August 13, 2013

Proposed Formaldehyde Emissions 

Standards for Composite Wood 

Products

US Environmental Protection Agency

Washington, DC
Discussion Outline

 Overarching Principle: a Performance-Based Approach 

for All Types of Composite Wood Products

 Laminated Products

 Health Risk/Benefits Analysis

 Estimated Benefits are Not Sufficient to Support Any 

Regulation More Stringent than CARB Phase II

 Formaldehyde Health Risks Must Be Accurately Assessed for 

This and Any Future Regulations

 Technical Concerns

 Humidity and Temperature Studies
Proposed Rule Should Be 

Performance-Based

Principle = performance-based emission limits without bias against any resin or 

manufacturing technology 

 Technologies are capable of delivering composite panel products that emit at, 

or very near, the emissions levels for natural wood

 Encourages advancement in all technologies

 Provides the widest array of options for panel manufacturers as well as the 

downstream chain of commerce

 Harmonized with CARB

 Experience under CARB Phase II provides support for performance based approach

 Consistent with Congressional intent

The clear bias against UF resins in the proposed rule runs counter to the 

performance-based principle, is not supported by the science and is 

inconsistent with Congressional intent
Laminated Products Approach Is 

Inconsistent With Other Exemptions

Proposed approach for laminated products is inconsistent with the 

other elements of the proposed rule

• Other exemptions applied throughout the proposed rule are performancebased

• E.g., exemptions for platforms (core) bonded with NAF and ULEF

• Requires non-exempt laminated products (adhered with ULEF resins) to 

meet the emission standard for hardwood plywood while acknowledging 

that the exempt laminated products (adhered with NAF resins) may not 

meet the same standard
Other Concerns With Laminated 

Products Approach

Assumption that laminators will switch to NAF resin is unsupported by data

• Does not recognize the limitations on producers to switch to NAF resins (e.g., 

inadequate handling or pressing equipment, product performance issues)

• High conversion rate assumption (98% switch to NAF) is not supported by data 

from CARB Phase II exemptions 

If the switch to NAF resins does not take place as assumed, cost avoidance 

no longer sufficient justification for the NAF exemption

No emissions data to support the NAF-only exemption
Estimated Benefits are Not Sufficient to Support 

Any Requirements More Stringent than CARB 

Phase 2

• The great majority of EPA’s estimated benefits involve avoiding cases of 

nasopharyngeal cancer (NPC)

• EPA’s risk assessment methods yield vastly overestimated incidence of NPC 

relative to National Cancer Institute (NCI) data on actual incidence

• EPA methods result in estimated incidence of NPC from formaldehyde 

exposure alone many times greater than NCI data on incidence of NPC 

from all causes. This is clearly impossible –- there are many causes for 

NPC in addition to formaldehyde exposure

Estimated Annual Incidence of Nasopharyngeal Cancer (NPC) Per 100,000

Due to Formaldehyde Exposure. Estimated Using EPA's Methods

Actual Data: Annual 

Incidence of NPC Per 

100,000 From All 

Causes (SEER*)

Ratio: EPA Estimate of NPC 

Incidence from HCHO Exposure 

to SEER Estimate of NPC 

Incidence from All Causes Individuals Estimated U.S. 

Population (2008)

Estimated # NPC 

cases per year

Annual Incidence 

per 100,000

Infants 0-1 9,332,890 439 4.7 0.002 2468

Children 2-15 60,105,502 5,313 8.8 0.01 796

16 and over 229,667,609 31,322 13.6 0.75 18

Total 299,106,000 37,074 12.4 0.60 21

* SEER Cancer Statistics Review 1975 - 2010. Tables 20.8 and 20.9
Technical Information on Our 

Calculations for NPC Incidence

Calculations using EPA’s methods:

• Unit cancer risk is drawn from IRIS (1991), ADAFs are applied for infants and 

children

• Exposure concentrations. For those in new and renovated housing, baseline ADC 

before implementation of CA standards is drawn from Docket # 2012-0018-0489 

(HCHO Results Matrices) for each population group. For others, ADC is assumed at 

year 10+ (after HCHO emissions abate from CWP) values from same Docket #.

• Exposed populations. Used EPA estimates for those in new and renovated housing. 

For those not in new or renovated housing, we distributed the remainder of the 

2008 US population using EPA’s estimated proportions by age and housing type

• Simplifying the calculations: we collapsed the 6 temperature/humidity climate 

zones into one, using values for Climate Zone 4 (relatively high exposure levels). 

