# Toxic Baby Furniture
The Latest Case for Making Products Safe from the Start

# Toxic Baby Furniture The Latest Case for Making Products Safe from the Start

Environment California Research & Policy Center

Travis Madsen Frontier Group

Rachel Gibson Environment California Research & Policy Center



# May 2008

# Acknowledgments

Environment California Research & Policy Center gratefully acknowledges Alfred Hodgson and Raja Tannous at Berkeley Analytical Associates, LLC for performing the emissions testing described in this report and for providing technical guidance. Additionally, we thank Dr. Mark J. Mendell of the Lawrence Berkeley National Laboratory, Gretchen Lee of the Breast Cancer Fund, and John Rumpler of Environment America Research & Policy Center for their insightful review.

Funding for this report was provided, in part, by the Public Health Trust, a program of the Public Health Institute, through a defendant’s settlement of a legal complaint. Additional generous financial support from The California Wellness Foundation and Clarence E. Heller Charitable Foundation made this report possible.

The opinions expressed in this report are those of the authors and do not necessarily reflect the views of our funders or those who provided review. Any factual errors are strictly the responsibility of the authors.

Copyright 2008 Environment California Research & Policy Center

Environment California Research & Policy Center is a 501(c)(3) organization. We are dedicated to protecting California’s air, water and open spaces. We investigate problems, craft solutions, educate the public and decision makers, and help Californians make their voices heard in local, state and national debates over the quality of our environment and our lives.

Frontier Group conducts independent research and policy analysis to support a cleaner, healthier and more democratic society. Our mission is to inject accurate information and compelling ideas into public policy debates at the local, state and federal levels.

For more information about Environment California Research & Policy Center, or for ad

ditional copies of this report, please visit our Web site at www.environmentcalifornia.org.

Cover photo credit: Fred Goldstein, istockphoto.com Design and layout: Harriet Eckstein Graphic Design

# Table of Contents

Executive Summary 1

Intr oduction 5
The He alth Risks of Formaldehyde Exposure 7 Formaldehyde Is an Indoor Air Pollutant 7 Formalde hyde Exposure Is Associated with Allergies, Asthma, and Cancer 9 

# Testing Results: Many Baby Nursery Furnishings Emit Formaldehyde 11 Furniture Containing Composite Wood Showed the Highest Emissions 11
A Home Furnished with High-Emitting Products Likely 13 Increases a Child’s Risk of Developing Allergies or Asthma Other Products Emitted Less Formaldehyde 15 

# How the Current Chemical Regulatory System Fails Children 18 Inadequate Resources and Legal Authority Often Prevent Regulatory Action 18
Form a ldehyde Is Just One of Thousands of Hazardous Chemicals on the Market 21 

# A New Approach: Green Chemistry 22 Methodology 26 Appe ndix: Detailed Product Identification & Testing Results 28

Notes 30

### Executive Summary 

# Executive Summary



# F urnishings containing formaldehyde —a toxic chemical linked with allergies, asthma, and cancer—can contaminate indoor air within California homes. Babies and young children are particularly vulnerable to harm. To evaluate the potential dangers children face, Environment California Research & Policy Center purchased 21 products intended for use in a baby’s nurs

ery and hired a professional laboratory to test them. We found that six of the prod

ucts produced high levels of formaldehyde vapor. In particular, several brands of cribs and changing tables emit formaldehyde at levels linked with increased risk of develop

ing allergies or asthma. To protect children from formal

dehyde and other chemical hazards, California should adopt a new approach to chemical regulation, encouraging manufac

turers to design products that are safe from the start.

Many baby nursery furnishings emit formaldehyde.

• Of the products tested, the Child Craft Oak Crib emitted the largest amount of formaldehyde. The crib includes a drawer made from composite wood, which is oftenmanufactured using formaldehydebased glue.

• Other products with high formalde

hyde emissions included the Bridget 4-in-1 Crib by Delta, the Kayla II Changing Table by Storkcraft, the Berkley Changing Table by Jardine Enterprises, the Country Style Changing Table by South Shore Furniture, and the Rochester Cognac Crib by Storkcraft.

• The remaining 15 products tested— including the Olympia Single Crib by Jardine Enterprises; several waste

baskets, lamps, and shelves made with composite wood; and several window valances and wall hangings—emitted relatively low amounts of formaldehyde.

A baby sleeping in a nursery fur

nished with a high-emission crib and changing table may face an increased risk of developing allergies and/or asthma.

### Toxic Baby Furniture 

### • A new single-family home furnished with only a Child Craft Oak Crib and a Storkcraft Kayla II Changing Table would have indoor formaldehyde levels of about 30 parts per billion (ppb) on average throughout the whole house. A less spacious unit in a new apartment building would have indoor formaldehyde levels as high as 52 ppb. (See Table ES-1.) These estimates exclude any additional formaldehyde emissions from building materials or other pieces of furniture within the home.

• Studies have shown that chronic exposure to formaldehyde at levels greater than 16 ppb in indoor air is linked with an increased likelihood of respiratory symptoms (such as cough

ing) and/or allergic sensitization in children. Indoor formaldehyde levels greater than 50 ppb have been associ

ated with an increased risk of diag

nosed childhood asthma.

• Formaldehyde appears to have a large impact on children’s respiratory health. For example, in one study, 16 percent of children in homes with formaldehyde levels less than 16 ppb had diagnosed asthma, while 44 per

cent had asthma in homes with indoor formaldehyde concentrations greater than 40 ppb.

• Moreover, contamination levels could be higher close to the source of emis

sions. For example, in a lightly venti

lated nursery furnished with a Child Craft Oak Crib, formaldehyde levels could be as high as 75 ppb. Formalde

hyde exposure could be even higher for an infant actually sleeping in the crib, very close to the source of emissions.

Formaldehyde exposure can cause cancer in the long term.

• The State of California and the International Agency for Research on Cancer classify formaldehyde as a known human carcinogen.

• Under Proposition 65, California has determined that exposure to form

aldehyde at 40 micrograms per day (equivalent to an indoor concentra

tion of about 2 ppb) results in a 1 in 100,000 lifetime risk of cancer. Indi

vidually, the Child Craft Oak Crib,

Product Manufacturer	 Retailer	 Estimated Contribution to Indoor Formaldehyde Levels (ppb)

Child Craft Oak Crib Child Craft Target 23 40 Bridget 4-in-1 Crib Delta Wal-Mart	 11 18 Kayla II Changing Table	 Storkcraft Babies R Us	 6.9 12 Berkley Changing Table	 Jardine Enterprises	 Babies R Us	 6.2 11 Country Style Changing Table	 South Shore Furniture	 Target 4.2 7.2

Rochester Cognac Crib	 Storkcraft Target 3.6 6.2 New Single Family Home New Unit in Apt.Bldg. 

### Table ES-1: Estimated Contribution of the Top Six Formaldehyde Emitters to Indoor Air Pollution Levels

### Executive Summary 

### the Bridget 4-in-1 Crib, the Kayla II Changing Table, the Berkley Chang

ing Table, the Country Style Chang

ing Table, and the Rochester Cognac Crib each contain enough formalde

hyde to contaminate an entire home with levels of formaldehyde greater than this threshold.

Formaldehyde is just one example of how the chemical regulatory system fails to protect children from health hazards.

• Inadequate resources and legal author

ity often prevent regulatory agencies from taking protective action—even where significant evidence of harm to public health already exists. For ex

ample, federal regulators first became aware of links between formaldehyde vapor and respiratory health problems more than 30 years ago. However, stiff resistance from the chemical industry in the early 1980s largely thwarted new rules on formaldehyde emissions. Moreover, California declared form

aldehyde to be a toxic air contaminant in 1992—yet 16 years passed before the state successfully issued a regulation to limit emissions from composite wood.

• In addition to formaldehyde, about 1,400 chemicals on the market today have known or suspected links to cancer, birth defects, and other health problems. And tens of thousands more have not been adequately tested for health impacts.

To better protect children, California should reform its system of chemical regulation through the Green Chemis

try Initiative. This program should:

• Require chemical manufacturers to prove that each chemical they market is safe.

• Empower regulatory agencies to re

strict or ban the manufacture and use of chemicals that pose potential dan

gers, erring on the side of protecting human health and the environment.

• Ensure public access to information on chemicals and their uses through mandatory reporting requirements. 

# How We Estimated Indoor Air Pollution Levels 

# E nvironment California Research & Policy Center hired Berkeley Analytical Associates, LLC to test the formaldehyde emissions of selected baby nursery furnishings. Laboratory staff placed each product in an environmental chamber and measured the amount of formaldehyde vapor that that was released to air. We then extrapolated the results to estimate how much each product would contribute to the formaldehyde air concentrations within a typical home. (For technical details, see the Methodology section on page 26.)

###  Toxic Baby Furniture 

# For Parents Seeking to Minimize Children’s Exposure to Formaldehyde:

• Ask about the formaldehyde emissions of furniture, cabinetry and building products before you purchase and install them in your home.

• If such information is unavailable, avoid products with components made of raw medium density fiberboard or other types of composite wood.

• Ensure adequate ventilation within your home. Maintain moderate tempera

tures and humidity levels.

• Place pollution-absorbing plants—such as spider plants, Boston ferns, dwarf date palms, pot mums, or peace lilies—in your home.

