## 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

Princip le = performance

- based emission limits without bias against any resin or manufacturing technology
 T echnologies are capable of delivering composite panel products that emit at, or very near, the emissions levels for natural wood
 E ncourages advancement in all technologies
 P rovides the widest array of options for panel manufacturers as well as the downstream chain of commerce
 H armonized with CARB  Experience under CARB Phase II provides support for performance based approach
 C onsistent 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 performance

based

• 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/m 3 

### ...” (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/m 3



### • 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/m 3 

### is 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/m 3 

### and benefits down to only 40 ug/m 3 

### . Why did EPA choose these 2 levels?



## • We will provide comments supporting no quantification of benefits for possible asthma and fertility impacts

# H umidity 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 O verreporting

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