We collapsed the 11 CWP house age groups into one, applying the exposure 

concentrations that EPA estimated for year 3-4 as the average over all 11 years 

(roughly equivalent to EPA’s assumed 1 1⁄2 yr emissions half life)

Calculations using NCI data:

• NCI provides age-distributed data on incidence only for all cancers of the oral 

cavity and pharynx, and not for NPCs only. We assume that NPCs are distributed by 

age in the same proportions as all cancers of the oral cavity and pharynx are 

distributed by age
Likely Reasons for EPA Overestimating 

NPC Risks and Benefits

• The World Health Organization (WHO) concluded that “... no excess 

nasopharyngeal cancer was reported at a mean formaldehyde 

exposure at or below 1.25 mg/m3...” (WHO, 2011)

– EPA instead assumes no such threshold and applies the 1991 IRIS unit cancer 

risk estimate

– EPA’s use of this outdated value is not appropriate. The NRC conducted an 

independent review of the IRIS assessment of formaldehyde and has 

signficantly challenged EPA’s evaluation.

– EPA estimates that mean residential exposure to formaldehyde, even with large 

assumed contribution from CWPs before CA standards, rarely exceeds even 100 

ug/m3

• Not appropriate to apply ADAFs

• Should use some version of “lowering factor”

• Various issues involving fatal vs. non-fatal NPCs, timing of cancers 

avoided, monetization

• Exposures due to CWPs may be overestimated: assumed rates of 

new home construction and renovation are too high
EPA Should Accurately Estimate Risks and 

Benefits for Other Health Effects, If Any

• Sensory irritation/eye irritation

– WHO (2010) concluded that a value of 125 ug/m3is considered 

safe for the entire population, including children, exposed in 

an indoor environment 24 hours per day. No risks or benefits 

should be estimated for exposures below this level.

– EPA analyzed 2 cases: benefits all the way down to 0 ug/m3 and 

benefits down to only 40 ug/m3. Why did EPA choose these 2 

levels?

• We will provide comments supporting no quantification 

of benefits for possible asthma and fertility impacts
Humidity and Temperature Testing Should 

Not Be Used To Justify Disparate Treatment 

of ULEF

• Basis for emissions in the statute set in accordance with 

ASTM E-1333, which prescribes humidity and temperature test 

conditions

• The statute clearly states that EPA is required to promulgate 

regulations implementing the emissions standards to ensure 

compliance

• These emissions standards are to be set based on test 

method ASTM E-1333

• Therefore, to rely on humidity and temperature tests that 

far exceed the prescribed ASTM E-1333 is inconsistent with the 

statute
Frihart Study Should Not Be Used For 

Regulatory Purposes

• Emissions test method EN 717-3 was used; not correlated 

with ASTM E-1333

• Used static or stagnant testing environment, not 

representative of normal use

• Used extreme “outdoor” temperature and humidity test 

conditions, again not representative

• Extremely high edge exposures of panels potentially 

exaggerates emissions results

• The study had no long term VOC emission decay data

• Reduction in material properties lead to product failure
Riedlinger Study Does Provide Valid 

Test Results

• Use of two labs and different analytical methods not 

uncommon

• Both labs used test methods correlated to ASTM E-1333 

through approved certified TPC

• Both labs also correlated with one another

• Tests were begun on the same day

Key finding in Riedlinger: specifying adhesive types may 

not make a difference – saw similar emissions responses 

regardless of adhesive chemistry employed
Battelle’s Use of Elevated Temperature and 

Humidity May Lead to Overreporting

While the Battelle study followed accepted test methodologies, its use 

of elevated temperature and humidity may lead to overreporting

• Concerns based on drawing conclusions solely based on small chamber 

emissions

• Under extreme conditions, small chamber was 25-50% higher than 

large chamber readings, suggested emissions may be overreported

• Small chamber results not representative of differences expected in 

large chamber tests, suggesting significantly overestimating magnitude of 

effects on emissions expected in large chambers

• No decay information evaluated

Battelle study’s use of elevated temperature and humidity does not 

reflect real world exposures
Formaldehyde Panel Contact:

Jackson Morrill

Director, Formaldehyde Panel

American Chemistry Council

700 Second Street NE, Washington, DC 20002

Work: (202) 249-6712

Cell: (202) 603-5957

Fax: (202) 330-5646

jackson_morrill@americanchemistry.com