Photo by stock.xchng

### Introduction 

# T his past year, parents got a rude awak

ening. Product recall after product recall made it abundantly clear that dangerous chemicals are making their way into a variety of products intended for children—and these products are finding their way onto store shelves. 1 

### For example, children playing with Aqua Dots, one of Wal-Mart’s best selling toys in the fall of 2007, fell seriously ill—even comatose—after swallowing the toy beads. It turned out that the beads were inadver

tently coated with a chemical that turns into the “date rape” drug gamma-hydroxy butyrate after ingestion. 2 

### Millions of ad

ditional children were exposed to products containing dangerous levels of lead, which can interfere with normal brain develop

ment. 3 

### However, countless additional products remain on store shelves, containing unreg

ulated but hazardous chemicals. Many of these chemicals can cause long-term health problems such as asthma or cancer. Parents can unknowingly bring these chemicals into their homes, where they can adversely affect the health of their families. In this report, we tell the story of form

aldehyde. Despite indications that indoor air contaminated with formaldehyde posed a threat to respiratory health as early as 1976, common consumer products—such as the baby nursery furnishings we identify in the pages that follow—can still emit formaldehyde. In April 2008, the California Air Re

sources Board finalized a new rule to limit the amount of formaldehyde emissions from products made of composite wood that are manufactured, sold or used in California. 4 

### With vigorous enforcement, this regulation will reduce our exposure to formaldehyde. However, formaldehyde—and the toxic substances involved in previous recalls— represent just the tip of the iceberg when it comes to chemical hazards in consumer products. There are more than 75,000 industrial chemicals on the market in the United States. 5 

### The health effects of almost half of the major industrial chemicals have not been studied at all. 6 

### Of those that have been studied, approximately 1,400 chemicals with known or probable links to cancer, birth defects, reproductive impacts, and other health problems are still in use today. 7 

### Many of these chemicals end up in products 

# Introduction

### Toxic Baby Furniture 

### that we buy and take into our homes, un

beknownst to consumers. When the federal government cre

ated the Toxic Substances Control Act in response to the PCB crisis 30 years ago, the chemical industry succeeded in making sure there were no new testing requirements placed on the tens of thou

sands of chemicals already in use. For new chemicals, the law required only a rapid pre-market screening based on existing information, and did not require toxicity testing for health effects. In other words, regulatory agencies can only act after a product has proven to be unsafe. This approach is far less stringent than the process for approving drugs, where the U.S. Food and Drug Admin

istration requires thorough pre-market testing and ongoing evaluation of drug effectiveness and safety. As a result, U.S. chemical regulation stumbles blindly, using an “innocent until proven guilty” model, allowing widespread exposure to toxic chemicals before they have been tested for safety. Moreover, where significant evidence of harm to public health already exists, inadequate resources and legal authority often prevent regulatory agencies from taking protective action. The Green Chemistry Initiative, launched by Governor Schwarzenegger and Secretary for Environmental Protec

tion Linda Adams in April 2007, offers an opportunity to try a different approach. 8 

### Green Chemistry “is a preemptive strat

egy to stop toxic substances before they contaminate the environment and our bod

ies.” 9 

### Green Chemistry seeks to reduce and eliminate hazardous substances in products by design, minimizing public health and environmental impacts from the start. If California gets the Green Chemis

try Initiative right, we can begin to of

fer parents new assurance that everyday consumer products are safe to bring home from the store and to use in caring for their families. 

# Formaldehyde represents just the tip of the iceberg when it

comes to chemical hazards in consumer products.

### The Health Risks of Formaldehyde Exposure 

# F ormaldehyde is a toxic chemical widely used in building materials and a variety of household products. For example, manufacturers use formaldehyde as a component in glues and adhesives, as a preservative in paints and related products,and as a means to give fabrics a permanentpress quality.When used in the home, formaldehydecontaining products can release the chemi

cal into indoor air. In particular, products made from composite wood containing urea-formaldehyde glue tend to create indoor air pollution. 10 

### Children chronically exposed to elevat

ed levels of airborne formaldehyde face an increased risk of developing allergic sensi

tivities and/or asthma. Moreover, the State of California and the International Agency for Research on Cancer classify formalde

hyde as a known human carcinogen.



# Formaldehyde Is an Indoor Air Pollutant The air within just about every indoor space in California contains measurable levels of formaldehyde. According to the California Air Re

sources Board, the average California home contains formaldehyde at more than 10 parts per billion (ppb). 11 

### In the most contaminated homes, formaldehyde levels exceed 200 ppb. 12 

### In one study published in 2000, findings showed that new homes—even before the addition of furnishings—had formaldehyde levels averaging 40 ppb. 13 

### Similar levels of contamination can be found in school classrooms, and levels in manufactured homes can be more than twice as high. 14



## Where Does Formaldehyde Contamination Come From? Consumer products and building materials manufactured using formaldehyde as an ingredient are a main source of indoor air pollution. Potential formaldehyde emission sources within a home include: 15



### • Furniture and building materials made from composite wood;

• Some types of fiberglass insulation; 

# The Health Risks of Formaldehyde Exposure

### Toxic Baby Furniture 

### • Permanent press textiles;

• Cosmetics (especially liquid fingernail products); and

• Combustion sources, including cigarettes.

In homes, composite wood products made with urea-formaldehyde resin are likely to be among the most significant sources of airborne formaldehyde. Manu

facturers use urea-formaldehyde because it is cheap and transparent. However, prod

ucts made with this adhesive tend to have very high formaldehyde emissions, which continue for several years after manufacture. 16 

### Heat and humidity tend to accelerate formaldehyde emissions, especially when a product is new. 17 

### In particular, Medium Density Fiber

board (MDF), a type of composite wood widely used in building materials and furniture, is a notorious source of formal

dehyde vapor in the home. 18 

### Particle board and hardwood plywood are two additional types of compressed wood made with form

aldehyde-based glue. Outdoor air also contains significant levels of formaldehyde as a byproduct of fuel combustion in cars and trucks. However, indoor sources of formaldehyde account for nearly 80 percent of a typical person’s daily exposure. 19



# The Home as a Toxic Environment 

# N ot all toxic chemicals enter the environment dripping from a factory waste pipe, leaking from a hazardous waste dump at the edge of town, or billow

ing into the air from an incinerator smokestack. Products made in factories and shipped to homes and offices around the state also contain hazardous materials, where they become an intimate part of the life of every Californian. Substantially more chemicals are shipped from factories to homes, contained within consumer products, than are spilled or dumped into the environment. Massachusetts, one of the few states where companies are required to report the amounts of chemicals they use and ship in products, provides a good illustration. In Massachusetts in 2001, for every one pound of chemicals released or disposed of, eight pounds were distributed in manufactured products. 20 

### Companies shipped thousands of times more of certain toxic chemicals—especially ingredients in plastics and personal care products—than they released into the environment. 21 

### As a result, children today grow up surrounded by many chemicals that did not exist a hundred years ago. Their food containers are made with plastic con

taining potentially harmful chemicals. Their homes and yards are treated with pesticides. Their families use cosmetics and personal-care products that contain hundreds of synthetic chemicals. Many of these chemicals escape from products and end up in household dust and in household air. 22 

### The chemicals have become such a close part of our lives that now they can be found in the blood and bodies of every mother and child. 23

### The Health Risks of Formaldehyde Exposure 

# Formaldehyde Exposure Is Associated with Allergies, Asthma, and Cancer Acute exposure to elevated levels of formaldehyde can irritate skin and re

spiratory tissue, leading to inflammation and triggering asthma attacks. When formaldehyde is present in the air at levels exceeding 100 parts per billion (ppb), some individuals may suffer from watery eyes; burning sensations of the eyes, nose, and throat; coughing; wheezing; nausea; and skin irritation. People repeatedly exposed to formaldehyde may develop a sensitivity to this chemical, increasing the severity of effects over time. 24 

### However, lower levels of formaldehyde also pose significant hazards, especially over longer periods of time. Scientific studies have linked long-term exposure to formaldehyde with increased odds of developing health problems ranging from asthma to cancer. Babies and young children are particularly vulnerable to harm since they are growing rapidly, with immature and vulnerable respiratory and other organ systems. 

## Children Chronically Exposed to Formaldehyde Are More Likely to Develop Asthma or Allergies In August 2007, Dr. Mark Mendell at the Lawrence Berkeley National Laboratoryin Berkeley published a review of peerreviewed scientific studies examining the health risks of exposure to indoor air pol

lutants, including formaldehyde. 25 

### He iden

tified 21 relevant studies, many of which linked formaldehyde exposure at levels commonly found in California homes to increased risk of respiratory symptoms, al

lergic sensitization, and doctor-diagnosed asthma. For example:



## • Dr. Martin Hooper at Monash University in Victoria, Australia, and his colleagues found that children exposed to formaldehyde at levels as low as 16 ppb in indoor air were more likely to show allergic sensitization and respiratory symptoms such as coughing. 26 

### Moreover, 16 percent of children in homes with formaldehyde levels less than 16 ppb had diagnosed asthma, while 44 percent had asthma in homes with indoor formaldehyde concentrations greater than 40 ppb.



