyde Problems in FEMA Trailers 

Prior to hurricanes Katrina and Rita, complaints about formaldehyde levels in 

FEMA trailers had not surfaced and, therefore, FEMA officials were unaware that 

this should have been an issue of concern. Furthermore, because this was never 

an issue of concern in past disasters, the contracts under which FEMA obtained 

the trailers did not contain protections against excessive formaldehyde 

concentrations. Nor were the FEMA production oversight and product 

acceptance procedures sufficient to ensure that trailers did not contain 

unacceptable levels of formaldehyde. 

The FEMA trailers provided to the Gulf Coast states following hurricanes Katrina 

and Rita encountered a “perfect storm” for the development of formaldehyde 

problems: 

� All of the units were some form of manufactured housing and therefore 

tended to have more of the manufactured wood products that can emit 

formaldehyde gas. 

� Most of the units were travel trailers, which are not designed to be permanent 

residences, tend to have a higher proportion of formaldehyde-emitting 

products per volume of internal air space and also usually have less capable 

ventilation systems. 

� Most of the trailers were new and a great percentage were brand new, having 

been hurried from the factory to the then-homeless residents rather than 

sitting in a dealer’s lot for a period of time as trailers usually do. 

� The manufacturers had been under pressure to speed the delivery of quickly 

completed units to the Gulf Coast; such quick assembly can lead to problems 

such as wider gaps in seams of covering materials, allowing increased 

formaldehyde emissions. 

� Almost all the trailers were going to locations that were unusually hot and 

humid during much of the year, creating two of the prime factors in 

increasing formaldehyde levels. 

� Ideally, units should be ventilated and air-conditioned to reduce 

formaldehyde levels, but it is difficult and expensive to do both at once 

during the summer in the Gulf Coast. 

� Residents are also advised to spend more time outside to limit their exposure 

to formaldehyde; but in the crowded, often barren, multiple-trailer group 

sites where many families were placed, it was probably more pleasant to 

remain inside, especially for people with mobility problems. 

� Smoking and cooking can contribute markedly to indoor formaldehyde levels 

in any residence, but the effect would be compounded in residences having 

as small a volume of air as the FEMA trailers. 

� The susceptibility of individuals to formaldehyde varies, with children, the 

elderly, and persons with prior health problems being most vulnerable. High 

numbers of each of these vulnerable population groups were living in FEMA 

trailers. 

FEMA Responses to Formaldehyde in Trailers 

Page 12 
In retrospect, it is not surprising that formaldehyde problems would develop in 

FEMA trailers. Many of the FEMA trailers, whether purchased from dealers or 

manufactured, were vulnerable to high formaldehyde levels. Most of the “off the 

lot” models that were purchased from dealer inventory right after the hurricanes 

were built and sold under regulations that placed no limits on formaldehyde 

levels. Only the mobile homes had regulations governing formaldehyde; travel 

trailers and park models that were commercially available had not been required 

to meet any maximum formaldehyde level standards. When FEMA contracted for 

the production of “FEMA-spec” mobile homes the contract specifications 

required that: “These units must meet and comply with all appropriate HUD 

requirements, regulations, standards, and guidance.” Among the applicable 

HUD standards was the requirement that materials used in mobile home 

construction must meet HUD restrictions on formaldehyde off-gassing. But the 

HUD restrictions, as drafted in 1984, were only intended to keep formaldehyde 

concentrations in mobile homes below 400 ppb; current mobile homes would 

generally test well below that level. When the FEMA-spec mobile homes were 

finally tested in January 2008, none of the units tested at more than 400 ppb of 

formaldehyde. 

The FEMA contracts for the production of travel trailers required that “units” 

shall meet industry standards. The contracts did not cite the HUD standards 

concerning formaldehyde in materials, which apply only to mobile homes. Nor 

had such mobile home standards been required of FEMA travel trailers in the 

past. Some CDC officials told us that even if the travel trailer materials had been 

required to meet HUD standards, the smaller interior airspace relative to 

formaldehyde-emitting materials and the 

weaker ventilation systems of some of 

these units could still have resulted in 

higher formaldehyde concentrations than 

in mobile homes. When FEMA did test 

the travel trailers in January 2008, six 

units from four different manufacturers 

were found to have formaldehyde 

concentrations greater than 400 ppb. It 

is unclear whether occupants’ habits 

such as smoking, may have affected 

these results. Interior of a typical FEMA-spec travel 

The quality control/quality assurance (QC/QA) processes that FEMA put in place 

for the trailer procurement contracts were not designed to prevent excessive 

formaldehyde in FEMA trailers. FEMA had four inspectors, but they were at the 

plant of only one of the manufacturers. In any case, excessive formaldehyde 

levels were not among the items that the FEMA inspectors were looking for. 

Although pre-acceptance inspections were conducted at FEMA’s receiving points, 

FEMA Responses to Formaldehyde in Trailers 

Page 13 
 

such as the Hope, AR, storage and staging facility, formaldehyde levels were not 

among the conditions that were examined. 

Conclusions 

The FEMA mobile homes were produced under contracts that would limit 

the amount of formaldehyde that was off-gassed by their materials, but 

might not result in units that had currently acceptable levels of 

formaldehyde. Travel trailers produced under FEMA contracts were not 

restricted at all in the levels of formaldehyde they might have. The 

QA/QC procedures in place during the manufacture of the units would not 

have prevented excessive formaldehyde levels, and the FEMA inspection 

and acceptance procedures would not have detected excessive 

formaldehyde levels. The travel trailers obtained on the commercial 

market did not offer any better protection against excessive formaldehyde 

levels. FEMA has taken steps to address some of these problems, but we 

recommend institutionalizing improvements for all emergency housing 

units. 

Recommendations 

We recommend that FEMA: 

Recommendation #1: Include specifications in contracts for 

future purchases of mobile homes, travel trailers, and park models 

that provide for acceptable maximum formaldehyde levels in units 

that are delivered. 

Recommendation #2: Establish quality assurance/quality control 

requirements to ensure that excessive formaldehyde levels will be 

prevented, and institute inspection procedures to detect and reject 

units with unacceptable formaldehyde levels. 

FEMA Responses to Formaldehyde in Trailers 

Page 14 
FEMA Responses to the Developing Formaldehyde Problem 

As formaldehyde problems started to surface, information concerning the nature 

and extent of the formaldehyde problem was not promptly relayed to appropriate 

FEMA officials. FEMA officials were not initially aware of the seriousness of the 

problems that some residents of FEMA trailers were encountering. Based on the 

information available, FEMA officials may have believed that they acted 

appropriately to respond to the formaldehyde issue. In hindsight, however, it is 

now clear that they should have reacted in a more timely manner to determine the 

extent and cause of the formaldehyde problem and taken a more aggressive 

approach to correcting the problem. In the future, FEMA needs to have protocols 

in place to ensure that indications of potential health or safety problems for 

FEMA clients are promptly addressed, i.e., determine the nature and extent of the 

problem, prescribe effective remedial actions to address the problem, and notify 

all affected clients. FEMA also needs to institute training on how to handle health 

and safety issues as part of the training provided to FEMA employees who have 

direct contact with FEMA clients. 

Early Indications of Formaldehyde Problems 

The first indications of possible formaldehyde problems in FEMA trailers 

came in October 2005, just 1 month after trailers were first shipped to the 

Gulf Coast region. Between October 2005 and January 2006, OSHA 

officials conducted more than 100 formaldehyde tests in the Gulf Coast 

region, many of which were conducted in FEMA trailers. OSHA’s 

apparent focus of the tests was to determine whether there were any 

problems with workplace safety. Some of the trailers tested had high 

formaldehyde readings. For example, three FEMA trailers that were 

tested by OSHA officials in Purvis, MS, on November 11, 2005, had 

formaldehyde level readings of 280, 520, and 590 ppb. OSHA gave these 

results to officials of the contractor managing the site where the trailers 

were located. However, the results were not forwarded by the contractor 

to FEMA officials. Finally, on March 21, 2006, OSHA officials faxed 

FEMA the results of the more than 100 formaldehyde tests that had been 

conducted at various sites. Many of those tests had results that indicated 

formaldehyde problems, but FEMA safety officers and other FEMA 

officials said that they had not been previously aware of the tests, let alone 

the problematical results. 

On March 16, 2006, a Biloxi, MS, television station reported on a local 

couple who were having formaldehyde problems with the FEMA trailer 

they had received in December. The couple said that after living in the 

trailer, they had developed burning eyes, scratchy throats, and sinus 

FEMA Responses to Formaldehyde in Trailers 

Page 15 
headaches. They had bought an air purifier and had tried ventilating the 

trailer, but nothing brought them relief from these symptoms. 

On April 6, 2006, one of the FEMA contractors hired a testing company to 

analyze the formaldehyde levels in a Baxterville, MS, FEMA trailer in 

which occupants had experienced formaldehyde symptoms, such as 

burning eyes, since first occupying the trailer in February. After testing 

the trailer for 8 hours with the air-conditioning off, the testing company 

reported that formaldehyde readings exceeded 1,000 ppb. The company 

reported: “These data show that both the OSHA and NIOSH [National 

Institute for Occupational Safety and Health] limits for formaldehyde were 

exceeded in this FEMA trailer.” 

On April 11, 2006, the Mississippi FEMA staff reported the case of a 

locally purchased FEMA trailer that was tested for formaldehyde at the 

request of the occupant. They reported that when the testing was 

performed with the windows closed and the air-conditioning off, the end 

result was above OSHA workplace standards, and that “the tester himself 

developed eye-watering symptoms of exposure.” 

On May 17, 2006, allegations that the problem with formaldehyde in 

FEMA trailers might be widespread were nationally publicized when the 

Sierra Club announced: 

“A new study conducted by the Sierra Club shows that the indoor 

air quality of FEMA trailers contains excessive levels of 

formaldehyde, a carcinogen that can cause various forms of 

cancer with repeated exposure. The Sierra Club has tested the 

indoor air of 31 FEMA trailers in Mississippi and Louisiana to 

determine formaldehyde levels. Only two tests were at or below 

the 0.1 parts per million [100 ppb] maximum safety limit 

recommended by the EPA and the American Lung Association. 

Several trailers were more than three times over the limit.” 

FEMA Officials’ Reactions to the Formaldehyde Issue 

Some FEMA officials tended to discount the Sierra Club findings. They 

noted that the announcement had not provided details concerning the 

testing procedures and wondered whether the procedures followed in the 

Sierra Club tests might have led to higher readings than would have been 

the case with other procedures. One FEMA official commented on May 

18, 2006: 

FEMA Responses to Formaldehyde in Trailers 

Page 16 
“I just can’t understand why out of 15,000 trailers we had in 

Florida during the 04/05 response/recovery that we didn’t have 

one complaint about formaldehyde. It’s really strange that in 

Louisiana they don’t have a single one either, and that no one 

complained until the press got this one guy in Mississippi, and now 

we have a number of complaints in MS. Really strange!” 

Other FEMA officials, however, had already recognized that the best way 

to answer any questions related to the Sierra Club report and determine the 

extent and nature of the problem facing FEMA and its clients was for 

FEMA to have the appropriate formaldehyde testing conducted as soon as 

possible. And media inquiries soon were received asking: 

“Will FEMA start doing their own testing of Formaldehyde in TT’s 

[travel trailers]?” 

This was not the first time the concept of testing to determine the nature, 

extent, and causes of any formaldehyde problem in FEMA trailers had 

been raised. Following the March 16, 2006, television report about the 

couple who were experiencing formaldehyde problems with their FEMA 

trailer, FEMA officials in the Gulf Coast region exchanged emails 

concerning what actions were called for. One asked if random testing of 

trailers could be required of manufacturers. Another recommended: 

“...either MHOPS [Mobile Home Operations] or Logistics needs to 

test units from various manufacturers to see if there are any 

patterns or only an isolated incident.” 

One of the FEMA field attorneys noted the issues that Gulf Coast officials 

faced: 

He added that: 

FEMA Responses to Formaldehyde in Trailers 

Page 17 
In another email, 7 days later, the same official noted: 

By May 16, 2006, some FEMA officials were notified of the dangers and 

potential consequences of excessive formaldehyde exposure. On that day, 

a FEMA safety officer sent out an email to regional officials in Alabama 

with a 11⁄2-page information sheet titled “Formaldehyde” from the 

Environmental Health Center of the National Safety Council. The 

information sheet noted that formaldehyde in excess of 100 ppb can cause 

“watery eyes; burning sensations in the eyes, nose and throat; nausea; 

coughing; chest tightness, wheezing; skin rashes; and other irritating 

effects.” It further noted that sensitive people can experience effects 

below 100 ppb and that the World Health Organization recommends that 

exposure should not exceed 50 ppb. The information also included a 

warning that: “Formaldehyde has caused cancer in laboratory animals 

and may cause cancer in humans; there is no known threshold level below 

which there is no threat of cancer. The risk depends upon amount and the 

duration of exposure.” 

On June 13, 2006, a Mississippi Sierra Club official wrote the Acting 

Assistant Administrator, Disaster Assistance Directorate, to warn him: 

“...94 percent of FEMA trailers tested by Sierra Club recently in 

Mississippi had formaldehyde levels over the safety limits set by 

EPA.” 

She recommended that: 

“...since FEMA consistently denies there is a problem, FEMA 

should undertake testing to prove that formaldehyde levels are not 

a concern.” 

Before the Sierra Club results were announced, some Mississippi FEMA 

officials had already attempted to establish a formaldehyde-testing 

program. By May 4, 2006, Mississippi FEMA officials had announced 

that: 

“The JFO [Joint Field Office] here in Mississippi is instituting a 

formaldehyde testing program and we will be testing for 

formaldehyde fumes in our trailers.” 

The Mississippi FEMA officials had submitted a contract request to 

institute such a program but it was going slowly because the contracting 

FEMA Responses to Formaldehyde in Trailers 

Page 18 
office had a very limited staff. On May 23, 2006, the contracting contact 

person had announced that he still did not have a contract for 

formaldehyde testing because his office had kept putting the request “on 

the back burner.” They could get a contract at any time, but he wrote: 

“Safety has given the contractor personnel responsible for taking 

the phone calls, instructions on how to respond to requests for 

testing. The instructions are basically, ventilate the trailer. Safety 

does not recommend testing. We can do a contract, but the 

general consensus is we are opening a can of worms.” 

The official requesting the formaldehyde testing was apparently not 

convinced and the next day emailed: 

“OK, let’s get it started today. Please get with Contracting, Safety, 

OGC [now OCC] and [management official] and let’s get a SOW 

[Statement of Work] written, accomplish a 60-1 and get it to 

contracting. This is a hot issue, getting hotter each day.” 