## • Dr. Krassi Rumchev at the Curtin University of Technology in Perth, Australia, and his colleagues found that children between 6 months and 3 years of age chronically exposed to formaldehyde at levels higher than 50 ppb showed an increased prevalence of asthma. 27 

### The scientists studied a group of children with doctor-diag

nosed asthma, and a group of children of similar age without asthma. They then tested the children’s bedrooms and living rooms for formaldehyde contamination, controlling for tem

perature and humidity. The risk of a child needing treatment for asthma increased by 39 percent with resi

dential formaldehyde concentrations greater than 50 ppb—and the risk increased as formaldehyde levels in

creased.Photo by Nick Winchester

### 10 Toxic Baby Furniture 

## • Dr. Michal Krzyzanowski and his colleagues at the University of Arizona Health Sciences Center in Tucson found that children exposed to formaldehyde levels greater than 60 ppb were significantly more likely to have asthma or chronic bronchi

tis, especially in homes with elevated levels of second-hand tobacco smoke. 28 

### Children exposed to greater amounts of formaldehyde also showed sig

nificantly decreased measures of lung function—a child exposed to 60 ppb formaldehyde lost about 20 percent of exhalation force compared to an unex

posed child. Asthmatic children were particularly sensitive to this effect, while adults were less sensitive.



## • Dr. Peter Franklin and his colleagues at Princess Margaret Hospital for Children in Perth, Australia, found that children living in homes with formaldehyde levels greater than 50 ppb showed elevated levels of nitric oxide in their breath, an indicator of swelling deep within the lungs and development of asthma. 29



## • Dr. Jouni Jaakkola at the University of Helsinki in Finland and his col

leagues found that 8—12 year old schoolchildren were more likely to suffer from asthma, wheezing, or al

lergies when exposed to new linoleum flooring, synthetic carpeting, par

ticleboard, wall coverings, furniture, or new paint. 30 

### New particleboard and furniture—both likely sources of formaldehyde emissions—were significantly associated with allergies, and showed an association, albeit not statistically significant, with wheezing and asthma.

The scientific literature to date shows associations between formaldehyde ex

posure and inflammation of lung tissues, sensitization to allergens, and potentially altered immune system development in children, all of which are involved in the development and progression of asthma. 31



## Chronic Exposure to Formaldehyde Can Cause Cancer Formaldehyde exposure can also cause cancer in both humans and animals. The International Agency for Research on Cancer (IARC) and the State of California both classify formaldehyde as a known hu

man carcinogen. 32 

### Specifically, California lists formaldehyde as a carcinogen under Proposition 65. 33 

### In one of the many studies evaluated by IARC, workers with a greater exposure to formaldehyde showed a higher risk of developing cancer. 34 

### Industrial workers exposed to formaldehyde were more likely to die from cancer in the back of the throat (or nasopharyngeal cancer) when compared to typical American citizens. 35 

### The study also showed a link, albeit weaker, between formaldehyde exposure and leukemia. 36 

### The link is supported by experiments within the laboratory, which show that formaldehyde causes damage to DNA in the upper respiratory tissues of both hu

mans and rodents after inhalation. 37

### Testing Results 11 

# T o evaluate the potential dangers chil

dren face from exposure to chemicals, Environment California Research & Policy Center purchased 21 consumer products and tested their formaldehyde emissions. We took on the role of prospec

tive parent and looked for cribs, changing tables, window dressings, shelves, and re

lated items found in a typical baby nursery. We shopped at Babies “R” Us, Wal-Mart, and Target; both on-line and in-store. We looked particularly for items containing composite wood or permanent press fab

rics, which we believed could be potential sources of formaldehyde. We then hired a professional laboratory, Berkeley Analytical Associates, LLC, to test the products. Laboratory staff placed each product in a continuously ventilated environmental chamber for 24 hours and measured the amount of formaldehyde vapor that that was released each hour. We then extrapolated the results to esti

mate the contribution of each product to the formaldehyde concentrations in the air within a typical home. (For technical details, see the Methodology section on page 26.) We found that six of the products emit

ted formaldehyde vapor at high rates. (See Figure 1.) In particular, several brands of cribs and changing tables emit formal

dehyde at levels that increase the risk of children developing allergies or asthma.



# Furniture Containing Composite Wood Showed the Highest Emissions
Products with components made from composite wood showed the highest level of formaldehyde emissions. Of the products tested, the Child Craft Oak Crib showed the highest rate of formaldehyde emission. The crib includes a drawer made from composite wood. Other products with high formaldehyde emissions included:

• Bridget 4-in-1 Crib by Delta,

• Kayla II Changing Table by Storkcraft, 

# Testing Results: Many Baby Nursery Furnishings Emit Formaldehyde

### 12 Toxic Baby Furniture Table 1: Products with High Formaldehyde Emissions

Product Manufacturer	 Retailer	 Formaldehyde Emissions (micrograms per unit per hour)

Child Craft Oak Crib	 Child Craft Target 3,680 Bridget 4-in-1 Crib Delta Wal-Mart	 1,670 Kayla II Changing Table	 Storkcraft Babies R Us	 1,090 Berkley Changing Table	 Jardine Enterprises	 Babies R Us	 974 Country Style Changing Table	 South Shore Furniture	 Target 662

Rochester Cognac Crib	 Storkcraft Target 573 

### Figure 1: Formaldehyde Emissions of Selected Baby Nursery Furnishings



## 0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 

# Formaldehyde Emission Rate (micrograms per unit per hour) My First Doll Winnie Pooh Wall Shelf Alphabet Soup Wall Hanging Olivia Decorative Valance Lambs & Ivy Froggy Lamp Olympia Single Crib

Sugar Plum Lamp Lady Bug Waste Basket South Shore Changing Table Alphabet Soup Waste Football Wall Shelf Baby Cocoa Valance

Lauren 4-in-1 Crib Americana Lifetime Crib

Nursery-In-A-Box Crib Rochester Cognac Crib Country Style Changing Berkley Changing Table Kayla II Changing Table Bridget 4-in-1 Crib Child Craft Oak Crib



# Formaldehyde Emission Rate (micrograms per unit per hour)

### Testing Results 13 

### • Berkley Changing Table by Jardine Enterprises,

• Country Style Changing Table by South Shore Furniture, and

• Rochester Cognac Crib by Storkcraft.

Table 1 summarizes the test results for the highest emitting products, along with the product manufacturers and the retail outlets where they were purchased.



# A Home Furnished with High-Emitting Products Likely Increases a Child’s Risk of Developing Allergies or Asthma Placing just one or two of the products identified in this report as high-emitting sources into a home would result in sig

nificantly elevated indoor formaldehyde levels. For example, the formaldehyde con

centration in the air of a new single-family home furnished with only a Child-Craft Oak Crib would be greater than 20 ppb. Children chronically exposed to formalde

hyde at this level in one study were more likely to show respiratory symptoms such as coughing. However, the typical home likely contains more than one source of form

aldehyde emissions. Homes also can have poor ventilation, or small indoor volume. In these cases, formaldehyde levels could easily exceed 50 ppb, entering the range where scientists have observed increased risk of asthma and allergy development in children. 

## Indoor Formaldehyde Levels Formaldehyde concentrations within a home are dependent on three factors: 1) The volume of the home;

2) Its ventilation rate; and

3) The formaldehyde emissions of each product within the home.
Homes with low volume, poor ventila

tion, and a large number of formaldehydeemitting products will tend to have high levels of indoor air pollution. Conversely, large homes with high ventilation and few products emitting formaldehyde will have indoor formaldehyde levels closer to those in outdoor air. According to a June 2007 survey con

ducted by the California Air Resources Board, only 10 percent of California homes have adequate ventilation. 38 

### Increased focus on security, and especially energy conservation, limits ventilation rates. In other words, the typical California home is susceptible to high indoor air pollution levels. All other factors being equal, new homes will tend to have higher levels of indoor air pollution. Over time, home construction and home energy efficiency have improved, and new homes are increasingly better sealed against the outdoors. 39 

### However, new homes also are more like

ly to be larger than older homes, partially offsetting this effect. Looking at median estimates for single-family home size, for example, Berkeley Analytical Associates concludes that a typical new single-family home encloses about 60 percent more air volume than an existing home. 40



### Evaluating the Health Risks Posed by Individual Products To evaluate the health risks posed by each of the products tested in this report, we estimated how each product would impact indoor air quality in a typical home. The formaldehyde emission rate of each product was determined by Berkeley Ana

lytical Associates through closed chamber

### 1 4 Toxic Baby Furniture 

### testing. We then used assumptions about the size and ventilation rates of typical California homes to estimate each prod

uct’s contribution to indoor formaldehyde levels. The assumptions, developed by the laboratory, describe typical air volumes and ventilation rates of single-family homes and units in apartment buildings, covering both existing and new buildings. 41 

### (For full details, see the Methodology section on page 26.) Under these assumptions, smaller homes with low ventilation rates, typical of new units in apartment buildings, would be most likely to have high formaldehyde concentration levels with a given set of fur

niture. Correspondingly, existing singlefamily homes, with higher ventilation rates and the same furniture, would most likely have lower formaldehyde levels. Table 2 shows the estimated contribu

tion of each of the six products identified as having high formaldehyde emissions to whole-house formaldehyde concentrations in various types of residences.

Respiratory Risks To put the information in table 2 into context, scientists have observed that children exposed to indoor formaldehyde levels greater than 16 ppb show increased risk of allergic sensitization and respira

tory symptoms, and increased likelihood of having asthma at formaldehyde levels above 50 ppb. 42 

### A typical single-family home—new or existing—furnished with only a Child Craft Oak Crib would have indoor form

aldehyde levels above 16 ppb. If the crib were placed in a new apartment unit, in

door formaldehyde levels could approach 40 ppb. Add in a Storkcraft Kayla II Changing Table along with the Child Craft Oak Crib, and indoor formaldehyde levels would ex

ceed 50 ppb in a new apartment. These estimates are for typical homes. In homes with worst-case conditions— small indoor space and very poor ventila

tion—indoor air pollution levels could be considerably higher. Also, most homes contain additional furnishings and building materials that contain formaldehyde. Formaldehyde emissions from cribs and changing tables in a home will add to pollution from these other materials, increasing the odds that a high-emission product could expose a child to an increased risk of allergies or respiratory disease.

Table 2: Estimated Contribution of High-Emitting Products to Whole-House Formaldehyde Levels

Total House Concentration (ppb)

Product Name Existing New Existing New Single Single Apartment Apartment Family Family

Child Craft Oak Crib 17.6	 23.3	 29.4 39.8 Bridget 4-in-1 Crib 8.0	 10.6	 13.3 18.1 Kayla II Changing Table 5.2 6.9	 8.7 11.8 Berkley Changing Table 4.7 6.2 7.8 10.5 Country Style Changing Table	 3.2 4.2	 5.3 7.2
Rochester Cognac Crib 2.7 3.6	 4.6 6.2

### Testing Results 15 

### Contamination Levels Could Be Higher **within a Baby’s Nursery**A baby nursery containing formaldehydeemitting products will likely have higher concentrations of formaldehyde than the average levels throughout the home. Consider a hypothetical situation: a par

ent furnishes a 150 square foot baby nurs

ery with a Child Craft Oak Crib. Assume that this room is ventilated such that the air volume fully recycles once every hour. This nursery could have a formaldehyde concentration as high as 75 ppb. 43 

### If the nursery had poor ventilation, with one air change every two hours, formaldehyde concentrations could potentially reach 150 ppb or more. Moreover, formaldehyde exposure will likely be even higher the closer one gets to the source of the emissions. For example, the Child Craft Oak Crib utilizes a com

posite wood board to support the mattress, likely delivering elevated amounts of form

aldehyde to a sleeping infant. In the scientific studies on childhood re

spiratory health discussed earlier, however, estimates of children’s exposure were made by measuring formaldehyde concentra

tions in various rooms within a home. The health consequences of periodic exposure to elevated levels of formaldehyde, similar to what would be experienced by an infant periodically sleeping in a high-emission crib, have not been specifically studied.

Cancer Risks California’s Office of Environmental Health Hazard Assessment considers all formaldehyde contamination to pose a health risk, with no lower threshold associ

ated with zero risk. 44 

### However, for regulatory purposes un

der Proposition 65, California has set a long-term “no significant risk level” for cancer from formaldehyde exposure at 40 micrograms per day. 45 

### Exposure at this level over a 70-year lifetime would pro

duce one excess case of cancer in 100,000 people. 46 

### Under California law, exposure to formaldehyde above this level would require a posted warning for consumers. 47 

### A 40 microgram per day dose is roughly equivalent to an indoor formaldehyde concentration of 2 ppb. Individually, the Child Craft Oak Crib, Bridget 4-in-1 Crib, Kayla II Changing Table, Berkley Changing Table, Country Style Changing Table, and Rochester Cognac Crib each emit formaldehyde at sufficiently high rates to contaminate an entire home with levels of formaldehyde greater than this threshold.



# Other Products Emitted Less Formaldehyde In addition to the six cribs and changing tables identified as high-emitting products, we tested 15 other products with potential to emit formaldehyde. We examined sev

eral additional cribs and changing tables, plus lamps, shelves, and wastebaskets po

tentially made with composite wood parts. We also tested a few window valances, wall hangings, and a doll made with perma

nent-press fabric potentially treated with Photo by Levi Gruber

### 16 Toxic Baby Furniture 

### formaldehyde-containing chemicals dur

ing manufacturing. Almost all of these items emitted mea

surable amounts of formaldehyde, but at rates several orders of magnitude lower than the high-emitting cribs and chang

ing tables identified earlier in the report. (See Table 3.) We also estimated the contribution that each of these products would make to over

all formaldehyde concentrations within typical homes. (See Table 4.) Individually, none of these products would add more than 0.74 ppb formaldehyde to the indoor air of a home. In comparison, the average level of formaldehyde in outdoor areas of California is 3 ppb, exceeding 10 ppb in areas with high vehicle traffic. 48 

### We con

clude that these products individually pose a relatively small additional health risk. However, these products may cumu

latively contribute to measurable formal

dehyde air contamination within a home. For example, if a family furnished a new home with a Nursery-In-A-Box Crib and two additional items with equivalent emissions, indoor formaldehyde levels would just exceed the “no significant risk level” for cancer of 40 micrograms per day (equivalent to an indoor concen

tration of about 2 ppb) established under Proposition 65. 49



### Table 3: Products with Relatively Low Formaldehyde Emissions

Product Manufacturer	 Retailer	 Formaldehyde Emissions (micrograms per unit per hour)

Nursery-In-A-Box Crib	 Simplicity for Children	 Wal-Mart 69

Americana Lifetime Crib	 Jardine Enterprises	 Babies R Us	 62

Lauren 4-in-1 Crib Graco Target 36 Baby Cocoa Valance Lambs & Ivy Babies R Us	 16

Football Wall Shelf Trend Lad Target 11 Alphabet Soup Waste Basket	 CoCaLo Babies R Us 9

South Shore Changing Table	 South Shore Furniture	 Babies R Us 8 Ladybug Wastebasket	 Kids Line Babies R Us 6 Sugar Plum Lamp CoCaLo Babies R Us 6 Olympia Single Crib Jardine Enterprises	 Babies R Us	 <6

Lambs & Ivy Froggy Tales Lamp	 Lambs & Ivy Babies R Us 5 Alphabet Soup Wall Hanging	 CoCaLo Babies R Us 4

Olivia Decorative Valance	 Kids Line Babies R Us 4

Winnie Pooh Wall Shelf	 Crown Crafts Infant Products, Inc	 Babies R Us 3
My First Doll Koala Baby Babies R Us

### Testing Results 17 Table 4: Estimated Contribution of Low-Emitting Products to Whole-House Formaldehyde Levels

Total House Concentration (ppb)

Product Name Existing New Existing New Single Single Apartment Apartment Family Family

Nursery-In-A-Box Crib 0.33	 0.44	 0.55	 0.74

Americana Lifetime Crib	 0.30	 0.39	 0.50	 0.67

Lauren 4-in-1 Crib 0.17	 0.23	 0.29	 0.39 Baby Cocoa Valance 0.07	 0.10	 0.12	 0.17

Football Wall Shelf 0.05	 0.07	 0.09	 0.12 Alphabet Soup Waste Basket	 0.04	 0.06	 0.07	 0.10

South Shore Changing Table	 0.04	 0.05	 0.07	 0.09 Lady Bug Waste Basket 0.03	 0.04	 0.05	 0.07 Sugar Plum Lamp 0.03	 0.04	 0.05	 0.07 Olympia Single Crib <0.03	 <0.04	 <0.05	 <0.06

Lambs & Ivy Froggy Tales Lamp	 0.02	 0.03	 0.04	 0.05 Alphabet Soup Wall Hanging	 0.02	 0.03	 0.03	 0.05

Olivia Decorative Valance	 0.02	 0.03	 0.03	 0.05

Winnie Pooh Wall Shelf 0.01	 0.02	 0.02	 0.03
My First Doll 0.01	 0.01	 0.01	 0.01

### 18 Toxic Baby Furniture 

# T he story of formaldehyde encapsulates what is wrong with federal and state approaches to chemical regulation. First, inadequate resources and legal authority often prevent regulatory agen

cies from taking protective action—even where significant evidence of harm to public health already exists. In the case of formaldehyde, regulators first became aware of links between emissions in homes and respiratory damage and cancer in the 1970s. However, stiff resistance from the chemical industry has largely thwarted new federal rules addressing formaldehyde exposure. And in California, 16 years elapsed between official declaration of formaldehyde as a toxic air contaminant and rules limiting formaldehyde emissions from composite wood. Meanwhile, the number of children with asthma is rising. Childhood asthma doubled in prevalence between 1980 and 1995, reaching 7.5 per

cent of all children. 50 

### Second, formaldehyde is just one of more than a thousand chemicals on the market that have documented links to dis

ease. 51 

### And tens of thousands of additional chemicals on the market have not been ad

equately tested for health impacts. 52 

### Under California’s current approach to chemical regulation, these potential hazards willbe addressed on a piecemeal, chemicalby-chemical basis. Moreover, by the time regulators are able to draft and issue effec

tive rules, harm to public health will have already happened—and in many cases will have been ongoing for decades.



# Inadequate Resources and Legal Authority Often Prevent Regulatory Action
At the federal level, the primary law gov

erning industrial chemicals—the Toxic Substances Control Act (TSCA)—has failed to live up to its purpose of protecting the public from toxic exposures. Even with strong evidence that chemicals pose health hazards, regulators often lack either the legal authority or the political will to take protective action. Action must overcome resistance from consumer product manu

facturers accustomed to using a particular chemical, and from a chemical industry reliant on the profits from its sale. 