The immediate response from the contracting officer was: 

“I’m getting conflicting messages here; the safety officer is still 

recommending not to do testing and has not been given any 

guidance from the FCO [Federal Coordinating Officer] or Chief of 

Staff to do so. He makes a good case for not testing and I believe 

if someone is pushing this, that person needs to hear what the 

safety officer has to say. The bottom line here is that if someone 

has a trailer that they can’t live in because of odors, then MHOPS 

needs to give them a new trailer. Testing is not going to make the 

odor go away.” 

This appears to have convinced the requesting official, who responded: 

“This does make some sense here. If they have a trailer that is 

causing discomfort then we may need to send them one that has 

been around for a while. Testing will only confirm that there is a 

problem. We need to fix the problem rather than apply a bandaid.” 

With the collapse of that testing effort, there would not be any significant 

or widespread FEMA testing of formaldehyde in occupied units for more 

than 18 months. 

FEMA Responses to Formaldehyde in Trailers 

Page 19 
Even though some safety officers had recommended against testing 

occupied units, FEMA Occupational Safety and Health officers did 

continue to test unoccupied units in FEMA staging areas to ensure that 

employee formaldehyde exposure levels were below the OSHA 

permissible exposure limit. However, we were told even that effort ended 

after FEMA officials told Occupational Safety and Health Office 

headquarters officials to have all such testing stopped. More than a year 

later, the Occupational Safety and Health Office was finally allowed by 

senior FEMA officials to resume testing to protect FEMA employees. 

FEMA officials did make some attempts to identify the extent of the 

formaldehyde problem, but they did so by trying to get an accurate tally of 

complaints from occupants rather than testing occupied units. However, 

such information was not formally tracked, and on July 21, 2006, FEMA 

local officials had been directed to not put the growing number of 

formaldehyde complaints in to the National Emergency Management 

Information System “because it may not be true.” By early October 2006, 

the total number of formaldehyde complaints to date was estimated to 

have been 50 in Mississippi and 20 in Louisiana. These figures were later 

used as an ongoing tally, but FEMA’s informal system could not 

determine an accurate estimate of the number of occupants having 

problems from formaldehyde in their trailers. A more accurate estimate of 

the number of occupants reporting problems from formaldehyde can be 

found in the August 10, 2007, formaldehyde factsheet put out by the 

FEMA Disaster Assistance Directorate. According to the factsheet, as of 

August 9, the FEMA hotline for emergency housing occupants had 

answered 8,238 calls concerning formaldehyde. Of those callers, 913 

requested to move out of their trailer and receive rental assistance, 1,554 

applicants requested to have their trailer tested for formaldehyde, 2,247 

had called just to report specific health concerns such as burning eyes and 

respiratory problems, and 362 applicants requested to exchange their 

trailer for another FEMA trailer. These totals may reflect multiple calls 

from one occupant. 

FEMA Policies on Addressing Formaldehyde Problem Cases 

FEMA policies regarding what was to be done for individuals who 

complained of adverse effects from formaldehyde in their trailers were 

unclear and FEMA clients were not treated consistently. In June 2006, the 

stated policy was that individuals who complained about formaldehyde 

should be directed to air out their units and run their air-conditioners, and: 

“As a final recommendation, we would swap out the unit for a 

used, renovated unit which would not present the off-gassing 

FEMA Responses to Formaldehyde in Trailers 

Page 20 
problems experienced in the new units.... Further, OGC [now 

OCC] has advised that we do not do testing, which would imply 

FEMA’s ownership of this issue.” 

In mid July 2006, however, a FEMA official who was trying to get a swap 

of a used unit for residents who were having health problems from 

formaldehyde fumes was told by a senior FEMA official that such swap 

requests could not be approved unless there was medical documentation in 

the applicant’s files. 

On July 19, 2006, FEMA OCC officials advised: 

These policies were apparently not clearly and extensively communicated. 

In August 2006, local FEMA officials who had been told to “make sure 

they do all the recommended actions” before a swap complained: 

“We have had little direction in dealing with formaldehyde issues. 

What are the recommended actions and policies for dealing with 

these issues?” 

Eight months later, there was apparently still some confusion in the field 

as to what the policy was and one FEMA official described telling a 

resident in April 2007 that: 

“...no way were we going to swap a TT [travel trailer] just because 

it smelled like formaldehyde.” 

Some FEMA officials took the above “hard line” position even though 

FEMA staff had reported on how bad the effects of the formaldehyde 

fumes could be. For example, on October 13, 2006, a FEMA employee 

reported on a visit to a travel trailer whose occupant had complained of 

formaldehyde fumes: 

“Contacted her by phone and obtained permission to enter the TT. 

It is a nice cool day outside and was nice and cool in the TT, but 

after about 5 minutes in the unit my nose/sinus began to burn. 

Have been out of the unit for approx. 15 minutes and still have 

burning sensation in my nostrils. Don’t believe this unit would be 

a healthy environment for young children.” 

FEMA Responses to Formaldehyde in Trailers 

Page 21 
On March 22, 2007, the FEMA Mobile Home Operations Maintenance 

Coordinator issued “guidelines to handle applicant request for 

‘Formaldehyde Issue’.” 

“First visit the applicant at the unit. Document your findings. 

Explain the procedure to ventilate the unit by opening the windows 

and letting the air flow. This appears to have the most positive 

effect. ...Have the applicant ventilate for 48 hours. ...If the 

applicant is still experiencing formaldehyde-related problems 

inform the applicant we will swap the unit for a previously 

occupied unit that did not have any formaldehyde problems.” 

By June 12, 2007, the issue was settled because FEMA policy had been 

changed to: 

“Where a complaint involving formaldehyde comes through, the 

unit involved is to be deactivated. Rather than offering a 

replacement TT, a rental unit is to be offered instead.” 

This policy was formalized on July 31, 2007, in the “FEMA Interim 

Direction on use of Temporary Housing Units,” which mandated that 

when the current eligible occupant of any FEMA-owned travel trailer or 

park model requested a replacement, he or she would be offered rental 

assistance or, if available, a mobile home - but not a replacement trailer. 

It is clear that the lack of a definitive, consistent, and well-promulgated 

FEMA policy resulted in some cases of problem trailers not being handled 

consistently. In May 2006, a Louisiana resident and his family became ill, 

reportedly from the formaldehyde in their trailer. They were told to 

ventilate but that did not cure the problem. The occupant moved his 

family into a hotel at his own expense and requested a swap of trailers. 

However, he had a difficult time swapping trailers because FEMA 

officials wanted a doctor’s “excuse” and worried about setting a 

precedent. In another case, a Long Beach, MS, trailer occupant who had 

lung disease had to sleep in her car after her physician told her to stay out 

of her trailer. She had called maintenance more than once about the 

problem, but had not received an effective response. Long Beach FEMA 

officials also reported the case of another woman who was told that a 

maintenance and deactivation contractor would only tell her to open the 

windows and air the place out. Another resident called about 

formaldehyde problems in October 2006 and February 2007, but 

maintenance did not follow-up on either complaint. Finally, the resident 

was in contact with a television news organization, and they widely 

publicized his case. 

FEMA Responses to Formaldehyde in Trailers 

Page 22 
FEMA Efforts to Assist Trailer Residents With Formaldehyde 

Complaints 

In general, despite the lack of a clear policy to address formaldehyde 

problems, most local FEMA officials appeared to respond well to 

complaints from residents. Gulf Coast FEMA officials told us that, while 

they were not specifically trained in addressing health issues, they listened 

and were as responsive as possible, to residents’ complaints of problems 

with FEMA trailers. Many FEMA employees who assisted the trailer 

occupants were themselves local residents who had been displaced into 

trailers and understood very well the problems of living in a trailer. 

According to the available emails concerning formaldehyde problems, 

most FEMA employees did what they could to assist those with problems 

in a setting where the lack of available housing severely limited the 

options they had available. FEMA officials did move those who 

complained of formaldehyde problems into replacement units when it 

became clear that ventilating the unit would not correct the problem. 

Because of the lack of testing, however, FEMA staff could not predict 

which units would have problems, so residents were moved into used units 

that staging-area staff tried to clean thoroughly before releasing. There 

were many instances where officials worked to get priority treatment for 

replacement of units that had been observed to be particularly bad. 

FEMA local officials also worked to inform trailer occupants concerning 

how to minimize the formaldehyde problem most effectively in their 

trailers. In July and August 2006, more than 268,000 brochures were 

distributed to FEMA trailer occupants in all of the affected states. The 

brochures emphasized that the first thing that residents could do was to 

ventilate the unit by opening doors and windows. The other effective 

action was to keep temperatures moderate and lower the humidity. These 

steps would, of course, require running the units’ air conditioners, which 

use a lot of electricity, especially when doors and windows are open. 

However, some residents could not afford the expense of using a lot of 

electricity. FEMA local employees pointed out this problem, and some 

tried to find a way for FEMA to pay for electricity in the units to enable or 

encourage residents to keep the formaldehyde levels down. But they were 

notified that the regulations do not allow for this, and that: 

“The only way we pay utilities is if the TT is part of the pad lease 

agreement that utilities are included.” 

Some local employees even got themselves in “hot water” for attempting 

to deal with the formaldehyde problems. One employee wrote on August 

30, 2006, concerning a unit that appeared to have a particularly high level 

FEMA Responses to Formaldehyde in Trailers 

Page 23 
of formaldehyde. He thought the unit might make a good “case study” for 

examining the formaldehyde problem, and was apparently concerned that 

such a unit not be placed back in service where it might be issued to 

another family. He wrote that: 

“Once deactivated we will mark the unit as ‘non-habitable’ and 

ship to BR staging area. If you would like to have the unit tested, 

we can track and provide information, etc. Otherwise we will 

designate it for the ‘boneyard’.” 

A FEMA official responded: 

“I am very concerned that you are recommending a level of 

habitability for the units when no other federal agency has set a 

threshold for residential formaldehyde levels. ...While we would 

like for you to identify units that were swapped for formaldehyde 

complaints, I would like to ask that you do not make suggestions of 

‘non-habitable’ and recommendations for putting units in 

‘boneyards’ in the future without engaging [appropriate FEMA 

officials].” 

The employee who had written the original email replied that he was: 

“Sorry if I got things stirred up - just trying to take care of 

business.” 

Nearly 1 year later, on July 20, 2007, the FEMA Administrator wrote a 

memorandum to all FEMA employees announcing: 

“Over the last two months, FEMA has significantly increased its 

focus on formaldehyde-related health concerns raised by Gulf 

Coast disaster victims. ...Earlier this week, I was troubled to learn 

that some FEMA employees may have not acted with the speed and 

sensitivity I expect in addressing the concerns raised by some 

victims of Hurricanes Katrina and Rita. I will deal with these 

issues swiftly. FEMA’s first priority is the health and welfare of 

disaster victims we serve. Anything less is totally unacceptable. I 

know that the FEMA team I am privileged to lead does hold sacred 

this same commitment.” 

This message should have provided some satisfaction to the many FEMA 

employees who had been doing their best to identify the cause and extent 

of the formaldehyde problem and to assist those who were affected by it in 

their residences. 

FEMA Responses to Formaldehyde in Trailers 

Page 24 
Effects of FEMA’s Initial Responses to Formaldehyde 

The consequences of FEMA’s initial decision not to undertake testing to 

determine the cause and extent of formaldehyde problems in occupied 

units are difficult to assess. There were not many alternatives to the 

FEMA trailers for those who wanted to remain in the Gulf Coast area. 

Perhaps, had the extent and seriousness of the formaldehyde problem been 

made known through prompt and timely testing, more residents would 

have vacated the trailers. Most, however, would probably have remained. 

Some residents might have then been more likely to follow the advice to 

ventilate and air-condition, but many probably could not afford to do so. 

At the least, more residents would have been aware of the seriousness of 

the formaldehyde problem and might have sought assistance. The FEMA 

relief system in place depended on the occupants to complain about 

problems with their units in order to get assistance. However, some 

people are not prone to complaining and may have just quietly endured 

adverse health conditions. For example, in May 2006 a Mississippi 

FEMA official reported that: 

“...I happened to go over to see a Sergeant in the Army National 

Guard the other day on other FEMA business and he happened to 

mention that he has had a FEMA trailer for 5 or 6 months now and 

he has had problems with smell, sore throat, burning eyes; he says 

he airs out the trailer every day but it only helps for a little while 

and then it is worse than ever. Seems like after a few weeks of 

airing the problem should be gone. I am not an expert but it 

doesn’t sound right. He knows it’s formaldehyde. This guy served 

in Iraq and says he’s lived in worse and doesn’t want to look a gift 

horse in the mouth. But it seems a shame he has to live under 

those conditions.” 

Such individuals who are not prone to complaining might have come in 

for assistance had FEMA tested the types of trailers they occupied and 

informed all residents of the seriousness of the formaldehyde problems. 

Other individuals who might have been more likely to come forward for 

help are those persons who are sensitive to formaldehyde, including 

persons with preexisting conditions such as asthma. Many “sensitive” 

individuals have conditions that are aggravated by levels of formaldehyde 

that are below the level at which formaldehyde can be smelled. Therefore, 

without any testing, they might not have been aware that the formaldehyde 

in their trailers was a reason their health conditions were deteriorating. 

FEMA Responses to Formaldehyde in Trailers 

Page 25 
Conclusions 

FEMA has an obligation to its clients to inform them whenever there is the 

possibility of health or safety problems inherent in their use of FEMA 

products or programs. In addition, FEMA should provide residences that 

are reasonably safe for the occupants. Appropriate FEMA officials did not 

immediately learn of the formaldehyde problems that were first identified 

in FEMA trailers. When they did learn of the formaldehyde problems, 

nearly a year passed before any testing program was started and nearly 2 

years passed before occupied trailers were tested and the occupants were 

informed of the extent of formaldehyde problems and potential health 

threats in their trailers. FEMA field staff did what they could to help those 

residents who complained of problems, but they were hindered by the 

paucity of available options and by the lack of a consistent and wellpromulgated policy on what corrective actions should be taken. 

Recommendations 

We recommend that FEMA: 

Recommendation #3: Promulgate a policy that any issue or 

problem that might affect the health and safety of occupants of 

emergency housing must be quickly forwarded to the responsible 

headquarters offices as defined in this new policy. 

Recommendation #4: Train FEMA and contractor “front-line” 

employees who have contact with disaster victims on how to 

respond to health and safety issues. 

Recommendation #5: Establish a policy that whenever a health 

or safety issue arises concerning its clients, all reasonable actions 

will be taken to determine the nature, cause, extent, and 

consequences of the problem. 

Recommendation #6: Whenever a problem might affect the 

health and safety of FEMA clients, such as occupants of 

emergency housing, promulgate consistent and effective guidance 

to the field concerning how to address such problems. 