# How the Current Chemical Regulatory System Fails Children

### How the Current Regulatory System Fails Children 19 

### The history of regulatory action on formaldehyde provides a good example. 

## Federal Action on FormaldehydeIn the 1970s, many builders used ureaformaldehyde foam insulation (UFFI) to improve home energy efficiency. After installation of the material, homes showed elevated levels of formaldehyde vapor. 53 

### As early as 1976, the federal Consumer Product Safety Commission (CPSC) began to hear complaints of respiratory irritation from residents living in homes insulated with UFFI. 54 

### The CPSC began to investigate what might be causing the irritation, and whether a new regulation
was necessary. In 1979, researchers experimenting with rats discovered that formaldehyde can

cause cancer. 55 

### The CPSC, along with the U.S. Environmental Protection Agency (U.S. EPA), the Occupational Safety and Health Administration (OSHA), and other regulatory agencies evaluated the findings. They concluded that “the concentrations of formaldehyde in inhaled air that caused nasal cancer in ... rats are within the same order of magnitude as those to which hu

mans may be exposed.” 56 

### However, attempts to draft new regu

lations met with stiff resistance from the Formaldehyde Institute, a coalition of in

dustries dependent on the chemical. As the Reagan Administration came into office in 1981, the Formaldehyde Institute held a series of meetings with agency leaders. Actions to regulate formaldehyde at U.S. EPA and OSHA were curtailed shortly thereafter. 57 

### Public interest organizations and several members of Congress pointed to undue influence from industry in the decision not to act. 58 

### The CPSC established new regulations on UFFI, and ultimately voted to ban the product in February 1982. However, this action too was voided, after the Fifth Cir

cuit Court of Appeals upheld a lawsuit by the Formaldehyde Institute claiming that the CPSC used a flawed decision-making
process. 59 

### In 1985, the U.S. Department of Hous

ing and Urban Development (HUD) issued a limited regulation aimed at keep

ing formaldehyde levels in manufactured homes below 400 ppb. 60 

### This limited rule (which applies to hardwood plywood and particleboard used as building materialsin manufactured homes, but not mediumdensity fiberboard) is currently the only federal limit on formaldehyde in consumer products sold in the United States. 61 

### In comparison, Japan’s standards allow only one-tenth as much formaldehyde emis

sions. 62 

### The European Union also has stronger limits. 63 

### Even China has stringent limits on the formaldehyde content of building materials—although they do not apply to products exported to the United States. 64 

### California regulators estimate that the HUD standard still allows 23 to 63 excess cancer cases per million children exposed for nine years, and 86 to 231 excess cancer cases per million adults exposed over a 70-year lifetime. 65 

### Respiratory and allergic health impacts would affect many morePhoto by Teri Olle

### 20 Toxic Baby Furniture 

### children, if exposed to formaldehyde at this level. Moreover, the HUD standard only applies to wood used in manufactured homes, and not other types of products. In place of official regulation, the com

posite wood industry adopted voluntary standards for formaldehyde emissions, which have kept the emissions from the average composite wood product at about 40 percent below the HUD standard. 66 

### However, these voluntary limits have not gone far enough to reduce indoor formal

dehyde contamination to safe levels. 

## Formaldehyde Regulation in California California formally declared formaldehyde to be a toxic air contaminant in 1992. 67 

### The Office of Environmental Health Hazard Assessment recommended that “formal

dehyde be treated as having no threshold exposure level below which no significant adverse health impacts are anticipated.” 68 

### State law requires the California Air Resources Board (ARB) to take action to reduce public exposure to toxic air con

taminants, requiring the use of best avail

able control technology that is technically available and economically feasible. However, ARB took little official action on formaldehyde until 2001, when it pro

posed a ban on all composite wood products made with urea-formaldehyde resin. 69 

### The composite wood industry argued against the measure, and in 2003, ARB ultimately decided to hold off on a ban.



# California’s New Formaldehyde Emission Rules and the Products Tested in this Report 

# T he Child Craft Oak Crib is made with composite wood that very likely will not meet the upcoming ARB formaldehyde emission standards. The Bridget 4-in-1 Crib, the Kayla II Changing Table, and the Berkley Changing Table include composite wood parts that likely exceed the ARB standard. And the Country Style Changing Table and the Rochester Cognac Crib include parts that may exceed the standard. If the construction of these products is changed to use boards that will comply with the ARB regulation, they likely will emit much less formaldehyde. However, the new ARB regulation is limited in several ways:

• The regulation will not apply to products intended for sale outside of California.

• The regulation will not eliminate formaldehyde emissions from consumer products. For example, even under ARB’s most stringent limit for formal

dehyde emissions from medium density fiberboard, a home containing 20 square meters of the product would still contain 25 to 55 ppb formaldehyde, depending on home size and ventilation rate. To put that in perspective, seven bookcases with dimensions of 13” x 31” x 70” and with no lamination on the undersides of shelves and the rear of the unit, would have 20 square meters of exposed composite wood surface.

• The rule also applies only to composite wood. Products that use other types of formaldehyde-emitting materials will not be affected.

### How the Current Regulatory System Fails Children 21 

### Recent Regulation for Formaldehyde In 2006, ARB proposed a new regulation limiting the emissions of formaldehyde from composite wood boards. The regula

tion applies at the level of board manufac

turing, reducing allowable emissions from the raw materials later used in furniture and buildings. For particleboard and hardwood-ply

wood, the regulation limits allowable formaldehyde emissions to 259 micrograms per square meter of board surface per hour beginning January 2009, and to 129 by 2011-2012. Regulators set formaldehyde emission limits for medium density fiber

board at roughly double these amounts. 70 

### The new regulation officially became California law on April 18, 2008. 71 

### ARB estimates that the regulation will reduce formaldehyde emissions from composite wood products by 180 tons per year in the first phase, reducing individual exposures by 15 percent. In the second phase, ARB expects to reduce emissions by 500 tons per year, and individual exposures by 40 percent. 72 

### This new rule will help to reduce indoor exposure to formaldehyde. However, it comes more than 30 years after federal regulators identified formaldehyde as a potential respiratory hazard, and 16 years after California officially determined that formaldehyde was a toxic air contaminant.



# Formaldehyde Is Just One of Thousands of Hazardous Chemicals on the Market Formaldehyde is one of a vast expanse of chemical hazards facing children that grow up in today’s world. Most of these threats have yet to be effectively addressed by ei

ther the federal or the California chemical regulatory systems. Chemical manufacturers produce and market more than 75,000 different chemi

cals for use across the U.S. economy. 73 

### 1,400 of these chemicals have known or probable links to cancer, birth defects, reproductive impacts, and other health problems that plague our society. 74 

### And the health effects of almost half of the major industrial chemicals—roughly 1,500 com

pounds—have not been studied at all. 75 

### Many of these chemicals are becoming part of our very bodies in complex mixtures that have never been evaluated to deter

mine their impact on human health. For example, the Environmental Work

ing Group recently found 287 different chemicals in the umbilical cord blood of 10 randomly selected infants born in the United States. 76 

### These chemicals included “pesticides, consumer product ingredients, and wastes from burning coal, gasoline and garbage.” 77 

### Of the chemicals detected, 180 are known to cause cancer in humans or animals; 217 have toxic effects on the brain and nervous system; and 208 cause birth defects or developmental problems in experiments with animals. 78 

### No study has ever evaluated the impact of this complex mixture of pollutants on fetal or infant health. Under the current regulatory frame

work, the burden of proving harm falls upon those exposed to chemical hazards. Regulators are faced with the task of assessing risks faced by the public, one chemical at a time. They must document public exposure, uncovering where the chemical is produced, used, discharged, and disposed of. Then regulators must evaluate associations between exposure and diseases. Finally, regulators must go through the arduous process of crafting and issuing new rules—a process that can take decades between hazard identification and action to reduce public exposure, if it does not fail outright. The result is that children continue to be exposed to hazardous chemicals—such as formaldehyde—every day.

### 22 Toxic Baby Furniture 

# R eforming California’s chemical regu

latory system to require manufactur

ers to consider potential impacts onpublic health and the environment upfront, during product design, could provide a much more effective means to reduce our exposure to dangerous chemicals in consumer products. Recognizing this possibility, Gover

nor Schwarzenegger and Secretary for Environmental Protection Linda Adams launched the California Green Chemistry Initiative in April 2007. 79 

### Green Chemis

try “is a preemptive strategy to stop toxic substances before they contaminate the environment and our bodies.” 80 

### Green Chemistry seeks to reduce and eliminate hazardous substances in products by de

sign, minimizing public health and envi

ronmental impacts. In order to be meaningful, the Green Chemistry Initiative should be more than a voluntary, incentive-based program. The state needs to create the regulatory infrastructure to assess chemical safety and restrict or phase out the use of the most dangerous substances. If an effective Green Chemistry ap

proach had been in place in 1992 when California classified formaldehyde as a toxic air contaminant, children’s exposure to formaldehyde would look very different today. Instead of spending several decades studying exposure and characterizing shades of risk, regulators could have judged that formaldehyde, as an intrinsically hazardous chemical, should not be used in applications that lead to human exposure, especially where safer alternatives are avail

able. Guided by this judgment, composite wood, building material, and furniture manufacturers could have deployed al

ternative adhesives or materials free from formaldehyde emissions. The same process would have guided manufacturer decisions about other dangerous chemicals that still await meaningful regulatory action. The result would have been healthier indoor air for children to breathe and reduced exposure to a range of health-threatening substances. Now, we have an opportunity to make this vision a reality. If California gets the Green Chemistry Initiative right, we can begin to offer parents new assurance that everyday consumer products are safe to bring home from the store and to use in caring for their families. 

# A New Approach: Green Chemistry

### A New Approach: Green Chemistry 23 

# Alternatives to Formaldehyde Are Readily Available 

# M any companies across the U.S. are using healthier building materials and de

veloping safer alternatives to replace toxic products. Columbia Forest Products provides a good example. In 2005, Columbia Forest Products, North America’s largest manufacturer of hardwood plywood and hardwood veneer, announced its transition to PureBond®, a manufacturing technology that utilizes a natural adhesive composed primarily of soy flour and water. 81 

### Scientists designed the formula “to mimic the protein that marine mussels use to attach themselves to rocks and other hard surfaces.” 82 

### By March 2008, the company had converted all seven of its manufacturing plants to use this system, producing more than 25 million plywood panels with formaldehyde-free adhesive. 83 

### The conversion replaced millions of pounds of urea-formaldehyde, reducing emissions of hazardous air pollutants at the plants by up to 90 percent. 84 

### Plywood panels made with PureBond® already comply with the most stringent formaldehyde emissions limits put forward by the California Air Resources Board. 85 

### Moreover, they cost no more than panels made with the standard urea-formal

dehyde adhesive. 86 

### In 2007, U.S. EPA recognized Colum

bia Forest Products for this achievement with a Presidential Green Chemistry Challenge Award. 87 

### Other alternative adhesives are avail

able to manufacture particle board and fiber board with ul

tra low formalde

hyde emissions. 88 

### In addition, everyday building materi

als—such as stone, brick, metal, glass, and solid wood—are generally formaldehyde-free. Furniture, cabinetry and build

ings made of these materials do not emit formaldehyde. The Green Chemistry Initiative should ensure that manufacturers identify and prioritize safer alternatives to many different varieties of toxic chemicals, much as Columbia Forest Products has done with formaldehyde-based adhesives. Columbia Forest Products and BuildingGreen.com

### 2 4 Toxic Baby Furniture 

# Policy Recommendations

Comprehensive chemical regulatory re

form is necessary to improve our knowl

edge of chemicals used in commerce, encourage the use of materials and pro

cesses most likely to be safe, and enable the government to take action to protect public health and the environment from the great

est threats, when warranted. In order to protect children from toxic exposures, the Green Chemistry Initiative should include the following directives:

Require chemical manufacturers to prove that a chemical is safe before al

lowing it on the market.

• Regulators should require companies to provide comprehensive data on the intrinsic hazards of chemicals that they produce or import into Califor

nia. Such data should include informa

tion on a chemical’s ability to persist in the environment, accumulate in living organisms, be metabolized into other hazardous compounds, cause genetic damage, mimic important hormone signals, interfere with hu

man development or reproduction, weaken the immune system, damage the nervous system, cause respiratory disease, or otherwise harm human health.

• Chemical testing should include spe

cific consideration of potential impacts on infants, children, and pregnant women; potential impacts of low-dose exposures; and potential interactions with other toxic chemicals.

• The reliability and adequacy of the information should be validated by government scientists and/or an inde

pendent third party free of conflicts of interest. Empower regulatory agencies to re

strict or ban the manufacture and use of chemicals that pose potential dangers to human health or the environment.

• Where chemicals show evidence of in

trinsic hazard—such as a tendency to persist in the environment, accumu

late in living organisms, or cause toxic effects—regulators should restrict or prohibit the use of these chemicals and require the substitution of safer alternatives, particularly in consumer products or other applications that lead to human exposure. In addition, regulators should consider possible adverse impacts to ecosystems.

• Where there is uncertainty in the evidence, regulators should err on the side of protecting health and the environment.

Ensure public access to information on chemicals and their uses.

• The public has a right to know about chemicals currently on the market, including their specific uses, poten

tial hazards to health and the envi

ronment, and potential exposures. California should create an easily understood database for all chemicals currently in use. This tool would enable businesses and consumers to compare the safety of chemicals, iden

tify missing data, and create demand for safer alternatives.

• Until health and safety data are avail

able for a particular chemical, there should be mandatory labeling for con

sumer products indicating the pres

ence of a chemical that has not been tested for its impact on human health.

### A New Approach: Green Chemistry 25 

# Recommendations for Consumers to Avoid Formaldehyde Exposure 

# C onsumers seeking to avoid formaldehyde exposure face many obstacles. Prod

ucts made with formaldehyde are very unlikely to be labeled as such. Even well-educated consumers consciously looking for healthy products may find that a seemingly innocuous product actually emits formaldehyde. For example, Dr. Mark Mendell, an indoor air quality expert at the Lawrence Berkeley National Laboratory, chose bamboo when remodeling the floor in his home. He later dis

covered that the bamboo floor was releasing formaldehyde vapor, likely from a urea-formaldehyde adhesive. 89 

### To reduce the risk of exposure to formaldehyde in the home, consumers should:

• Ask retailers and manufacturers about the formaldehyde emissions of prod

ucts, including furniture, cabinetry and building products made of composite wood, before you purchase them.

• If information about formaldehyde emissions is unavailable, avoid products with components made of medium density fiberboard, particleboard or other types of composite wood. Look for product descriptions that indicate the use of solid wood, which does not contain formaldehyde.

• Maintain moderate temperature and humidity levels and provide adequate ventilation within your home. Formaldehyde emissions are accelerated by heat, and also somewhat by humidity. Adequate ventilation with outdoor air can help to prevent formaldehyde and other indoor air pollutants from build

ing up to greatly elevated levels within your home.

• Place pollution-absorbing plants in your home. For example, scientists have demonstrated that spider plants ( Chlorophytum elatum ), Boston ferns ( Nephro

lepis exalta Bostoniensis ), dwarf date palms ( Phoenix roebelinii ), pot mums ( Chry

santhemum morifolium ), and peace lilies ( Spathiphyllum ) can effectively reduce formaldehyde levels in indoor air. 92

### 26 Toxic Baby Furniture 

## Q * (C – C

o 

## )

N 

## Formaldehyde Emission Testing Environment California Research & Policy Center contracted with Berkeley Analytical Associates, LLC in Richmond, California, to test 21 baby nursery furnishings for their formaldehyde emissions. The firm is a commercial laboratory specializing in the measurement of chemical emissions from building materials, architectural finishes, and furniture using large and small scale environmental chambers. Their services are available to industry, governmental agencies, and professional organizations. The laboratory placed each product into a large or small scale chamber operated under controlled conditions according to ASTM Standards D 5116 and D 6670. Products were taken from their packaging and trans

ferred directly to the chambers. Many of the large pieces were tested in unassembled or partially assembled configuration. Conditions within the chamber were set to approximate the indoor environ

ment. Temperature ranged from 22°C to 24°C. Relative humidity ranged from 45 to 55 percent. Air within the chamber was changed once per hour by ventilation. Af

ter 24 hours, air samples for formaldehyde 

# Methodology

were collected from the chambers. The samples were analyzed for formaldehyde by High Performance Liquid Chromatogra

phy following ASTM Method D 5197, with a limit of detection of about 1 microgram per cubic meter. 90 

### The laboratory reported the results for each product in terms of an emission factor, in units of micrograms of formal

dehyde emitted per product unit per hour, according to Equation 1, where Q is the rate of air flow into the test chamber (in cubic meters per hour), C is the measured concentration of formaldehyde in the test chamber (in micrograms per cubic meter), C

o 

### is the chamber background concentra

tion of formaldehyde before the product was added, and N is the number of units of product added to the testing chamber.

Equation 1:



## Emission Factor =

### Methodology 27 

## Indoor Air Quality Modeling Using the results of the testing, we esti

mated the contribution each product would have toward whole-house formaldehyde concentrations. We used Equation 2 to estimate indoor formaldehyde levels, where EF is the measured emission factor of the product (in micrograms per unit per hour), N is the number of units, V is the interior volume of the home (in cubic meters), and A is the ventilation rate (in air changes per hour). The resulting concentration in micrograms per cubic meter was converted to ppb by multiplying by 0.813, per the Agency for Toxic Substances and Disease Registry (ATSDR), Toxicological Profile for Formaldehyde, July 1999. Equation 2:



## Indoor Concentration =

We used a set of assumptions describing the size and ventilation rate of four generic types of North American residences, per Alfred T. Hodgson, Berkeley Analytical Associates, LLC, Residential Exposure Scenarios for Estimation of the Impacts of Products on Indoor Air Quality, 20 September 2007. Table 5 lists these as

sumptions.