FEMA Responses to Formaldehyde in Trailers 

Page 26 
Formaldehyde Testing Effort for Unoccupied Trailers 

Once FEMA officials instituted a formaldehyde testing effort, it focused on 

determining the extent of formaldehyde in new, unoccupied trailers and on 

methods to reduce those levels rather than focusing on, or giving equal focus to, 

identifying the extent of the formaldehyde problem in occupied units and the 

causes of those problems. Several management issues slowed the progress of this 

unoccupied-units testing program. When the initial results of the tests of 

unoccupied units were superseded by a cautionary letter from the testing 

authority, this was not conveyed to the appropriate FEMA officials. This may 

have resulted in pronouncements to Congress and the public that were more 

optimistic concerning the nature of the formaldehyde problem than was 

warranted, and possibly delayed the development of a testing program for 

occupied trailers. 

Initiation of a FEMA Formaldehyde Testing Program 

On June 27, 2006, an extensive exchange of emails took place among 

senior FEMA staff in the Gulf Coast area and headquarters concerning a 

FEMA trailer resident who had died in his trailer at a site in St. Tammany 

Parish, LA. The resident was reported to be an older man who had heart 

problems, and there was no reason to conclude that his death was due to 

the formaldehyde level in his trailer. However, his neighbors had said that 

he told them he was reluctant to use his air-conditioner because he was 

afraid it would make the formaldehyde worse. This tragic event, and the 

concerns it raised, caused those FEMA officials who had advocated 

testing for formaldehyde in order to determine the full nature of the 

problem to once again raise this issue. One FEMA official noted: 

“In addition, we need to move past OGC [now OCC] objections to 

possible testing and move forward with our safety notice (similar 

to the one HUD uses for Mobile Homes). I believe this issue is 

well past the point of ‘wait and see.’” 

The Acting Assistant Administrator, Disaster Assistance Directorate, 

responded that he had discussed the situation and supported the concept of 

tasking EPA to perform a full assessment of the formaldehyde problem 

and make recommendations. 

FEMA Responses to Formaldehyde in Trailers 

Page 27 
On June 28, 2006, officials from FEMA, EPA, the United States Public 

Health Service (PHS), and CDC/ATSDR held a conference call.1 One of 

the goals of the conference call was to identify an organization to test the 

air quality of the deceased’s unit and determine whether random sampling 

of all FEMA trailers was necessary. Among the resolutions agreed upon 

in the conference call were: 

“FEMA Safety is to investigate and sample [the deceased’s trailer], 

Request that the Consumer Product Safety Commission vet FEMA 

trailers against the industry standard” [and] “Identify an 

independent, non-governmental agency to conduct tests of indoor 

air quality and evaluate policies.” 

On July 7, 2006, another conference call concerning a formaldehydetesting program was scheduled. In a briefing document to prepare for that 

call, the authors wrote that, because of health concerns and press articles 

concerning FEMA housing units, FEMA staff had entered into discussions 

with CDC/ATSDR and EPA regarding the advisability of, and 

recommended procedures for, random formaldehyde testing. But there 

were concerns expressed that air quality testing might not be an effective 

strategy because: 

“There is a lack of consensus among various agencies regarding 

acceptable levels of formaldehyde....The results can be influenced 

by many outside factors, such as new furniture or draperies, 

smoking in the unit with no ventilation...New units less than two 

months old will frequently show higher levels of formaldehyde....” 

During a July 11, 2006, conference call, some experts warned that 

preliminary research indicated that a health baseline for formaldehyde 

would probably be much lower than expected and the formaldehyde levels 

that would be found in testing could be much higher than the health 

baseline level. During the call, it was agreed to run tests that could 

“establish the difference between ventilated and unventilated units.” This 

would be done by pulling together a valid sample of unused units from 

each manufacturer, leaving half the units closed up for 2 weeks, running 

the air-conditioners in the other units for 2 weeks, and then testing all the 

units. This plan would evolve and become more detailed over the next 2 

months, but it remained the basic concept for testing these never-occupied 

trailers. 

1

 The Centers for Disease Control and Prevention (CDC) and Agency for Toxic Substances and Disease 

Registry (ATSDR) are separate agencies, but both are divisions of the Department of Health and Human 

Services (HHS) and have the same senior leadership. 

FEMA Responses to Formaldehyde in Trailers 

Page 28 
Conduct of Testing of Unoccupied Units 

By July 18, 2006, EPA officials had developed and submitted to FEMA a 

proposed “Quality Assurance Sampling Plan for Formaldehyde Sampling 

at FEMA Temporary Housing Units.” FEMA officials reviewed the plan 

and raised some concerns, including who would perform the “data 

management-result interpretation and recommendations,” and whether 

there would be enough unused units available to produce a valid sample of 

each manufacturer’s units. 

By a July 20, 2006, FEMA, EPA and CDC/ATSDR conference call, the 

details of the testing plan were starting to be worked out, including how 

many units to test and from what sources. The notes for the conference 

call state that there was: 

“Discussion about whether the testing will be done with the units 

open or with just the air conditioner. Initial proposal was just for 

the air conditioner. Point was made that the formaldehyde will not 

dissipate without the windows being open.” 

The conference call notes also state that there was: 

“No resolution as to how testing will be accomplished and what we 

are trying to achieve. Discussion will continue regarding the 

variables and when and how long each variable will be tried 

during the testing process.” 

Through successive conference calls, the testing plan was worked out in 

more detail by late July. The basic plan was to define the formaldehyde 

levels on various models in a controlled test and then: 

“...perform several actions (open windows for a specific time, run 

fans, control humidity) and measure the effect on the formaldehyde 

level.” 

There were some problems in finding enough unused trailers from each 

manufacturer for each test, but by September 8, 2006, the main remaining 

problem was the provision of electrical power to each of the units that was 

to be tested. The power company wanted the payment account in place 

before the meters were installed and powered up. Also, the contractor 

selected to wire the trailers had not completed the work and had to have 

the completion date for the contract extended. However, these problems 

were addressed, and by September 19, 2006, EPA’s contractor had started 

testing the 96 selected trailers. Each trailer would be initially tested to 

FEMA Responses to Formaldehyde in Trailers 

Page 29 
establish a baseline formaldehyde level and then be retested after 

ventilation or air-conditioning steps were completed. By October 19, 

2006, EPA Region 6 reported that the EPA contractor had all of the 

agreed-upon data, but that problems in the analysis would delay delivery 

of the data from the contractor to EPA for approximately 1 week. EPA 

expected to deliver the database to FEMA around November 13, 2006. 

Analysis of Formaldehyde Tests of Unoccupied Units 

CDC/ATSDR agreed to analyze the data package provided by EPA and its 

contractor and offer recommendations based on the data set. Since there 

was no existing interagency agreement between FEMA and the CDC 

under which this analysis could be performed, the responsible program 

office started working on all of the necessary documents, including a 

possible acquisition plan, on October 26, 2006. However, by November 4, 

2006, CDC/ATSDR officials concluded that they could “complete the task 

before an IAA [interagency agreement] could go through the approval 

process,” and agreed to interpret the test results without an established 

IAA. FEMA had designated an attorney to be responsible for the class 

action litigation alleging personal injuries related to formaldehyde in 

FEMA trailers. In that capacity he received the raw data during 

Thanksgiving week from EPA. Thereafter, the data was forwarded by 

FEMA officials to CDC/ATSDR and arrived December 1, 2006. FEMA 

officials initially stated that they expected a final analysis from 

CDC/ATSDR around December 11, 2006, but once CDC/ATSDR 

officials received the EPA packet they told FEMA that it would take 

longer than anticipated to complete the analysis. 

On February 1, 2007, the CDC/ATSDR Health Consultation 

“Formaldehyde Sampling at FEMA Temporary Housing Units” was sent 

to FEMA from the Acting Associate Director; Office of Terrorism, 

Preparedness and Emergency Response; National Center for 

Environmental Health/ATSDR. The analysis was 14 pages long, and as 

the cover letter noted: 

“In summary, the opening of windows and vents was effective in reducing formaldehyde 

concentrations below levels of health concern. Running the heating, ventilation and air 

conditioning systems did not provide adequate air exchanges to adequately reduce the 

formaldehyde concentrations. A combination of ventilation methods may be necessary to 

reduce formaldehyde concentrations below levels of health concern for sensitive 

individuals. FEMA has not requested ATSDR to evaluate longer term formaldehyde 

concentrations in trailers or health concerns related to potential exposures.” 

FEMA Responses to Formaldehyde in Trailers 


Page 30 

 

 

The FEMA attorney who had received the CDC/ATSDR report sent it to a 

limited number of FEMA officials. In general FEMA officials interpreted 

the report to say, as one FEMA official concluded: 

“...the tests confirmed that we do not have a major issue with the 

formaldehyde but we are probably too casual in our 

communications with our applicants [residents] regarding proper 

ventilation.” 

Problems With the Initial Analysis Report 

However, 6 weeks later, on March 17, 2007, the Associate Director; 

Office of Terrorism, Preparedness and Emergency Response; National 

Center for Environmental Health/ATSDR sent the FEMA attorney who 

had received the “Formaldehyde Sampling at FEMA Temporary Housing 

Units Health Consultation” a letter that expressed concerns with that 

report as issued. This letter, which was actually signed by the Associate 

Director, as opposed to the previous letter, which had been signed by an 

acting official, stated: 

“I am writing in follow-up to my previous correspondence last month on behalf of the 

CDC National Center for Environmental Health/Agency for Toxic Substances and 

Disease Registry. 

It has just come to my attention that the Health Consultation ‘Formaldehyde Sampling at 

FEMA Temporary Housing Units’ has been completed without a policy review by our 

senior technical staff. I am concerned that this health consultation is incomplete and 

perhaps misleading. 

Formaldehyde is classified as ‘reasonably anticipated to be a human carcinogen.’ As 

such, there is no recognized ‘safe level’ of exposure. Thus, any level of exposure to 

formaldehyde may pose a cancer risk, regardless of duration. Failure to communicate 

this issue is possibly misleading, and a threat to public health. I had discussed this issue 

several months ago in a review of the public statement derived from the Toxicological 

Profile that FEMA proposed. I specified at that time that this statement contained no 

mention of the cancer risk and that should be a public health concern. 

Thank you for your consideration of this issue and please feel free to contact me. Failure 

to speak to the long-term cancer risk regarding formaldehyde exposure irrespective of 

duration is of particular concern.” 

In October 2007, ATSDR would issue “An Update and Revision of 

ATSDR’s February 2007 Health Consultation: Formaldehyde Sampling of 

FEMA Temporary-Housing Trailers, Baton Rouge, Louisiana, SeptemberOctober 2006.” This update was approximately three times the length of 

FEMA Responses to Formaldehyde in Trailers 

Page 31 
the original report and, in addition to reporting the data of the first 

consultation; it contained a great amount of additional information, 

including that which was referred to in the second letter. 

The CDC/ATSDR letters had both been sent to one FEMA attorney 

because the CDC/ATSDR officials still understood him to be their contact 

point at FEMA as he had been for the test results. While the FEMA 

attorney who received these letters shared the first letter with appropriate 

FEMA officials, he did not share the second, or revised, letter. According 

to the FEMA attorney, the cautionary second letter was consistent with 

previous communications that results from CDC should not be “over 

read.” Not being aware of the second letter, FEMA officials reassured 

Congress and the public of the safety of FEMA trailers in statements that 

do not reflect the content of the second letter and that might not have been 

made if they had been aware of the content of the second letter. For 

example, on March 23, 2007, the Acting Assistant Administrator, Disaster 

Assistance Directorate, sent a letter to a congressional committee 

responding to the committee’s questions. In that letter he stated: 

“At this point, FEMA is not aware of any significant health risks to 

the residents of these trailers.” 

On May 10, 2007, the Associated Press quoted a FEMA spokesperson as 

saying: 

“We have no need, and we see no need, to question the reliability 

and safety of the trailers....As long as residents can properly 

ventilate their units, there is no significant health hazard, little if 

any.” 

On July 3, 2007, the “FEMA Forward” newsletter was quoted as stating 

that it is a myth that FEMA must remove formaldehyde from travel trailers 

because: 

“The agency’s study of air samples collected from travel trailers in 

the Gulf area shows that formaldehyde emission levels in the units 

can be significantly reduced through adequate ventilation.” 

The FEMA attorney, however, said he was not aware that FEMA officials 

had made such public statements. 

FEMA Responses to Formaldehyde in Trailers 

Page 32 
Role of the FEMA Attorney in the Formaldehyde Testing 

Program 

The FEMA attorney involved in the formaldehyde issue since early on in 

its development became a point person for the issue. On June 14, 2006, the 

FEMA Associate General Counsel for Litigation sent an email to FEMA 

officials that read, in part: 

“A class action suit seeking injunctive and monetary relief from 

FEMA and trailer manufacturers was filed last week. 

Administrative tort claims also were filed.” 

He then named the attorney, referred to in this report as the “FEMA 

attorney”, who: 

“...is handling the matter for OGC [now OCC]. The program 

should not be dealing with applicants on the formaldehyde issue 

without first coordinating with [the FEMA attorney] and DOJ 

[Department of Justice].” 

Later that day, a FEMA official wrote an email related to formaldehyde in 

trailers that included: 

“This came up at the Senate. Has the agency conducted our own 

testing of the units? If not, we need to do so ASAP and put this 

issue to rest or remove people from harm. I don’t want to rely on 

non-fed testing. We also need an information campaign on what 

we are doing about the potential issue and our eventual findings to 

include temporary and permanent remedies.” 

One of the recipients of his email, a FEMA attorney in the Gulf Coast 

area, forwarded the message to the FEMA attorney with the message: 

“Please see the email from [the FEMA official] below – you 

weren’t copied so I didn’t know if you had seen it.” 

On June 15, 2006, the FEMA attorney sent an email to the drafter of the 

email concerning testing, the Gulf Coast FEMA attorney who had 

forwarded him the testing email, and the Associate General Counsel for 

Litigation, which read: 

“Do not initiate any testing until we give the OK. While I agree 

that we should conduct testing, we should not do so until we are 

fully prepared to respond to the results. Once you get results and 

FEMA Responses to Formaldehyde in Trailers 

Page 33 
should they indicate some problem, the clock is running on our 

duty to respond to them.” 

On June 16, 2006, FEMA OCC recommended that: 

On June 27, 2006, as part of the discussions addressing how to perform 

testing that was to be conducted by the EPA, a FEMA official asked the 

FEMA Gulf Coast Recovery Office whether they were taking the lead in 

resolving the formaldehyde issue. A Gulf Coast recovery official 

responded: 

“Yes, Gulf Coast Recovery will take the lead, in coordination with 

the TROs [Transitional Recovery Office] and HQ Recovery.” 

Within 15 minutes, the Associate General Counsel for Litigation sent an 

email to the two officials who had exchanged the emails and to more than 

30 other FEMA officials stating that: 

“Please be aware that there is active pending litigation on the 

formaldehyde issue. FEMA activities related to testing, etc., must 

be coordinated with OGC [now OCC] and DOJ. [The FEMA 

attorney] is the OGC [now OCC] attorney assigned to the case.” 

The FEMA attorney was closely involved in the testing program once 

OCC put out the informal order that he was to be part of all 

communications. For example, the FEMA attorney was involved in 

discussions regarding how often the EPA contractor was to test each of the 

unoccupied units and how the units were to be coded so the testers would 

not know the manufacturer of each. But the FEMA attorney told us that 

he had no authority to direct how the EPA conducted its tests or decide 

which trailers to test, and did not direct EPA’s testing. Once the tests were 

completed, EPA was to give all of the raw data to the FEMA attorney. He 

would be the FEMA official holding the data and would be the individual 

responsible for sending the data to CDC/ATSDR for analysis. The FEMA 

attorney received the results from EPA officials by November 21, 2006, 

and CDC/ATSDR received the results from him by December 1, 2006. 

There was a 1-week delay in the forwarding of the data because the 

FEMA attorney did not know to whom in CDC/ATSDR to send the results 

for analysis. When CDC/ATSDR completed the analysis, their product 

FEMA Responses to Formaldehyde in Trailers 

Page 34 
was to be sent to the FEMA attorney, who was to serve as their contact at 

FEMA. The CDC/ATSDR letter that would accompany that product to 

the FEMA attorney would eventually note: 

“Per your request, the data and the subsequent analysis of the data 

has not been shared with anyone other than [two CDC/ATSDR 

staff].” 

The control held by the FEMA attorney over the testing data information 

is shown in a December 1, 2006, report by a FEMA official of her 

conference call with the attorney. She reported that he had said that he: 

“Reviewed the raw data ‘in a very non-scientific manner.’ It 

appeared overall, there were low levels of airborne contaminants 

of formaldehyde found in the samples collected and analyzed by 

the EPA. Ventilation is the primary method in which to reduce 

formaldehyde in the trailers.”... “The data was duplicated and 

forwarded to [the contact person] of the CDC.” He had then 

reiterated that “if the media or another government agency ask 

questions pertaining to formaldehyde” they were to be referred to 

FEMA OCC. 

The FEMA attorney may not have been in charge of the testing program, 

but he served as point of contact for study information, and that may have 

affected FEMA in its public announcements. 

Effects of the FEMA Attorney’s Role in the Program 

The extent of the effects of having the FEMA attorney in a position of 

control in the formaldehyde testing of unoccupied residences is not very 

clear. There was a 1-week delay in getting the test data to CDC. 

However, CDC/ATSDR officials told us that their subsequent data 

analysis was not interfered with. The fact that the attorney controlled the 

receipt of data and analysis from CDC had an adverse effect because the 

second letter which should have cautioned FEMA officials about the 

reliance that could be put on the first letter and report, was not distributed 

or discussed by the attorney. This may have caused or allowed FEMA 

officials to make assurances about the safety of the FEMA trailers that 

were later shown to be incorrect. FEMA’s appearance and reputation 

were also damaged with the public disclosure in the national press of the 

FEMA attorney’s directive: 

FEMA Responses to Formaldehyde in Trailers 

Page 35 
“Do not initiate any testing until we give the OK.2

...Once you get 

results and should they indicate some problem, the clock is 

running on our duty to respond to them.” 

These comments were eventually released to Congress in response to a 

congressional request and were carried in newspapers, with the result that 

FEMA was portrayed as more concerned with legal liabilities than the 

health of its clients. 

Effects of Testing Unoccupied Units Rather Than Occupied Units 

The decision by FEMA officials to test unoccupied trailers in order to 

analyze two mitigation strategies rather than testing occupied trailers to 

determine the cause, nature, and extent of the formaldehyde health threat 

had significant negative repercussions. Tests on unoccupied units 

concluded that maximum ventilation of trailers was effective and was 

more effective than merely cooling units with air-conditioning and limited 

ventilation—in effect, the study proved in the tested trailers what was 

already generally known. The Consumer Product Safety Commission had 

been advising trailer occupants since at least 1997 that the first way to 

reduce formaldehyde was to, “Bring large amounts of fresh air into the 

home. Increase ventilation by opening doors and windows and installing 

an exhaust fan(s).” Other health and safety organizations, including CDC 

offices, had provided similar advice. Even FEMA, in brochures that were 

distributed in July and August 2006, well before the testing was 

conducted, had advised residents under the heading “What can I do to 

reduce my exposure to formaldehyde in my travel trailer?” to “Increase 

ventilation. You can reduce your exposure to formaldehyde by bringing 

more outdoor air into your home. Open windows and doors whenever 

possible.” Although the benefits of the testing of unoccupied units were 

therefore limited, the real cost, apart from the funds that were spent, was 

that occupied units were not tested to determine the potential 

formaldehyde threat and would not be tested for more than a year after the 

testing of unoccupied units. 

Causes of the Manner in Which the Testing Program Was 

Managed 

Some FEMA officials told us that the program offices were really in 

control of the program, but the FEMA attorney played a key role. From 

the beginning of the testing effort, the program office and OCC both 

2

 The major press article left out the intervening text of “While I agree that we should conduct testing, we 

should not do so until we are fully prepared to respond to the results.” 

FEMA Responses to Formaldehyde in Trailers 

Page 36 
supported testing, but for different reasons. In late August 2006, a news 

network submitted a Freedom of Information Act (FOIA) request for the 

formaldehyde testing results. 

FEMA attorneys took the position that: 

“The testing was undertaken because FEMA was sued.... The 

testing is covered under the following exception to FOIA #5 and 

has been prepared in anticipation of litigation and is covered 

under deliberative process privilege, the attorney work product 

privilege and the attorney client privilege.” 

In other words, the testing responded to a legal issue and the results were 

not publicly releasable. 

The Acting Assistant Administrator, Disaster Assistance Directorate, 

responded: 

“For the record, we initiated this testing before we were sued.” 

[And wrote to his staff] “Is that right? I was not aware of any 

litigation when you first proposed engaging the EPA to test.” The 

Recovery staff responded: “I don’t know if we were aware of the 

litigation when we began working with EPA (it certainly wasn’t the 

driving factor). I will need to review my email archives for actual 

dates.” 

Since the FEMA attorney received the formaldehyde analysis from 

CDC/ATSDR, he was also the only person who received the second CDC 

letter that called into question the reliance that should be placed on the 

first letter and report. When he did not release the second letter to other 

FEMA officials, they proceeded to make optimistic statements about the 

safety of the FEMA trailers that they might not have made if they had all 

the relevant information. 

We have been given several reasons for the decision to test unoccupied 

trailers rather than occupied trailers including that other agencies were 

resistant to conduct testing, especially of occupied units. FEMA officials 

told us that unoccupied units were tested first because that was necessary 

to establish a protocol for testing occupied units. However, the standard 

protocol for testing for formaldehyde is an established NIOSH protocol 

that existed long before the testing of the FEMA trailers. CDC officials 

told us that this NIOSH protocol was used in the tests of occupied units 

that were to be conducted in December 2007, and that no additions to that 

protocol from the FEMA/EPA testing of unoccupied units were needed or 

FEMA Responses to Formaldehyde in Trailers 

Page 37 
used in that testing. Some officials who were engaged in the test planning 

for unoccupied units and in the analysis of those results told us that they 

believed that the testing of unoccupied units was needed to establish a 

baseline for the subsequent testing of occupied units. However, such a 

baseline is not referred to in the test results of occupied units and, in any 

case, this would not have prevented testing of occupied units from being 

conducted simultaneously with the testing of unoccupied units rather than 

more than a year later. 

At the time the testing was announced to the public, the FEMA News 

Desk stated that: 

“The agency has specifically asked for and received from the 

Environmental Protection Agency (EPA) an air monitoring and 

sampling plan that is intended to validate scientifically, methods 

that can be used to reduce the presence of formaldehyde in travel 

trailers.” 

The FEMA Public Affairs Office sent out talking points stating: 

“The purpose of the study is to provide scientific support for 

methods that can be used to reduce the presence of formaldehyde 

in trailers. Specifically, the results will be used to identify 

activities we can take and that we can instruct the occupants to 

take to lower the levels of formaldehyde.” 

FEMA officials used the following similar language to describe the 

program to the DHS Secretary and to a congressional committee 

chairman: 

“The test plan will identify a variety of activities to reduce levels, 

such as opening the windows for 15 minutes every morning, with 

testing to take place after each of the different activities.” 

These announcements all leave the impression that some groundbreaking 

research will test a variety of different activities and options for effectively 

reducing formaldehyde in trailers – research that might conceivably be 

worth postponing the analysis of formaldehyde problems in occupied 

units. However, after discussions between FEMA and EPA officials, the 

actual EPA test plan for unoccupied trailers accepted by August 22, 2006, 

called for only testing two variables: the airborne formaldehyde 

concentration when ventilation is provided by open windows, static vents 

and exhaust fans; and the airborne formaldehyde concentrations when 

ventilation is provided by open static vents and the air temperature and 

FEMA Responses to Formaldehyde in Trailers 

Page 38 
humidity are controlled through the use of the home’s air-conditioning 

system. While these were certainly valid options to test, they were already 

recognized as being among the priority steps to take to reduce 

formaldehyde levels in trailers and were hardly the groundbreaking 

research on a variety of options that were described by FEMA officials. 

Our review of most of the FEMA emails concerning formaldehyde that 

were exchanged between late 2005 and early 2008 leads to another 

possible reason for testing unoccupied units rather than testing the trailers 

that were actually occupied and whose residents’ health might be 

threatened. Once testing for formaldehyde levels in occupied units was 

completed, FEMA would need to be able to tell the occupants what the 

test results actually meant and how much of a health risk the occupants 

were taking by remaining in the trailers. The key problem that FEMA 

officials faced was that there were no standards for residential 

formaldehyde safety levels against which to compare the results. After 

testing, FEMA would only be able to tell the occupants: “Here are the 

results and they might mean you are at risk.” When the results of testing 

occupied units were finally released in 2008, the conclusions were not too 

different from this statement. 

FEMA officials at various levels expressed, on different occasions, this 

fear of what to do with the information and what to tell the occupants. 

FEMA officials sought usable safety standards for trailer formaldehyde 

levels from several organizations on several occasions, including from a 

CDC-convened experts panel. However, FEMA officials did not succeed 

in getting any organization to view producing such guidance as its role or 

responsibility, or in getting the standards that it needed. These were 

needed not only to demonstrate the real meaning of any tests of occupied 

units that might be conducted, but also to design the standards for future 

FEMA housing units in order to provide safe residences for occupants. 

Conclusions 

The testing of unoccupied trailers was somewhat delayed by several 

factors. The role that the FEMA attorney played harmed the public’s 

perception of FEMA. The attorney’s position that: “Once you get results 

and should they indicate some problem, the clock is running on our duty to 

respond to them” may have created a negative public image of FEMA’s 

efforts to address the formaldehyde problem. Moreover, the attorney’s 

sole possession of information may have allowed FEMA officials to give 

incorrect assurances concerning formaldehyde safety in FEMA trailers. 

FEMA Responses to Formaldehyde in Trailers 

Page 39 
 

Whenever there are serious allegations of health and safety problems 

affecting FEMA clients, the initial steps should include determining 

whether the problem is real and the cause, extent, and nature of the threat. 

In this case, these steps would have required testing the formaldehyde 

levels in the occupied units before, or at least concurrent with, the testing 

of the unoccupied units. The reasons given for testing the unoccupied 

units first are not sufficiently convincing to overcome the general principle 

that determining the extent and nature of health and safety threats should 

always be a priority. However, the absence of any standards for what is a 

safe level of formaldehyde acceptable in a FEMA travel trailer, although 

not a sufficient reason for delaying the testing of occupied trailers, is a 

major health and safety problem and obstacle. HUD standards address 

what materials can be used in mobile homes but do not address what level 

of formaldehyde is acceptable in such a unit–and these standards do not 

work for travel trailers. In addition, the apparent 1984 HUD 

formaldehyde goal of 400 ppb does not appear to satisfy the safety 

demands that are being made of FEMA. 

There will always be some formaldehyde in trailers, but FEMA officials 

need to know what constitutes acceptable and safe levels for the trailers 

provided to occupants. FEMA is not the agency responsible for 

determining such residential formaldehyde standards and its staff does not 

have the capability to do so. Nor were FEMA officials able to determine 

just what organization can and will fulfill such a need. However, these 

formaldehyde standards are definitely needed to ensure the safety of future 

occupants of FEMA trailers. Such standards would also help to provide 

for the health and safety of occupants of non-FEMA travel trailers, park 

models, and mobile homes, and would be of great use to consumers when 

they are purchasing such units. 

Recommendation 

We recommend that FEMA: 

Recommendation #7: Establish clear policy over the decision 

making processes related to matters of health and safety. This 

policy should mandate that responsible program and management 

officials make decisions after obtaining and considering all 

appropriate professional advice, including opinions and input from 

medical, scientific, and legal experts. Moreover, FEMA should 

ensure that responsible program officials and managers have 

access to critical information and advice related to the health and 

safety effects of all FEMA programs. 

FEMA Responses to Formaldehyde in Trailers 

Page 40 
Formaldehyde Testing Effort for Occupied Trailers 

A testing program to examine the seriousness and extent of the health threat of the 

formaldehyde problem in occupied FEMA trailers in the Gulf Coast region was 

initiated in May 2007, partly due to heightened congressional interest in these 

matters and after a senior DHS official directed health specialists from DHS’ 

Office of Health Affairs (OHA) to become involved in the problem. OHA 

quickly started to work with CDC officials to develop the plans for an appropriate 

comprehensive testing program. However, there were lengthy FEMA delays in 

producing the documents necessary to conduct the testing. The testing program 

was initially delayed until October 2007. The testing effort was further delayed 

by 2 months when a senior FEMA official decided that FEMA was not prepared 

for the possible results and stopped the contract. By the time testing was 

conducted, it was early winter, when formaldehyde levels and, therefore, test 

results were likely to be lower because of the weather. Nevertheless, the test 

results were serious enough to cause the FEMA Administrator and the CDC 

Director to hold a press conference to announce the results and efforts to move the 

remaining occupants out of FEMA trailers. 

Initiation of the Testing Program for Occupied Trailers 

The process of testing occupied trailers did not start until outside events 

and outside officials put pressure on FEMA officials. On May 1, 2007, a 

major national news program featured an episode titled “Toxic Trailers.” 

The feature addressed formaldehyde problems in FEMA trailers, and 

stated “epidemiologic studies have established quite clearly that there’s an 

increased risk of cancer, especially cancer of the nasal sinuses.” The 

news feature also discussed a Mississippi pediatrician’s conclusion that 

the persistent colds, pneumonias, and sinus and ear infections being 

suffered by some of his young patients might be related to the fact that 

every one of them was living in a FEMA trailer. 

On May 17, 2007, a senior DHS official emailed the Chief Medical 

Officer (CMO), the Administrator, and the Deputy Administrator of 

FEMA: 

“Can you work with FEMA to do a quick assessment of the facts 

associated with this story and let me know what you think? Is this 

a real medical concern? If so, how serious? Remedy?” 