## Table 5: Size and Ventilation Rates for Four Generic Types of Residences 91

Home Volume Ventilation Rate (cubic meters)	 (full air changes per hour)

Existing Single Family Home 340 0.5

New Single Family Home 536 0.24 Existing Unit in Apartment Building	 204 0.5

New Unit in Apartment Building 260 0.29 

## EF * N

V * A

### 28 Toxic Baby Furniture 

# Appendix: Detailed Product Identification and Testing Results

Product Name Product Sample ID Manufacturer ID Manufacturer Retailer

Child Craft Oak Crib with Storage Drawer-Oak ASIN: B000BV3I1Q Catalog #10182136 Child Craft Target 3,680 17.6 23.3 29.4 39.8
Bridget 4-in-1 Crib (White) Item #8021348771 Wal-Mart #002638982 Delta Wal-Mart 1,670 8.0 10.6 13.3 18.1
Kayla II Changing Table – Natural Item #95971 00525-72N; SKU: 517E7D45 Storkcraft Babies R Us 1,090 5.2 6.9 8.7 11.8
Cherry Berkley Ready-to-Assemble Changing Table #572982 0603G00WP Jardine Enterprises Babies R Us 974 4.7 6.2 7.8 10.5
Pure White Country Style Changing Table Catalog #663615 3580330 South Shore Furniture Target 662 3.2 4.2 5.3 7.2
Rochester Cognac Crib with Drawer Catalog #551420 04550-92C Storkcraft Target 573 2.7 3.6 4.6 6.2
Nursery-In-A-Box Crib (Cherry)* Item #74102289003 Wal-Mart #002653394 Simplicity for Children Wal-Mart 69 0.3 0.4 0.5 0.7

Natural Americana Lifetime Crib Item #666974 DJ203B4NWP; SKU 57DF2C35 Jardine Enterprises Babies R Us 62 0.3 0.4 0.5 0.7
Graco Lauren 4-in-1 Dropside Convertible Crib – Natural Catalog #10456405 Model #3150282 Graco Target 36 0.2 0.2 0.3 0.4
Baby Cocoa Valance Jungle Animals Style Item #31663 Lambs & Ivy Babies R Us 16 0.1 0.1 0.1 0.2

Football Wall Shelf Catalog #695759 Item #100339 Trend Lad Target 11 0.1 0.1 0.1 0.1
Alphabet Soup Decorative Waste Basket Item #882841 7110109, SKU: F9E9BB53 CoCaLo Babies R Us 9 0.0 0.1 0.1 0.1
South Shore Changing Table - Natural Maple Item #584484 2713-330; SKU: 32836556 South Shore Furniture Babies R Us 8 0.0 0.1 0.1 0.1
Lady Bug Waste Basket UPC 7 89887 274116 Style #7001WTC Kids Line Babies R Us 6 0.0 0.0 0.1 0.1
Sugar Plum Lamp Base & Shade Item #577615 716129; SKU: C3E05D08 CoCaLo Babies R Us 6 0.0 0.0 0.0 0.1
Olympia Single Crib - Dark Pine Item #292424 0102E00; SKU: AEEEBF16 Jardine Enterprises Babies R Us <6 0.0 0.0 0.0 0.1
Lambs & Ivy Froggy Tales Lamp Item #87405 54024; SKU: A4123372 Lambs & Ivy Babies R Us 5 0.0 0.0 0.0 0.1
Alphabet Soup Wall Hanging UPC 6 80601 00759 4 711037 CoCaLo Babies R Us 4 0.0 0.0 0.0 0.0

Olivia Decorative Valance Item #310066 5008V Kids Line Babies R Us 4 0.0 0.0 0.0 0.0
Winnie The Pooh Wall Shelf with Pegs UPC 85214 00346 7 1400989 DB Wall Shelf Crown Crafts Infant Products, Inc. Babies R Us 3 0.0 0.0 0.0 0.0
My First Doll UPC/EAN/ISBN 7 17851 15078 Style #3415078; PA #5248 (RC) Koala Baby Babies R Us 1 0.0 0.0 0.0 0.0

*We tested the crib only, not the dresser or the table that also come with this product.

### Appendix 29 

# Appendix: Detailed Product Identification and Testing Results

Product Name Product Sample ID Manufacturer ID Manufacturer Retailer

Child Craft Oak Crib with Storage Drawer-Oak ASIN: B000BV3I1Q Catalog #10182136 Child Craft Target 3,680 17.6 23.3 29.4 39.8
Bridget 4-in-1 Crib (White) Item #8021348771 Wal-Mart #002638982 Delta Wal-Mart 1,670 8.0 10.6 13.3 18.1
Kayla II Changing Table – Natural Item #95971 00525-72N; SKU: 517E7D45 Storkcraft Babies R Us 1,090 5.2 6.9 8.7 11.8
Cherry Berkley Ready-to-Assemble Changing Table #572982 0603G00WP Jardine Enterprises Babies R Us 974 4.7 6.2 7.8 10.5
Pure White Country Style Changing Table Catalog #663615 3580330 South Shore Furniture Target 662 3.2 4.2 5.3 7.2
Rochester Cognac Crib with Drawer Catalog #551420 04550-92C Storkcraft Target 573 2.7 3.6 4.6 6.2
Nursery-In-A-Box Crib (Cherry)* Item #74102289003 Wal-Mart #002653394 Simplicity for Children Wal-Mart 69 0.3 0.4 0.5 0.7

Natural Americana Lifetime Crib Item #666974 DJ203B4NWP; SKU 57DF2C35 Jardine Enterprises Babies R Us 62 0.3 0.4 0.5 0.7
Graco Lauren 4-in-1 Dropside Convertible Crib – Natural Catalog #10456405 Model #3150282 Graco Target 36 0.2 0.2 0.3 0.4
Baby Cocoa Valance Jungle Animals Style Item #31663 Lambs & Ivy Babies R Us 16 0.1 0.1 0.1 0.2

Football Wall Shelf Catalog #695759 Item #100339 Trend Lad Target 11 0.1 0.1 0.1 0.1
Alphabet Soup Decorative Waste Basket Item #882841 7110109, SKU: F9E9BB53 CoCaLo Babies R Us 9 0.0 0.1 0.1 0.1
South Shore Changing Table - Natural Maple Item #584484 2713-330; SKU: 32836556 South Shore Furniture Babies R Us 8 0.0 0.1 0.1 0.1
Lady Bug Waste Basket UPC 7 89887 274116 Style #7001WTC Kids Line Babies R Us 6 0.0 0.0 0.1 0.1
Sugar Plum Lamp Base & Shade Item #577615 716129; SKU: C3E05D08 CoCaLo Babies R Us 6 0.0 0.0 0.0 0.1
Olympia Single Crib - Dark Pine Item #292424 0102E00; SKU: AEEEBF16 Jardine Enterprises Babies R Us <6 0.0 0.0 0.0 0.1
Lambs & Ivy Froggy Tales Lamp Item #87405 54024; SKU: A4123372 Lambs & Ivy Babies R Us 5 0.0 0.0 0.0 0.1
Alphabet Soup Wall Hanging UPC 6 80601 00759 4 711037 CoCaLo Babies R Us 4 0.0 0.0 0.0 0.0

Olivia Decorative Valance Item #310066 5008V Kids Line Babies R Us 4 0.0 0.0 0.0 0.0
Winnie The Pooh Wall Shelf with Pegs UPC 85214 00346 7 1400989 DB Wall Shelf Crown Crafts Infant Products, Inc. Babies R Us 3 0.0 0.0 0.0 0.0
My First Doll UPC/EAN/ISBN 7 17851 15078 Style #3415078; PA #5248 (RC) Koala Baby Babies R Us 1 0.0 0.0 0.0 0.0 Existing Single Family Formaldehyde Emissions (micrograms per unit per hour) New Single Family Existing Apt. New Apt. Estimated Contribution to Total Home Formaldehyde Concentration (ppb)

### 30 Toxic Baby Furniture 1. U.S. Consumer Product Safety Com

mission, Infant/Child Product Recalls (N ot Including Toys) , downloaded from www.cpsc. gov/cpscpub/prerel/category/child.html on 10 March 2008. 2. Janine Brady, et al., “Toy Contaminated with ‘Date Rape’ Drug Pulled,” CNN , 8 No

vember 2007; available at www.cnn.com. 3. Recalls: See Note 1. Lead impacts: U.S. Centers for Disease Control and Prevention, A Review of Evidence of Adverse Health Effects Associated with Blood Lead Levels <10 μg/dL in Children , Appendix A in: Preventing Lead Poisoning in Young Children , August 2005. 4. California Code of Regulations, Title 17, 93120-93120.12, 18 April 2008. 5. U.S. Environmental Protection Agency, What is the TSCA Chemical Substance Inven

tory? (factsheet), 28 September 2007; available at www.epa.gov/opptintr/newchems/pubs/in

vntory.htm. 6. U.S. Environmental Protection Agency, Chemical Hazard Data Availability Study, 1998

. Major chemicals are defined as those produced or imported in amounts exceeding one million pounds per year. 7. Commission of the European Communi

ties, White Paper: Strategy for a Future Chemi

cals Policy , COM(2001) 88 final, 27 February 2001; Carcinogenic, mutagenic, and repro

toxic chemicals, plus chemicals defined as category 1 or 2 in EU Directive 67/548, plus persistent organic pollutants. 8. California Department of Toxic Sub

stances Control, California Green Chemistry Initiative , downloaded from www.dtsc.ca.gov/ PollutionPrevention/GreenChemistryInitia

tive/ on 12 March 2008. 9. California Department of Environmental Protection, Green Chemistry Position State

ment , 15 October 2007. 10. U.S. Environmental Protection Agency, The Inside Story , downloaded from www.epa. gov/iaq/pubs/insidest.html, 04 October 2005. 11. Peggy Jenkins, California Air Resources Board, Formaldehyde , Presentation given to the California Electricity and Air Quality Confer

ence, 3 October 2006.