FEMA Responses to Formaldehyde in Trailers 

Page 41 
Eight minutes later, the Acting Administrator for the Disaster Assistance 

Directorate also emailed the CMO: 

“Reference yesterday’s CBS report that a Bayou Le Batre 

physician has identified what he believes is an ailment trend 

among travel trailer residents, which he attributes to 

formaldehyde. While the study we commissioned on the 

formaldehyde problem by CDC and EPA would seem to dispute 

that, I am nevertheless interested in arranging to have a formal 

federal medical assessment of this individual’s evidence and 

claims, to determine their validity and if further health and safety 

actions on the part of FEMA may be warranted. Before reaching 

out to the obvious candidate agency, HHS, request your 

recommendation on an approach.” 

Later that day, the FEMA Deputy Administrator emailed the head of 

OHA: 

“We’ve previously had CDC conduct a study. Welcome fresh look 

from [the head of OHA] and his team.” 

That same day, the CMO emailed a CDC official: 

“ATSDR did a nice environmental exposure study in response to a 

FEMA request...which showed conclusively that ventilating a new 

trailer could obviate the problems with new, manufacturingrelated formaldehyde concentrations. We may need some further 

suggestions from a clinical tox perspective, and wonder how we 

might go about enlisting the help of you and your associates with 

expertise in the matter, hopefully to put it to rest, but more 

importantly to make sure we are not missing anything.” 

FEMA officials were apparently still unaware of the second CDC letter, 

which limited the reliance that should be placed on the first ATSDR study. 

By May 18, 2007, the CMO was able to email FEMA officials that he had 

been in contact with CDC and had appointed an OHA team to work with 

CDC and others “to get to the ground truth on this.” 

FEMA Responses to Formaldehyde in Trailers 

Page 42 
Meanwhile, FEMA officials in the Gulf Coast were reporting that, after 

being down during the winter, complaints about formaldehyde were 

picking up, with 28 complaints in the past couple of days: 

“Further, occupants are now starting to request that we test their 

unit for formaldehyde levels.” 

FEMA Gulf Coast officials reported their plan was to explain to occupants 

that their workforce was not qualified to do formaldehyde testing and 

instead continue to recommend ventilation and swapping units when that 

did not work and added: 

“But, we need this position to be confirmed with HQ and the Chief 

Medical Office.” 

The Acting Assistant Administrator, Disaster Assistance Directorate, 

replied: 

“Don’t have a strong opinion on this. Will support whatever 

response/interdiction strategy OGCR [Office of Gulf Coast 

Recovery] and OHA jointly determine.” 

By May 25, 2007, the OHA team and CDC had already reached initial 

agreement on a series of actions that were needed to address the 

formaldehyde problem. These consisted of a statistically valid sampling 

of occupied trailers looking at formaldehyde and other volatile organic 

compounds (VOCs), a medical evaluation through interviews with trailer 

occupants, a toxicological review recommending target levels based on 

past and ongoing research, and an engineering review looking for long 

term engineering solutions for formaldehyde in trailers. Thus, the critical 

questions concerning the health threat in occupied trailers were now being 

asked after more than a year. 

By May 30, 2007, after discussions with CDC and FEMA officials, the 

OHA team had further defined the areas of inquiry that CDC would be 

requested to perform. These areas included how the government should 

determine whether excessive levels of formaldehyde or other substances 

were contributing to noted adverse health effects on residents of FEMAprovided travel trailers; the reasonable target levels for mitigating both 

long-term and short-term health effects; whether the CDC recommended 

that occupants be relocated from trailers that cannot be mitigated to the 

above recommended level; the practical trailer engineering mechanisms to 

reach the target levels; and the continuing mitigation requirements 

recommended by the CDC, such as testing and monitoring formaldehyde 

FEMA Responses to Formaldehyde in Trailers 

Page 43 
 

levels in occupied trailers. The following day the OHA team and FEMA 

officials discussed the plan in detail with CDC officials. 

By June 6, 2007, a FEMA executive summary of the four tasks to be 

requested of CDC was complete. These were: 

1. “Determine the levels of certain air quality measures (including 

formaldehyde, molds and airborne bacteria) for a representative sample of 

these trailers, under actual use conditions, in order to assist FEMA in 

making short-term risk management decisions concerning continued 

habitation of these trailers. The goal of this requirement is to determine 

actual conditions in the field.” 

2. “Develop a protective indoor air level for formaldehyde for various timeof-residence periods, to help inform FEMA in risk management decisions 

concerning immediate and future habitation of travel trailers.” 

3. “Identify any practical mechanisms or engineering solutions for these 

trailers to reach target levels that would ensure safety/health of residents.” 

4. “Determine whether there is an association between poor indoor air 

quality in FEMA trailers and adverse health effects in children who live 

in these trailers.” 

FEMA Delays in Obtaining Testing Assistance From CDC 

Problems with FEMA administrative procedures significantly delayed the 

agreements needed for CDC to proceed with the project, which, in turn, 

delayed the start of testing by about 6 weeks. 

As early as June 7, 2007, one of the FEMA officials involved in the testing 

program had emailed the Acting Assistant Administrator, Disaster 

Assistance Directorate, asking whether, now that the definition of the tasks 

to be performed by CDC was complete, someone could start drafting the 

“appropriate FEMA task document for CDC.” CDC officials told us that 

they had notified FEMA early on that CDC would not be able to start any 

substantive work without the proper authorizations from FEMA, 

especially a letter of request to the CDC Director from the FEMA 

Administrator, and funding documents. The Acting Assistant 

Administrator, Disaster Assistance Directorate, immediately emailed the 

appropriate persons, including a note that: 

“We need to quickly formalize a funding mechanism with CDC, to 

support their engagement in the formaldehyde issue.” 

By June 15, 2007, a proposed letter from the FEMA Administrator to the 

CDC Director requesting engagement of CDC in addressing the four 

formaldehyde issues had been drafted, and the Administrator and his 

deputy had been briefed on the formaldehyde issues and the proposal for 

FEMA Responses to Formaldehyde in Trailers 

Page 44 
CDC involvement. By June 19th, a few changes had been made to the 

draft request letter for CDC and by June 25th, FEMA staff reported that 

they hoped the letter would go out the next week. Meanwhile funding 

documents for the requested CDC effort were also being completed, since 

“the real task will not begin until the IAA [interagency agreement] is in 

place.” 

On July 2, 2007, a copy of the draft letter was sent to CDC with the note 

that there might still be changes in the letter, but probably not in scope. 

CDC, of course, needed more than just a “likely-to-get-out” draft request 

before they could proceed. By July 3rd, the FEMA staff who were in 

contact with CDC were asking to know when the letter might be signed 

since the CDC staff who were writing their own Director’s response letter 

“want to be ready to respond quickly.” 

By July 10, 2007, the head of the OHA team was emailing the Acting 

Assistant Administrator, Disaster Assistance Directorate, warning that 

since a congressional committee was scheduling a formaldehyde hearing 

for the next week: 

“I think this is all the more reason that we need to do whatever can 

be done to get CDC their official start letter from FEMA.” 

One of the FEMA contacts for the letter then wrote: “Letter is in final 

concurrence. Pushing to have final signed ASAP.” But that same day 

other FEMA staff reported: “The letter to CDC is mired in bureaucracy.” 

On July 11, 2007, the Deputy Assistant Secretary, DHS OHA, emailed the 

FEMA Deputy Administrator to mention that he had been talking to the 

head of the OHA formaldehyde team: 

“...after we heard about the invitation to testimony that you have 

for next week. [The head of the team] mentioned that the letter 

from FEMA going to the CDC requesting CDC’s help with the 

environmental study, etc., has not been sent yet as the cost analysis 

and clearance process had not been completed. ...Evidently the 

CDC has also been asked by the committee what it is doing to 

work with FEMA on the issue...” 

The FEMA Deputy Administrator then emailed the Acting Assistant 

Administrator, Disaster Assistance Directorate: 

“What’s the story on this letter to CDC? Have we not sent it? Is 

there an issue?” 

FEMA Responses to Formaldehyde in Trailers 

Page 45 
To which the Acting Assistant Administrator responded: 

“Our staff continue to work with the CFO [Chief Financial Officer] 

to establish a funding vehicle for this effort. Will have a more 

detailed update later.” 

On July 20, 2007, the CDC received the hard-copy letter from the FEMA 

Administrator to the CDC Director. It had taken approximately 45 days 

from the time that FEMA finalized the tasks to be requested of CDC until 

the CDC received the letter requesting that the tasks be performed. 

Testing Program for Occupied Trailers Commences 

Once the necessary FEMA documentation was completed, the 

formaldehyde-testing program moved forward. By the end of July, CDC 

officials had completed a site visit to the Gulf Coast area to “gather 

information in order to draft a protocol and sampling plan.” 

However, by early August 2007, it became clear that CDC would need to 

use contractors for the testing that was planned, since the CDC NIOSH 

element would not be able to perform the required testing activity. This 

may have led to additional delays. FEMA reported that CDC would have 

a challenge getting these tests contracted because of the “timing in 

relationship to end of fiscal year.” On August 16, 2007, the FEMA 

interagency agreement with CDC was completed. By September 10, 

2007, some FEMA officials were already requesting that the contracting 

officer issue a delinquency notice to CDC because testing had not started 

as scheduled. As other FEMA officials had noted: “we are losing some of 

the best time of the year to test as the heat and humidity are high.” By 

October 12, 2007, CDC had announced the contract for testing of FEMA 

trailers and had selected a contractor to perform the tests. Testing was 

scheduled to begin in the Gulf Coast region in late October, and the testing 

contractor proceeded to get staff and equipment on site to commence the 

testing. And then the testing program came to a complete stop. 

FEMA Officials Stop the Testing Program for Occupied Trailers 

Even after the CDC contractor was in place, FEMA officials’ concerns 

about what their strategy should be once the testing results became public 

caused FEMA to halt the testing effort before it could get underway. This 

resulted in yet another delay, nearly 2 months in this case, in the testing of 

occupied units. 

FEMA Responses to Formaldehyde in Trailers 

Page 46 
For many months, FEMA officials had discussed what test results would 

mean and what could and should be said about the results of testing in 

occupied units. As far back as August 2006, a FEMA official had written 

Texas FEMA staff, who had wanted to test their occupied trailers for 

formaldehyde, that: 

“...my concern [is] that even with the test, what are you going to 

use to determine if it is OK or not? There are no standards for 

residential safety and FEMA is not an agency to set one.” 

On September 24, 2007, the FEMA Deputy Administrator emailed the 

OHA and FEMA officials involved in the testing effort: 

“...are the NIOSH and CDC efforts different or the same? Are 

they going to work just with unoccupied trailers or with occupied? 

Travel trailers only or also with mobile homes? Is the RVIA 

[Recreation Vehicle Industry Association] resolution applicable to 

TTs? Is that the point? On the CDC assessment, is its primary 

objective how to help us with inventory or to gain information that 

will help us ensure the safety of disaster victims? I would like a 

timeline of what to expect from who and when. We meet with the 

Secretary tomorrow. Would be worthwhile to provide an update. 

Will need this info to ensure that I understand where we are.” 

The next day the Deputy Administrator, having received a response 

including a timeline that predicted the testing would be conducted from 

October 7 to 20, 2007, emailed the same officials: 

“Looks like sampling completed on Oct 20th, but analysis will not 

be provided to FEMA until mid-December. Is that correct? What 

is the communications plan? It would seem that our largest 

communications challenge will come once we have the sampling 

analysis. Yet, presuming that we want to communicate the results 

of the sampling, how can we have the comms plan two weeks 

ahead of the sampling assessment? You are working in MS with 

CDC. Presume that sampling will take place in LA as well. I am 

still looking for something that will define level of ‘safe’ so that 

results of sampling have useful value. [OHA team] indicates the 

expert panel will not provide that clarity, but may provide ‘relative 

risk’ information, for whatever that means. I am concerned that 

we have not given enough discussion of where we will be at the 

end of sampling. I am concerned that we will have sampling data, 

but won’t know how to apply it. We likely will not have ‘safe’ but 

will have ‘relative risk’. What is that? How do we think, 

FEMA Responses to Formaldehyde in Trailers 

Page 47 
communicate and develop policy? I would like to have this 

discussion now as opposed to end of October. I would like to meet 

with you and [OHA] on this issue when able. Once again, I 

appreciate the issue of deploy-dispose, but am more focused on 

safety aspects and ability to communicate those issues to current 

and previous occupants of these housing units.” 

On October 21, 2007, having viewed the October 19th Weekly Update on 

formaldehyde testing, the Deputy Administrator wrote: 

“Thanks for the update. Have some concern for proper launch of 

test of occupied TTs. Will want assurance that we are ready, and 

opportunity to advise on Hill and at DHS. Still concerned we will 

have validated testing results and no standard to which apply. 

Presume 1.0 ppm will become de facto standard. Want to discuss 

before green light is given to proceed.” 

The Acting Assistant Administrator, Disaster Assistance Directorate 

responded: 

“1.0 ppm too high, at least as a standard for future purchases. We 

are using .015 as our current de facto standard for new purchases. 

This is .001 ppm below the NIOSH cellular-effect level. If we 

select a current habitation safety standard above .015, we will 

need to defensibly reconcile the two.” 

The next day, a FEMA official coordinating formaldehyde efforts wrote: 

“The numbers that are ‘out there’ are 0.1ppm, which is the NASA 

[National Aeronautics and Space Administration] standard and is 

further supported by the American Society of Heating, 

Refrigerating and Air-Conditioning Engineers (ASHRAE). The 

California Air Resources Board and Dept. of Health have set 

0.1ppm as their ‘action guideline,’ meaning above that requires 

active mitigation. In the absence of a medical/scientific agency 

coming forward with a contrary number, as you suggest 0.1 ppm 

will likely become the de facto standard. I’ve asked DHS [the 

OHA team] to come over this week for a discussion on risk, the 

standard and what we might expect from the Expert Panel. I 

propose we have this discussion before considering approval of the 

CDC Sampling Plan. And we have not yet seen a draft of that 

sampling plan.” 

FEMA Responses to Formaldehyde in Trailers 

Page 48 
The Deputy Administrator responded: 

“All good info. I do want a discussion here before a sampling plan 

is approved. Want to ensure that we have our media and Hill 

message ready, are engaged with our State partners, and have 

DHS up to speed. We need to look forward to anticipate the 

readings we are going to get, compared to the 0.1 ppm standard, 

and how we are going to respond when and if that level is 

exceeded. This is a big deal that merits a brief to the Chief 

[FEMA Administrator] to gain his approval. I’ve included [a 

public affairs officer] on this email to ensure that this ratchets up 

on the agenda in External Affairs.” 

One week later, on October 29, 2007, the CDC liaison with FEMA 

emailed several of his FEMA official contacts: 

“I received a telephone call on Friday from [the OHA team 

leaders] in which they told me that in briefing the [FEMA Deputy 

Administrator] that a decision had been made that FEMA wanted 

to put our sampling on hold until they could determine a ‘level of 

exposure number for formaldehyde that all or most reasonable 

people would consider safe.’ This being necessary in case we 

found numbers in our sampling that it was determined would 

preclude further occupancy of the unit. I need something official 

from you as project officer that relays this request to me so that I 

can contact our contractor and put them on hold again. You know 

that we made an accommodation last week and delayed the project 

for a week at your request so that FEMA could do messaging 

around the sampling issue; this delay will no doubt cause our 

contractor some hardship and I would expect that they will charge 

the contract due to expenses that they have and will incur as a 

result of this delay. Please let me know ASAP what your wishes 

are.” 

Later that day, the FEMA formaldehyde project coordinator emailed the 

Deputy Administrator: 

“This is a courtesy notification that we have initiated the action to 

stop CDC work on the assessment of occupied trailers until we 

have an approved FEMA engagement plan. We are aware that 

action may result in additional costs beyond the planned contract 

and we accept that. Tuesday we will back up the initial verbal 

notification with written notification via the KO/COTR 

[Contracting Officer/Contracting Officer’s Technical 

FEMA Responses to Formaldehyde in Trailers 

Page 49 
Representative] mechanisms. In the meantime we have worked 

with our EA [External Affairs] staff and the CDC EA staff to draft 

a ‘Response to Query Only’ statement on the reason for the delay.” 

The Deputy Administrator replied: 

“I am fine with the stop-work notification. As we discussed last 

week, this is a big step in our process that I do not think we are 

ready in all respects to take.” 

The FEMA Public Affairs Office would later issue the following 

statement: 

“Testing was to have begun the first week of November, but 

previously scheduled appointments have been postponed until 

health and environmental experts finalize the testing process and 

action levels for responding to the results of the testing are 

determined.” 

CDC officials told us that the contract they had with the contractor on site 

in the Gulf Coast to conduct testing did not allow for the type of stop-work 

order that FEMA officials wanted. The contract had to be canceled using 

the standard clause that allows contracts to be canceled “at the 

convenience of the Government.” In such cases, the government has to 

compensate the contractor for the expenses it has incurred to date in the 

contract. In this case, once the contractor had pulled back its equipment 

and staff from the testing area, the total cost to the government for 

canceling the contract came to approximately $150,000. 

Testing Effort for Occupied Trailers Gets Completed 

When FEMA officials were ready for the testing process to continue, CDC 

re-advertised for contractors to conduct the testing in the Gulf Coast area. 

On November 16, 2007, the CDC contact emailed FEMA officials: 

“Please be assured that we are proceeding with all haste to put in 

place a new contract for the formaldehyde sampling of the 500 

units in MS and LA, and at the present time we have adequate 

funds to proceed to contract.” 

FEMA Responses to Formaldehyde in Trailers 

Page 50 
 

On December 11, 2007, he notified FEMA that: 

“The contracting officer has just notified me that an award of the 

contract for the testing in occupied FEMA temporary housing units 

has just been made to...a large environmental testing firm.” 

CDC officials told us that, because they were fortunate in getting more 

competition when they competed this second effort at a testing contract, 

the second bid award was significantly lower than the first award had 

been; the savings more than covered the approximately $150,000 in closeout charges that had to be paid for canceling the first contract. 

Formaldehyde testing of 519 randomly selected occupied trailers in 

Mississippi and Louisiana started on December 21, 2007, and was 

completed on January 23, 2008. From that date, the contractor had 10 

days to wrap up its work and get the database to CDC. CDC officials had 

planned to complete their analysis in 10 to 14 days. 

On February 14, 2008, 22 months after early reports of formaldehyde 

problems from occupants of FEMA trailers, the FEMA Administrator and 

the CDC Director held the press conference to announce preliminary 

results of FEMA-sponsored CDC testing of FEMA trailers and mobile 

homes in Louisiana and Mississippi. At that conference, the CDC 

Director stated that CDC had found approximately one-third of the 

housing units had formaldehyde levels that could cause irritation and 

symptoms such as runny nose, cough, or even breathing problems for 

residents who were vulnerable to formaldehyde such as young children, 

older people, or individuals who already have airway diseases. 

Furthermore, around 5% of the FEMA units had formaldehyde levels that 

were so high that even residents without vulnerabilities could experience 

such formaldehyde-caused symptoms. The FEMA Administrator then 

announced that: 

“As a result of these preliminary findings FEMA is going to 

continue our aggressive action to provide for the safety and wellbeing of the residents of these travel trailers by finding alternative 

housing.” 

In addition, he stated in response to a question about future emergency 

housing plans: 

“We will not ever use trailers again. We may use mobile 

homes...But we will not use trailers again.” 

FEMA Responses to Formaldehyde in Trailers 

Page 51 
 

 

 

The CDC study was released as interim findings on February 29, 2008, 

and in its final version on July 2, 2008. The following table, which is 

slightly abridged from page 24 of the CDC final report, presents an 

overview of the results of the formaldehyde tests. 

CDC Formaldehyde Test of Occupied Trailers 

Brand 

Number 

in 

Stratum 

Number 

in 

Sample 

Formaldehyde 

GM1 

(ppb)2 

Range 

(ppb) 

Weighted 

Percentage 

>= 100 

ppb 

>= 300 

ppb 

Travel 

Trailers 

Gulf Stream 14,624 123 104 3-590 56% 9% 

Forest River 3,220 36 82 17-510 42% 6% 

Fleetwood 2,371 47 39 3-140 6% 0% 

Fleetwood 

CA 1,699 39 43 7-300 13% 3% 

Pilgrim 1,584 39 108 25-520 51% 3% 

Keystone 1,395 38 102 23-480 53% 11% 

Other 15,637 38 74 11-330 37% 3% 

Type Total3

 40,530 360 

Park 

Models 

Silver Creek 224 53 33 3-170 6% 0% 

Other 809 37 48 11-160 16% 0% 

Type Total 1,033 90 

Mobile 

Homes 

Cavalier 921 42 78 14-320 36% 2% 

Other 4,486 27 53 11-120 4% 0% 

Type Total 5,407 69 

Grand Totals 46,970 519 77 3-590 38% 5% 

Notes 

1. GM-geometric mean 

2. ppb-parts per billion (Divided by 1000 to get parts per million) 

3. Type totals include summations. 

Source: DHS-OIG abridgement of a table in the Final Report on Formaldehyde Levels in FEMA 

Supplied Travel Trailers, Park Models, and Mobile Homes issued by the Centers for Disease 

Control and Prevention on July 2, 2008. 

Of the 519 mobile homes, park models, and travel trailers tested, more 

than 170 units (approximately one-third) showed formaldehyde 

concentrations at or in excess of 100 ppb, “the level at which health effects 

have been described in sensitive persons.” Twenty-one of the units tested, 

more than 4%, had readings of more than three times that level, or greater 

than 300 ppb. Six of the trailers tested had formaldehyde readings in 

FEMA Responses to Formaldehyde in Trailers 

Page 52 
5 

25 

45 

65 

85 

105 

125 

145 

165 

185 

205 

225 

245 

265 

285 

305 

325 

345 

365 

385 

405 

425 

445 

465 

485 

505 

525 

545 

565 

585 

excess of 400 ppb. The overall mean formaldehyde reading for the units 

tested was 77 ppb, with a range of 3 ppb to 590 ppb of formaldehyde. 

Number of Units Tested by
 

Formaldehyde Concentration at Each Level
 

0 

10 

20 

30 

40 

50 

60 

Number of Units 

ppb (Parts Per Billion) 

The tested levels varied greatly by type of unit and by manufacturer. In 

general, travel trailers had significantly higher average formaldehyde 

levels than park models and mobile homes, but all types of units tested had 

some units that tested at greater than 100 ppb. 

Also, different travel trailer manufacturers’ units had very different levels 

of formaldehyde. The lowest mean reading for a manufacturer of travel 

trailers was 39 ppb, with a range of 3 to 140 ppb, while the highest mean 

for a manufacturer of travel trailers was 108 ppb, with a range of 25 to 520 

ppb. Of the six travel trailer manufacturers that supplied the most units to 

FEMA, only 6% of the best-performing manufacturer’s units exceeded 

100 ppb and none exceeded 300 ppb, and of the second-best 

manufacturer’s units, 13% exceeded 100 ppb and 3% exceeded 300 ppb. 

More than half of the tested units from the three poorest performing 

manufacturers exceeded 100 ppb; 51%, 56%, and 53%, respectively. In 

addition, more of their units exceeded 300 ppb in the tests; 3%, 9%, and 

11% respectively. 

Park model manufacturers’ units fared better than most travel trailer 

manufacturers in formaldehyde testing. The single separately tested 

manufacturer of park model units had a mean of 33 ppb of formaldehyde 

for its units tested, with a range of 3 to 170 ppb. Only 6% of its units 

exceeded 100 ppb in testing and none exceeded 300 ppb. A combined 

group of park models from other manufacturers, whose units were less 

FEMA Responses to Formaldehyde in Trailers 

Page 53 
used by FEMA, had a mean of 48 ppb and a range of 11 to 160 ppb. 

Sixteen percent of this group tested at greater than 100 ppb, but none 

tested at greater than 300 ppb. 

Mobile home testing results were higher than park model results but lower 

than the results of most travel trailer manufacturers. The only separately 

tested manufacturer of mobile homes had a mean of 78 ppb of 

formaldehyde, with a range of 14 to 320 ppb. More than one-third of its 

units exceeded 100 ppb of formaldehyde in the tests, and 2% of its units 

tested at greater than 300 ppb. Since fewer mobile homes from other 

manufacturers were used in the Gulf Coast region, their units were 

grouped together in one test group. That combined group had a mean of 

53 ppb, with a range of 11 to 120 ppb. Only 4% of these units tested at 

greater than 100 ppb and none tested at greater than 300 ppb. 

In general, CDC’s formaldehyde study shows a fairly wide range of 

exposure levels. All of the park models tested had a mean result of less 

than 50 ppb, as did the travel trailers of the two best-scoring 

manufacturers. The two groups of mobile homes tested both had means 

that were in excess of 50 ppb, but not by as much as the four poorestscoring manufacturers of travel trailers, three of whom had tested units 

with a mean of more than 100 ppb. The mixed group of mobile homes 

was the best of the tested groups in percentage of units scoring more than 

100 ppb, with only 4% doing so. However, the best-scoring manufacturer 

of park models and the best-scoring manufacturer of travel trailers tied 

with only 6% of their tested units scoring greater than 100 ppb, while the 

only individually tested manufacturer of mobile homes had 36% of its 

units test at greater than 100 ppb. 

The CDC study also noted that formaldehyde readings are higher during 

warmer weather and tend to decrease as a trailer ages. The CDC results, 

which were measured during the winter and only after the trailers had been 

lived in for about 2 years, may therefore under-represent the long-term 

exposure levels of FEMA trailer residents. The report concluded: 

“On the basis of the data reported here and in previous scientific 

reports and publications about adverse health effects associated 

with exposure to elevated formaldehyde levels, CDC recommended 

that FEMA relocate Gulf Coast residents displaced by hurricanes 

Katrina and Rita and still living in trailers.” 

Causes of Delay in the Testing Effort for Occupied Units 

FEMA administrative procedures and a lack of planning on how to 

announce the results of testing and its implications delayed testing of 

FEMA Responses to Formaldehyde in Trailers 

Page 54 
occupied units by nearly 4 months. But this appears to have been more 

the result of a lack of management effort rather than an intentional effort 

to delay testing until winter. 

We did not conclude that FEMA officials were trying to delay the CDC 

testing to a time when the results would be better. Although delaying the 

testing until the cooler weather of December and January probably did 

result in lower formaldehyde readings than would have been the case if the 

testing had been conducted in late summer or early fall, there is no 

evidence that FEMA officials delayed the process in order to obtain such 

lower formaldehyde results. Lower formaldehyde readings from testing 

would not necessarily have worked to FEMA’s interests. As one FEMA 

official noted in an email to other FEMA officials: 

“Conventional wisdom suggests that FEMA is withholding 

information to keep occupants in the trailers, yet in fact nothing is 

further from the truth....Cynics would argue that is why we’ve 

‘delayed’ testing until the cooler weather. Again, untrue. ...FEMA 

doesn’t need to test. We want Katrina victims out of travel trailers. 

We have acknowledged that there may be elevated levels of 

formaldehyde. The industry and their consumers have known this 

for years. And we don’t dispute that elevated formaldehyde levels 

have health effects. We have already researched and 

recommended mitigation strategies and urged occupants to work 

with us to explore and accept alternate housing options. 

Unfortunately, the remaining occupants are overwhelmingly 

reluctant to accept the options. Short of testing, and requiring 

federal actions, we are running out of administrative authorities to 

move or house these remaining Katrina victims. In the meantime, 

we are working closely with CDC to try and articulate a federal 

standard, and continue to lead research in mitigation strategies. 

This is just being smart as the largest block consumer and holder 

of travel trailers. It is not FEMA’s place to determine ‘safe.’ It 

would be nice to have defined for us a ‘safe’ level for future 

application of future THUs [temporary housing units] or disposal 

of current THUs. But the public health community should test, 

apply the results to the body of scientific knowledge and 

communicate guidance to all consumers and occupants, including 

FEMA.” 

Even though we did not find any indications that FEMA officials wanted 

to delay the conduct of testing, actions and lack of action by FEMA 

officials significantly delayed the testing of occupied units. In general, 

there was no urgency to test occupied units until a senior DHS official 

FEMA Responses to Formaldehyde in Trailers 

Page 55 
directed that medical professionals from the OHA become involved in the 

process. Before that time, most of the key officials’ experience, focus, 

goals, and frameworks of reference were in the areas of disaster recovery, 

legal liabilities, emergency housing, or scientific studies. Their primary 

focus over the prior 14 months of formaldehyde-related efforts was, 

unfortunately, not on the medical conditions of the occupants of the 

trailers. But, within 10 days of assigning medically qualified OHA staff to 

the formaldehyde problem, FEMA’s focus finally came to rest on the key 

actions that were needed. These included a statistically valid sample of 

occupied trailers being tested for formaldehyde and other VOCs, a 

medical evaluation through interviews with trailer occupants, a 

toxicological review recommending target levels based on past and 

ongoing research, and an engineering review looking for long-term 

engineering solutions for formaldehyde in trailers. Having officials with 

the right background and expertise helped FEMA focus its formaldehyde 

effort on the critical issues. 