12. Ibid

. 13. Al Hodgson et al., “Volatile Organic Compound Concentrations and Emission Rates in New Manufactured and Site-Built Houses,” Indoor Air 3:178-192, 2000.

14. See Note 11. 15. U.S. Environmental Protection Agency, Sources of Indoor Air Pollution—Formaldehyde
, downloaded from www.epa.gov/iaq/formalde. html, 27 March 2006. 16. T.J. Kelly, et al., “Emission Rates of Formaldehyde from Materials and Consumer 

# Notes

### Notes 31 Products Found in California Homes,” En

vironmental Science and Technology 33: 81-88, 1999.
17. See Note 15.

18. Ibid

. 19. See Note 11. 20. Toxics Use Reduction Institute, Toxics Use Reduction Act Reports: Report for Mas

sachusetts as a Whole, 2001 , downloaded from turadata.turi.org on 9 April 2004. 21. For example, see diethylhexyl-phthalate or butylbenzyl- phthalate in Note 20. 22. Ruth Rudel et al, Silent Spring Insti

tute and Harvard School of Public Health, “Phthalates, Alkylphenols, Pesticides, Polybrominated Diphenyl Ethers, and Other Endocrine-Disrupting Compounds in Indoor Air and Dust,” Environmental Science and Technology 37: 4543-4553, 15 October 2003.
23. U.S. Centers for Disease Control and Prevention, Second National Study on Human Exposure to Environmental Chemicals , 31 Janu

ary 2003; Environmental Working Group, Body Burden: The Pollution in People , January 2003.
24. Lowell Center for Sustainable Produc

tion, Formaldehyde Fact Sheet , March 2003. 25. Mark Mendell, “Indoor Residential Chemical Emissions as Risk Factors for Re

spiratory and Allergic Effects in Children: a Review,” Indoor Air 17: 259–277, doi:10.1111/ j.1600-0668.2007.00478.x, August 2007. 26. M.H. Garrett et al., “Increased Risk of Allergy in Children due to Formaldehyde Exposure in Homes,” Allergy 54, 330–337, 1999. 27. K.B. Rumchev et al., “Domestic Expo

sure to Formaldehyde Significantly Increases the Risk of Asthma in Young Children,” Eu

ropean Respiratory Journal 20, 403–408, 2002. 28. M. Krzyzanowski, J. J. Quackenboss, and M. D. Lebowitz, “Chronic Respiratory Effects of Indoor Formaldehyde Exposure,” Environmental Research 52: 117–125, 1990. 29. Peter Franklin et al., “Raised Exhaled Nitric Oxide in Healthy Children is Associ

ated with Domestic Formaldehyde Levels, American Journal of Respiratory and Critical Care Medicine 161: 1757–1759, May 2000. 30. Jouni Jaakkola et al., “Asthma, Wheez

ing, and Allergies in Russian Schoolchildren in Relation to New Surface Materials in the Home,” American Journal of Public Health 94: 560–562, April 2004.

31. See Note 25. 32. IARC is part of the World Health Or

ganization. Its mission is to coordinate and conduct research on the causes of human cancer and to develop scientific strategies for cancer control. As part of the California En

vironmental Protection Agency, OEHHA’s mission is to protect and enhance public health and the environment through the sci

entific evaluation of risks posed by hazardous substances. Carcinogen listings: U.S. EPA Technology Transfer Network Air Toxics Website, Formaldehyde: Hazard Summary— Created in April 1992: Revised in January 2000
, 9 March 2006; International Agency for Research on Cancer, IARC Monographs on the Evaluation of Carcinogenic Risks to Humans , 88 (2-9), June 2004. 33. State of California, Office of Environ

mental Health and Hazard Assessment, Proposition 65 Safe Harbor Levels: No Signifi

cant Risk Levels for Carcinogens and Maximum Allowable Dose Levels for Chemicals Causing Reproductive Toxicity , January 2008. 34. International Agency for Research on Cancer, “Formaldehyde, 2-Butoxyethanol and 1- tert -Butoxypropan-2-ol,” IARC Mono

graphs on the Evaluation of Carcinogenic Risks to Humans , 88, December 2006.

35. Ibid

. 36. Ibid

. 37. Ibid

. 38. Marla Mueller, University of California, Berkeley, Ventilation Characteristics of Califor

nia Homes , ARB Contract No. 03-326, June 2007. 39. Francis Offerman et al., Indoor Envi

ronmental Engineering, San Francisco, CA, Window Usage, Ventilation, and Formaldehyde Concentrations in New California Homes: Sum

mer Field Sessions , November 2007. 40. Alfred Hodgson, Berkeley Analytical As

sociates, LLC, Residential Exposure Scenarios for Estimation of the Impacts of Products on Indoor Air Quality , 20 September 2007.

### 32 Toxic Baby Furniture 41. Ibid

. 42. 16 ppb: See Note 26; 50 ppb: See Note 27. 43. This estimate makes simplifying assump

tions, essentially treating the bedroom as if it were a small independent dwelling with a 40 cubic meter volume and a ventilation rate of 1 air change per hour, and using Equation 1 on page 26. 44. State of California, Office of Environ

mental Health Hazard Assessment and Air Resources Board, Final Report on the Identifi

cation of Formaldehyde as a Toxic Air Contami

nant , January 1992.

45. See Note 33.

46. Ibid

. 47. California Code of Regulations, Sections 12705 and 12805.

48. See Note 11.

49. See Note 33. 50. Tracey Woodruff et al, U.S. Environ

mental Protection Agency, “Trends in Envi

ronmentally Related Childhood Illnesses,” Pediatrics 113: 1133-1140, April 2004.

51. See Note 7.
52. See Notes 6 and 7.

53. See Note 15. 54. Nicolas Ashford et al., “A Hard Look at Federal Regulation of Formaldehyde: A Departure from Reasoned Decisionmaking,” Harvard Environmental Law Review 7: 297- 370, 1983. 55. Chemical Industry Institute of Toxicol

ogy, Statement Concerning Research Findings
, Docket No. 11109, 8 October 1979. 56. Federal Panel on Formaldehyde, “Re

port of the Federal Panel on Formaldehyde,” Environmental Health Perspectives 43: 139-168, 1982.
57. See Note 54.

58. Ibid

. 59. Ibid

. 60. Consumer Product Safety Commission, An Update On Formaldehyde: 1997 Revision, CPSC Document #725, 1997. 61. California Air Resources Board, Proposed Airborne Toxic Control Measure for Composite Wood Products (factsheet), July 2006. 62. Marla Cone, “U.S. Rules Allow the Sale of Products Others Ban: Chemical-Laden Goods Outlawed in Europe and Japan Are Permitted in the American Market,” Los Angeles Times , 8 October 2006. 63. Europe’s E1 standard is about half of the HUD standard for plywood and particle board. Japan’s F standards are even more stringent, forcing new emissions-limiting technology for some products. California Air Resources Board, Airborne Toxic Control Mea

sure on Composite Wood Products , Presented at a Public Workshop, Sacramento, CA, 20 June 2006.

64. See Note 62. 65. California Air Resources Board, Pro

posed Airborne Toxic Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products [Board Presentation], 26 April 2007.

66. See Note 63.
67. See Note 44.

68. Ibid

. 69. Association of Woodworking and Fur

nishings Suppliers, Proposed Formaldehyde Regulations for Compwood Sets Emission Limits Industry Believes Are Not Feasible , undated, downloaded from www.awfs.org on 18 March 2008. 70. Alfred Hodgson and Raja Tannous, Berkeley Analytical Associates, Meeting the Requirements of the California Composite Wood ATCM Using Chambers of Different Sizes , 7 September 2007; California Air Resources Board, Final Regulation Order: Airborne Toxic Control Measure to Reduce Formaldehyde Emis

sions from Composite Wood Products , 7 March 2008.
71. See Note 4.
72. See Note 65.
73. See Note 5.
74. See Note 7.
75. See Note 6. 76. Out of 413 chemicals tested for. Jane Houlian et al., Environmental Working Group, Body Burden: The Pollution in New

borns , 14 July 2005.

77. Ibid

.

### Notes 33 78. Ibid

. 79. See Note 8.

80. See Note 9.
81. “Columbia Forest Products Launches a Revolution in Plywood Adhesives,” Environ

mental Building News: The Leading Newslet

ter on Environmentally Responsible Design & Construction , 14(6), June 2005. 82. Columbia Forest Products, “Columbia Forest Products wins EPA’s Presidential Green Chemistry Challenge Award,” ( Press Release ), 26 June 2007. 83. Columbia Forest Products, “Columbia Forest Products Reaches 25 Million Pure

Bond (R) Formaldehyde-Free Hardwood Plywood Panels,” ( Press Release ), 13 March 2008.

84. Ibid

. 85. Ibid

. 86. See Note 82.
87. Ibid

. 88. See Note 65. 89. Mark Mendell, Personal Correspon

dence, 17 April 2008. 90. For details on ASTM standards, see www.astm.org.
91. See Note 40. 92. For more information, see Anne Raver, “Cuttings; Need an Air Freshener? Try Plants,” New York Times , 13 February 1994; B. C. Wolverton, Rebecca C. Mcdonald and E. A. Watkins, “Foliage Plants for Removing Indoor Air Pollutants from Energy-Efficient Homes,” Economic Botany 38 (2): 224-228, April 1984.