But even after FEMA began to focus on the critical issues, it would be 5 

months before the first step of testing occupied trailers was ready to 

commence. Most of that time was needed to work out administrative 

details between FEMA and CDC because there was no existing 

interagency agreement in place between FEMA and CDC to undertake this 

type of health study. FEMA was not able to respond adeptly to such a 

situation calling for quick administrative action. It took more than 6 

weeks to issue a formal request to CDC asking for their assistance. CDC 

officials, while not critical of FEMA, told us that they were rather 

surprised at how long it took FEMA to get the formal letter of request to 

CDC, considering that FEMA officials had acted as if the matter was 

urgent. Furthermore, CDC officials had to keep asking FEMA to “shake 

loose” the letter that they had previously warned was necessary to get the 

effort underway. 

FEMA actions delayed CDC testing, but did not otherwise significantly 

interfere with it. We asked all of the CDC officials that we interviewed 

whether FEMA officials had in any way tried to influence the scientific 

conduct or outcomes of the study. Every one of the CDC officials we 

interviewed stated that in no way had FEMA officials made any attempt 

whatsoever to influence the scientific conduct or outcomes of the 

formaldehyde study. There had only been some minor conflicts 

concerning public affairs efforts. 

Once the testing process was in place, a questionable FEMA decision set 

the process back by another 2 months. The Deputy Administrator caused 

work on the testing of occupied units to be stopped just as testing was 

FEMA Responses to Formaldehyde in Trailers 

Page 56 
about to begin, resulting in the testing contract being canceled for the 

convenience of the government and resulting in more than an 8-week 

delay before another contract could be issued and a contractor put in place. 

The Deputy Administrator had the testing stopped because, in the absence 

of needed standards for “safe” levels of formaldehyde in trailers, it would 

be extremely difficult to communicate to the occupants of trailers just 

what degree of health threat they were facing. Also a plan was needed for 

how FEMA would respond and what actions it would take if the testing 

found that formaldehyde levels exceeded acceptable levels. In addition, 

the Deputy Administrator wanted to have a “message” ready for Congress 

and the media. All of these issues could and should have been anticipated 

prior to the commencement of the testing efforts, or could have been 

completed concurrently with the testing process. In any case, there never 

was, and still has not been, a determination of what constitutes a “safe” 

level of formaldehyde in travel trailers, and testing eventually went 

forward under a second contract without any such determination. 

Usually, such an arbitrary stop-work and contract cancellation order could 

have cost the government significant damages. However, in this case it 

worked out favorably because the second contract’s costs were lower than 

the first by more than the amount in damages that had to be paid to the 

first contractor. More important though, terminating the first contract 

delayed the testing process until winter when formaldehyde levels and, 

therefore, test results would be lower and delayed the announcement of the 

formaldehyde conditions to occupants by another 2 months. 

Conclusions 

Initiating testing of occupied trailers to determine the nature, causes, 

extent, and impact of the formaldehyde problem took far longer than 

necessary. Part of the reason is that the officials who were originally 

managing the program did not have the medical background or focus to 

take the necessary actions in an effective and expeditious manner, 

although they did attempt to reach out to scientific experts. Whenever 

FEMA clients face health or safety problems, it is important that qualified 

consultants quickly be made part of the problem management team. In the 

case of health issues, this means bringing in medically qualified persons. 

Once OHA personnel were part of the management team, they were able 

to help FEMA focus its efforts on medical priorities, as was appropriate in 

this case. OHA may not always have adequate resources to assist FEMA 

in such cases, but FEMA needs access to the type of expertise that they 

brought to the team. 

FEMA Responses to Formaldehyde in Trailers 

Page 57 
 

Health issues are a frequent component of disasters, and FEMA has 

interagency agreements to address many related health program needs. 

However, there was no such agreement in place for performing the types 

of testing and analysis that were needed in the case of the FEMA trailers’ 

formaldehyde problems. It is likely that such problems and needs will 

occur in the future. Given the amount of time and problems encountered 

in putting a single individual agreement in place, it would be beneficial to 

have a standing interagency agreement to provide such testing services in 

the future. 

The decision to stop testing occupied trailers to work on improving the 

FEMA message and provide trailer occupants with meaningful 

information explaining how to apply the data was not justified by the 

circumstances. The necessary preparation should have been done long 

before testing commenced or could have been done concurrently while 

allowing testing to go forward. Testing to determine the prevalence, 

extent, and nature of health threats should not be held up in order to 

develop or improve messages. 

Recommendations 

We recommend that FEMA: 

Recommendation #8: Develop a standing agreement with OHA 

or another organization to provide medical consultants as needed 

to help design approaches for dealing with client health issues in 

FEMA operations. 

Recommendation #9: Establish a standing interagency agreement 

with the CDC or another qualified agency to provide testing and 

evaluation services for future health threat issues. 

Recommendation #10: Develop policy and related guidelines that 

make clear that identification and analysis efforts related to health 

threats to FEMA clients are not to be stopped or held up except 

when absolutely necessary. 

FEMA Responses to Formaldehyde in Trailers 

Page 58 
Epilogue – Actions and Efforts Related to Formaldehyde in 

Trailers After the February 14, 2008, News Conference 

Although the scope of this report ends with the February 14, 2008, formaldehyde 

news conference, FEMA has subsequently continued efforts to address the 

formaldehyde problem and has instituted new efforts. There also have been a 

number of ongoing efforts and some new joint efforts with CDC. These efforts 

were outside the scope of our review and many are ongoing and still changing. 

All of the occupants whose trailers had been part of the formaldehyde testing by 

the CDC contractor were encouraged to have an individual “explanation session” 

with CDC and FEMA officials. CDC and FEMA representatives visited the 

occupants of the trailers and described how their unit had fared in the tests, what 

the test results implied, and what housing options were available to them. In 

addition, FEMA offered formaldehyde testing to all of the occupants whose units 

had not been included in the original sample of 519 trailers, but only when they 

requested such testing. The testing was conducted by the same firm that had 

performed the testing of the 519 units in the original tests, but under a FEMA 

contract rather than a CDC contract. As of October 15, 2008, the occupants of 

more than 3,500 FEMA trailers had taken advantage of this offer. 

FEMA’s goal was to find alternative housing for all residents of temporary 

housing units in the Gulf Coast area. Many of the occupants were in trailers that 

had been located on their property while they repaired their homes. Some of the 

occupants had completed repairs to the point where they could move back into 

their homes. It was not that difficult for those individuals to give up their trailer. 

But others were not so fortunate. Repairs to their homes were not yet complete 

because of disputes over insurance payments, the slowness of some assistance 

programs, the extent of damage to their residences, or other problems. Many of 

those individuals did not want to give up their FEMA trailers and move to 

alternative housing. Doing so would make it more difficult to complete the 

repairs to their homes, and some feared that moving away from their partially 

finished homes would leave them vulnerable to vandals and thieves. Other 

occupants of FEMA trailers were located on group or commercial sites. Many of 

those individuals and families had been renters before the hurricanes hit. Many 

were low-income families who were faced with the fact that much of the low-cost 

rental stock had been destroyed and the remaining rental properties had greatly 

escalated in price as a consequence of the reduced supply. FEMA offered 

alternative housing, such as FEMA-funded rentals and motel rooms, but many 

were reluctant to take these offers owing to doubts about what would happen to 

them when FEMA rental assistance was discontinued. 

Nevertheless, FEMA and local officials were successful in transferring most 

trailer occupants back into their private residences or to alternative rented houses, 

FEMA Responses to Formaldehyde in Trailers 

Page 59 
apartments, or motels. By October 15, 2008, only 11,461 households remained in 

FEMA trailers. 

FEMA is also working to develop a supply of emergency housing units that do 

not present significant formaldehyde problems. Some of the existing FEMA 

housing stock, particularly mobile homes, park models, and travel trailers from 

some manufacturers, have lower formaldehyde levels. 

All of the FEMA mobile homes were required to be constructed to HUD 

standards, including HUD restrictions on formaldehyde. Meeting those standards, 

however, does not mean that a unit will be below a formaldehyde level that is 

acceptable to FEMA. The HUD standards were originally designed to keep 

mobile homes below 400 ppb of formaldehyde. Although the 69 FEMA mobile 

homes tested by the CDC were below 400 ppb, one was greater than 300 ppb and 

around 25% of the units tested at more than 100 ppb. FEMA park model units 

actually fared better than FEMA mobile homes in the CDC tests. None of the 90 

park model units tested at more than 300 ppb formaldehyde and only around 10% 

of the units tested at more than 100 ppb. FEMA officials are having the mobile 

homes and park models that are in their usable inventory tested for formaldehyde 

and certified by a qualified contractor. Those units that have results within an 

acceptable level are being offered to states suffering disasters, such as Iowa after 

the 2008 floods. The levels of formaldehyde in the units are made known to state 

officials and the states have the option of rejecting any units that are above their 

respective acceptable levels. 

In addition, FEMA officials have developed specifications and designs for 

procuring future emergency housing stock that will not pose a formaldehyde 

threat of more than 16 ppb. Previously, in July 2007, the Acting Assistant 

Administrator, Disaster Assistance Directorate had directed that the 

implementation of contract specifications for the new park model units be halted 

because the plans had included using the HUD mobile home standards for 

formaldehyde in materials as the standards for the new park models. He directed 

that: “Those specs will not suffice. Please suspend any purchases until this issue 

is resolved.” 

By October 21, 2007, the Acting Assistant Administrator, Disaster Assistance 

Directorate, had announced, “We are using .015 as our current de facto standard 

for new purchases. This is .001 ppm below the NIOSH cellular-effect level.” 

There is some question as to the validity of this “cellular-effect” level. CDC 

officials told us that NIOSH officials made this determination because it was the 

lowest level that the metering devices available at that time could measure, rather 

than being based on any particular test data. Nevertheless, the 15 ppb 

specification, which has been subsequently revised to 16 ppb, is an extremely 

ambitious specification and if met, would make FEMA trailers among the most 

FEMA Responses to Formaldehyde in Trailers 

Page 60 
formaldehyde-free of any new trailers. Several trailer manufacturers, in testimony 

before a congressional committee, testified that they did not believe such a 

specification would be workable. In August 2008, however, FEMA officials told 

us that the majority of the park models being produced under the current contract 

are meeting this standard and that the rest are being sent back to the contractor for 

corrective work. FEMA’s intention is to purchase park models and mobile homes 

that will all be constructed to the new standard of 16 ppb, or less, in tested 

formaldehyde readings. 

In addition to the testing of the 519 occupied trailers in Louisiana and Mississippi, 

FEMA and CDC have cooperated in developing further research that examines 

the causes and effects of the formaldehyde problem. These efforts should lead to 

future trailers being much safer in terms of formaldehyde. 

On April 24, 2008, CDC released a study titled “Assessment of health complaints 

among pediatric residents living in FEMA temporary housing in Hancock County, 

Mississippi.” The purpose of the study was to determine whether there was a 

relationship between families living in FEMA trailers and their children having 

air-quality related illnesses. The study found similar illness patterns between 

children who had lived in FEMA trailers and children who had not. However, the 

availability of pre-Katrina data was limited and the fact that all of the children 

tested would likely have health effects from just living through the hurricane and 

its aftereffects placed limitations on the study. 

In a FEMA and CDC joint effort, sometimes referred to as the “chain-saw study,” 

to examine the causes of formaldehyde in trailers, four travel trailers from four 

different manufacturers were disassembled and a total of 45 formaldehydeemitting component parts were shipped to Lawrence Berkeley National 

Laboratory in California for analysis. The report of this analysis was released on 

May 8, 2008. Before disassembly, these four units had daytime formaldehyde 

readings of 35 to 78 ppb. The tests found that 44 of the 45 tested components 

actually met the HUD standards for components of mobile homes, even though 

the components of these travel trailers were not required to meet the standards. 

The study concluded that elevated formaldehyde levels in travel trailers are most 

likely due to the cumulative effect of too much formaldehyde-emitting material in 

too small a space with insufficient ventilation, even though construction materials 

individually meet standards generally used in the building industry. 

CDC officials told us of several additional ongoing or planned joint efforts of 

FEMA and CDC. These include a study of mitigation methods that might be used 

to reduce the formaldehyde levels of existing trailers; a “chain-saw” study of 10 

to 15 more units including mobile homes, park models, and travel trailers to 

determine what factors allow some to have low levels of formaldehyde and what 

factors cause others to have high levels; and a study to validate a type of meter 

FEMA Responses to Formaldehyde in Trailers 

Page 61 
that would allow for quick and easy testing of formaldehyde levels of FEMA 

trailers in the field. FEMA officials also reported that CDC and FEMA are 

making an initial combined investment of $14 million on a health registry and 

children’s health study to further examine and monitor the health impacts of 

formaldehyde on the subject population. 

Conclusions 

FEMA and CDC have undertaken significant efforts to address current 

formaldehyde exposure of trailer occupants and improve the formaldehyde 

exposure in future emergency housing. FEMA offered formaldehyde 

testing services to current occupants of FEMA trailers and has actively 

encouraged the occupants to accept alternative housing. FEMA is also 

working aggressively to develop new low-formaldehyde trailers. These 

development efforts, if successful, could set new standards of excellence 

in air quality for trailers in the industry. FEMA and CDC have supported 

and conducted research that has given new insight into the causes of 

formaldehyde problems and the steps that need to be taken to address such 

problems. Planned future research should help address the causes and 

effects of formaldehyde exposure and may assist in the development of 

much-needed residential formaldehyde standards. 

FEMA Responses to Formaldehyde in Trailers 

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Management Comments and OIG Analysis 

FEMA concurred with all of the recommendations we offered to improve 

efforts to promote and protect the health and safety of its clients. During 

the audit and after our fieldwork, FEMA officials took steps to address 

formaldehyde and other health and safety issues in emergency housing 

units. Based on FEMA’s comments and actions to date, all of the report’s 

recommendations have been resolved. FEMA will apprise us of its 

progress in implementing all of the recommendations within 90 days. We 

will close each recommendation when FEMA provides evidence that the 

recommendation has been fully implemented. 

Two issues raised in FEMA’s response to our draft report merit further 

clarification. FEMA officials believe the report was “unreasonable” in 

stating that “the contracts that FEMA entered into to purchase housing 

units did not result in units that had currently acceptable levels of 

formaldehyde.” We agree that FEMA contracting officers at the time of 

purchase did not have knowledge of the problems that subsequently 

developed or of the importance of addressing such problems. We believe, 

however, that the report presents a reasonable analysis of one of the 

factors that allowed trailers with formaldehyde problems into the FEMA 

housing supply. Analysis of such factors is appropriate to determining 

what the causes of the formaldehyde problems were and what corrective 

actions would be needed for the future. 

FEMA officials also believe “the report does not adequately emphasize the 

compelling fact that there were no established formaldehyde standards for 

travel trailers and no consensus in the health and regulatory communities 

as to what constituted acceptable residential formaldehyde levels.” We 

agree that there is a lack of formaldehyde standards for travel trailers and 

confusion as to acceptable residential standards. We believe, however, 

that issue is appropriately addressed in the “Formaldehyde Standards” 

section of the report. 

FEMA Responses to Formaldehyde in Trailers 

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Appendix A 

Purpose, Scope and Methodology 

This review was mandated by Congress under the terms of the 

Consolidated Appropriations Act, 2008 (PL 110-161). Specifically, the 

2008 Appropriations Omnibus Explanatory Statement provided that: 

“The IG is directed to investigate the Federal Emergency 

Management Agency’s (FEMA) policies and processes regarding 

formaldehyde in trailers purchased by the agency to house disaster 

victims. The IG shall investigate the process used by FEMA to 

collect and respond to health and safety concerns of trailer 

occupants; whether FEMA adequately notified occupants of 

potential health and safety concerns; and whether FEMA has 

proper controls and processes in place to deal with health and 

safety concerns of those living in trailers following disasters. The 

IG is to report its findings to the Committees on Appropriations, 

including any recommendations.” (Page 1026) and 

“Additionally, the Committees on Appropriations direct the 

Inspector General to report to the Committees on Appropriations, 

the Senate Committee on Homeland Security and Government 

Affairs, and the House Transportation and Infrastructure 

Committee regarding FEMA’s decision-making regarding 

formaldehyde in trailers.” (Page 1077) 

The objectives of our review were to determine: (1) how some of the 

FEMA emergency housing came to have formaldehyde problems; (2) 

when FEMA officials learned of the formaldehyde problems in the 

housing units; (3) what was done to protect housing residents and prevent 

further problems; and, (4) why it took as long as it did for FEMA officials 

to determine the extent of the formaldehyde problems in FEMA 

emergency housing units. 

The scope of our review included all FEMA actions and other significant 

events relating to formaldehyde in FEMA emergency housing units 

(mobile homes, travel trailers, and park models trailers) from procuring 

the first emergency housing units in the wake of Hurricane Katrina in 

early September 2005 through the joint FEMA/CDC press conference 

announcing the results of formaldehyde testing on February 14, 2008. We 

also sought relevant information related to those actions taken subsequent 

to that date that are clearly related to the reported actions and events. That 

additional information is reported in the epilogue section. 

We reviewed available files and documents relating to formaldehyde in 

FEMA emergency housing units, including all available FEMA email 

FEMA Responses to Formaldehyde in Trailers 

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Appendix A 

Purpose, Scope and Methodology 

documents from the period under review that included reference to the 

topic of formaldehyde. Quotes from these emails are referred to 

throughout this report. Because emails frequently have common errors of 

spelling or grammar, corrections were made as appropriate. However, in 

no case was the meaning or content of any email modified. 

We interviewed responsible officials from pertinent FEMA offices, 

including the Disaster Assistance Directorate, the Office of the Chief 

Counsel, the Logistics Management Directorate, the Occupational Safety 

and Health Office, the Gulf Coast Recovery Office, the Louisiana 

Transitional Recovery Office, and the Mississippi Transitional Recovery 

Office. We also interviewed officials from the DHS Office of Health 

Affairs, CDC, and ATSDR. 

We conducted fieldwork in Washington, DC; New Orleans and Baton 

Rouge, LA; Biloxi, MS; and Atlanta, GA. We conducted our review from 

February through October 2008 under authority of the Inspector General 

Act of 1978, as amended, and according to the Quality Standards for 

Inspections issued by the President’s Council on Integrity and Efficiency. 

The findings and recommendations in our report were prepared 

independently of any pending or anticipated litigation, and our report was 

not drafted to satisfy the evidentiary standards of a court of law. It is the 

position of DHS that nothing in the OIG report is an admission for 

purposes of litigation. 

FEMA Responses to Formaldehyde in Trailers 

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Appendix B 

Timeline of Key Events 

August 29, 2005 – Hurricane Katrina made landfall on the 

Louisiana/Mississippi state line. 

September 3, 2005 – The first FEMA trailers arrived in the Gulf Coast 

region. 

September 10, 2005 – The first FEMA trailer in the Gulf Coast region 

was occupied. 

September 24, 2005 – Hurricane Rita made landfall on the 

Texas/Louisiana state line. 

November 11, 2005 – OSHA conducted formaldehyde tests on 

unoccupied FEMA trailers in Purvis, MS. 

March 16, 2006 – A Biloxi television station reported on formaldehyde 

problems in a FEMA trailer. FEMA officials were quoted by the press as 

requesting that...“if anyone suspects a serious problem [with 

formaldehyde] to call the FEMA maintenance number at 1-866-877­

6075.” 

April 6, 2006 – A testing company found unacceptable formaldehyde 

levels in an occupied FEMA trailer. 

April 11, 2006 – A FEMA contractor tested a trailer’s formaldehyde 

levels at the occupant’s request. The results were high. 

May 17, 2006 – The Sierra Club issued a press release and reported they 

had tested occupied FEMA trailers, and formaldehyde levels, in most, 

ranged from approximately 100 ppb to more than 300 ppb. 

June 13, 2006 – Sierra Club officials wrote to the Acting Assistant 

Administrator, Disaster Assistance Directorate, and recommended that 

FEMA test trailers to determine formaldehyde levels, supplement 

manufacturers’ warnings, and tell trailer occupants to vent their units. 

June 14, 2006 – FEMA OGC received Hillard v. United States, et al., Civ. 

Action No. 06-2576 (E.D. La.) and the case was assigned to a FEMA 

litigation attorney. The Hillard plaintiffs asserted that the trailers provided 

by FEMA contained dangerous levels of formaldehyde and sought class 

action status, $1 billion in damages, and injunctive relief. FEMA OGC 

advised that because of the lawsuit, FEMA persons dealing with 

FEMA Responses to Formaldehyde in Trailers 

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Appendix B 

Timeline of Key Events 

applicants on formaldehyde issues must coordinate with the FEMA 

litigation attorney assigned to the case and the Department of Justice. 

June 14, 2006 – In response to concerns regarding whether a disaster 

victim’s death might be related to formaldehyde in a trailer, a FEMA 

official sent out an email: “Has the Agency conducted our own testing of 

the units? If not we need to do so ASAP and put this issue to rest or 

remove people from harm.” 

June 15, 2006 – FEMA OGC responded: “Do not initiate any testing 

until we give the OK. While I agree that we should conduct testing, we 

should not do so until we are fully prepared to respond to the results. 

Once you get results and should they indicate some problem, the clock is 

running on our duty to respond to them.” 

June 16, 2006 – FEMA officials decided to address the complaining 

occupants on an individual basis. Occupants should be directed to air out 

their units, run their air conditioners and: “As a final recommendation, we 

would swap out the unit for a used, renovated unit which would not 

present the off-gassing problems experienced in the new units....Further, 

OCG has advised that we do not do testing, which would imply FEMA’s 

ownership of this issue.” 

June 27, 2006 – A FEMA official emailed the Acting Assistant 

Administrator, Disaster Assistance Directorate, and other FEMA officials, 

and stated that FEMA had to move past OCC’s objections to testing and 

needed to prepare a safety notice for emergency housing unit occupants. 

The Acting Deputy Administrator for Recovery responded: “I discussed 

this with [FEMA official] yesterday, and his recommendation, which I 

support, is to mission assign EPA to do a full assessment of the 

formaldehyde problem, and make recommendations. Agreed that you 

should not wait to post notices.” 

June 28, 2006 – EPA, FEMA, and ATSDR officials discussed the concept 

of formaldehyde testing. 

July – August 2006 – More than 268,000 formaldehyde brochures were 

sent to trailer occupants. The brochure described formaldehyde, its 

effects, and actions occupants should take to reduce formaldehyde levels. 

September 18, 2006 – An EPA contractor commenced testing neveroccupied trailers at baseline and under two ventilation methods: by 

FEMA Responses to Formaldehyde in Trailers 

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Appendix B 

Timeline of Key Events 

running the air-conditioning with the bathroom vents open and by opening 

the windows and vents. 

October 19, 2006 – The testing of unoccupied units by an EPA contractor 

was completed and the contractor processed the preliminary data. 

Late November 2006 – FEMA received the EPA testing data and 

forwarded the data approximately 1 week later to ATSDR for analysis. 

February 1, 2007 – ATSDR sent their “Health Consultation” report on 

the analysis of EPA testing results to FEMA stating: “In summary, the 

opening of windows and vents was effective in reducing formaldehyde 

concentrations below levels of health concern.” 

March 17, 2007 – ATSDR sent a letter to FEMA warning that the 

February 1, 2007, “Health Consultation” report did not address the fact 

that formaldehyde may cause cancer, the report had been completed 

without a policy review by the senior technical staff, and the report was 

incomplete and perhaps misleading. 

March 22, 2007 – The FEMA Mobile Home Operations (MHOPS) 

Maintenance Coordinator issued revised formaldehyde guidelines to 

MHOPS Field Staff for handling complaints. 

March 23, 2007 – A FEMA official informed Congress that FEMA was 

not aware of any significant health risks to trailer occupants. 

May 1, 2007 – A national news report aired a feature titled “Toxic 

Trailers.” 

May 17, 2007 – A senior DHS official sought DHS OHA involvement in 

the problem and OHA contacted CDC regarding testing of occupied 

trailers. 

May 18, 2007 – A conference call was held with CDC regarding the 

formaldehyde issue. DHS OHA, on behalf of FEMA, continued 

formaldehyde discussions with CDC officials to shape the questions that 

needed to be addressed. 

June 12, 2007 – Policy was released directing the replacement of 

formaldehyde problem trailers with rental housing rather than with used 

trailers. 

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Appendix B 

Timeline of Key Events 

July 13, 2007 – FEMA sent a letter to the CDC Director formally 

requesting assistance in designing additional tests related to formaldehyde 

and enhanced strategies for mitigation. 

July 20, 2007 – The formal letter of request from FEMA for CDC 

assistance in testing and analysis of occupied trailers was received at 

CDC. 

July 31, 2007 – The FEMA Administrator issued an Interim Direction 

announcing several additional steps FEMA was taking to address 

formaldehyde concerns and to work more closely with occupants who may 

have concerns about formaldehyde exposure including an information 

portal for formaldehyde concerns and the provision of rental housing to 

replace trailers. 

August 16, 2007 – The FEMA interagency agreement with CDC for 

testing and analysis of occupied trailers was signed. 

October 2007 – The revised and updated version of the February 2007 

ATSDR “Health Consultation” addressing the testing of unoccupied 

trailers was issued. 

October 29, 2007 – FEMA officials caused a stop-work order to be placed 

on the testing of occupied trailers. 

December 11, 2007 – CDC awarded a new contract for testing occupied 

units. 

December 21, 2007 – The testing of occupied units commenced. 

January 23, 2008 – The testing of the 519 occupied trailers was 

completed. 

February 14, 2008 – The FEMA Administrator and the CDC Director 

held a joint press conference announcing the results of testing occupied 

trailers. 

February 29, 2008 – The interim CDC report on testing of occupied units 

was released. 

April 24, 2008 – The CDC report on assessment of children’s health was 

released. 

FEMA Responses to Formaldehyde in Trailers 

Page 69 
Appendix B 

Timeline of Key Events 

May 8, 2008 –The CDC contracted report on the testing of trailer 

components for formaldehyde emissions was released. 

July 2, 2008 – The final CDC report on the testing of occupied trailers 

was released. 

FEMA Responses to Formaldehyde in Trailers 

Page 70 
Appendix C 

Consolidated List of Recommendations 

We recommend that FEMA: 

Recommendation #1: Include specifications in contracts for future 

purchases of mobile homes, travel trailers, and park models that provide 

for acceptable maximum formaldehyde levels in units that are delivered. 

Recommendation #2: Establish quality assurance/quality control 

requirements to ensure that excessive formaldehyde levels will be 

prevented, and institute inspection procedures to detect and reject units 

with unacceptable formaldehyde levels. 

Recommendation #3: Promulgate a policy that any issue or problem that 

might affect the health and safety of occupants of emergency housing 

must be quickly forwarded to the responsible headquarters offices as 

defined in this new policy. 

Recommendation #4: Train FEMA and contractor “front-line” 

employees who have contact with disaster victims on how to respond to 

health and safety issues. 

Recommendation #5: Establish a policy that whenever a health or safety 

issue arises concerning its clients, all reasonable actions will be taken to 

determine the nature, cause, extent, and consequences of the problem. 

Recommendation #6: Whenever a problem might affect the health and 

safety of FEMA clients, such as occupants of emergency housing, 

promulgate consistent and effective guidance to the field concerning how 

to address such problems. 

Recommendation #7: Establish clear policy over the decision making 

processes related to matters of health and safety. This policy should 

mandate that responsible program and management officials make 

decisions after obtaining and considering all appropriate professional 

advice, including opinions and input from medical, scientific, and legal 

experts. Moreover, FEMA should ensure that responsible program 

officials and managers have access to critical information and advice 

related to the health and safety effects of all FEMA programs. 

Recommendation #8: Develop a standing agreement with OHA or 

another organization to provide medical consultants as needed to help 

design approaches for dealing with client health issues in FEMA 

operations. 

FEMA Responses to Formaldehyde in Trailers 

Page 71 
Appendix C 

Consolidated List of Recommendations 

Recommendation #9: Establish a standing interagency agreement with 

the CDC or another qualified agency to provide testing and evaluation 

services for future health threat issues. 

Recommendation #10: Develop policy and related guidelines that make 

clear that identification and analysis efforts related to health threats to 

FEMA clients are not to be stopped or held up except when absolutely 

necessary. 

FEMA Responses to Formaldehyde in Trailers 

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Appendix D 

Management Comments to the Draft Report 

FEMA Responses to Formaldehyde in Trailers 


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Appendix D 

Management Comments to the Draft Report 

FEMA Responses to Formaldehyde in Trailers 


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Appendix D 

Management Comments to the Draft Report 

FEMA Responses to Formaldehyde in Trailers 


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Appendix D 

Management Comments to the Draft Report 

FEMA Responses to Formaldehyde in Trailers 


Page 76 

Appendix D 

Management Comments to the Draft Report 

FEMA Responses to Formaldehyde in Trailers 


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Appendix E 

Report Distribution 

Department of Homeland Security 

Secretary

 Deputy Secretary 

 Chief of Staff for Operations 

 Chief of Staff for Policy 

 General Counsel 

 Executive Secretariat 

 Director, GAO/OIG Liaison Office 

Acting Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Federal Emergency Management Agency

 Administrator 

 Acting Deputy Administrator 

Acting Assistant Administrator, Disaster Assistance Directorate 

Acting Director, Office of Policy and Program Analysis 

 Assistant Administrator, Management 

FEMA Audit Liaison (Job Code: DC8M01) 

Office of Management and Budget 

Chief of Homeland Security Branch 

 DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

FEMA Responses to Formaldehyde in Trailers 

Page 78 
Appendix F 

OIG Contributors 

Kaye McTighe, Director 

Donald Norman, Senior Program Analyst 

Nigel Gardner, Senior Program Analyst 

FEMA Responses to Formaldehyde in Trailers 


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ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4199, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.