From: "Schaffer, Amy" <Amy_Schaffer@afandpa.org>

To: Jim Berlow/DC/USEPA/US@EPA
Cc: "Hunt, Tim" <Tim_Hunt@afandpa.org>, <dbisson@cpamail.org>

Date: 10/04/2010 03:18 PM Subject: Formaldehyde Data.



### Jim –

You asked me if AF&PA had additional information concerning the content of formaldehyde in wood products as a way to demonstrate that we are not burning formaldehyde to discard it. We want to reiterate that we do not believe you have jurisdiction under RCRA to regulate trim from wood products because we do NOT discard the materials. They are valuab le as fuel and as recycled materials – the decision on which way they go depends on the economics of fuel and the market place.

Furthermore, whether formaldehyde is in the w ood product or not is irrelevant because it is also a natural product of combustion of wood.

However, in order to be helpful to you, we polled the members and have the best data on formaldehyde from the Composite Panel A ssociation. These data are not content, but emissions from final product – basically what you would buy at Home Depot. Note that plywood is not included because they have very very low emissions. (See http://www.apawood.org/pdfs/ unmanaged/FemaTrailers.pdf ).

The large majority of industry is in comp liance with the California rule and the new
federal law that codifies the CA limits into federal law.

The following is from Donald Bi sson at the CPA. He explains the data that are included in the attachments – showing the percentage of shipments in 2009 meeting the CARB limit or lower (about 83%) and explaining the new law.

Unfortunately, we are not aware of any data that demonstrates form aldehyde content in coal or other fossil fuels. We did, how ever, find information about naturally-occurring formaldehyde in foods – which is come cases is higher than that found in wood. This chart is from the Hong Kong Centre for Food Safety, 1997.Food Safety Focus (6th Issue, January 2007) – Incident in Focus



### Formaldehyde in Food

Reported by Mr. Arthur Y AU, Scientific Officer, Risk Communication Section, Centre for Food Safety

Table 1: Examples of Foods Known to Contain Naturally Occurring Formaldehyde

Food Type Level (mg/kg)

Apple 6.3-22.3

Banana 16.3

Cauliflower 26.9

Pear 38.7-60 Fruits and Vegetables

Shiitake mushroom (dried / raw) 100-406 / 6-54.4

Meat and Meat Products Beef, pork, mutton and poultry meat 2.5-20

Cod 4.6-34

Fish ball 6.8

Crustacean 1-98 Seafood

Bombay-duck (fresh)

أ 140



### From CPA:

All manufacturers of composite panels have experienced huge downward trends in formaldehyde emissions since 2005. The CARB Rule which sets ceiling limits at:

1. For particleboard at 0.18ppm under phase 1 effective January 1, 2009 and 0.09ppm under phase 2 which is to become effective on January 1, 2011.

2. For MDF at 0.21ppm under phase 1 effectiv e January 1, 2009 and 0.11 under phase 2 which is to be effective January 1, 2011.

has brought in new urea formaldehyde resin systems and also non UF systems that more and more manufacturers are adopting.

On July 7, 2010, President Ob ama signed the Formaldehyde Standards for Composite Wood Products Act which amends the Toxic Substances Control Act (TSCA) to make the formaldehyde emission standard contained in the California Code of Regulations applicable to hardwood plywood, medium-den sity fiberboard, and particleboard sold, supplied, offered for sale, or manufactured in the United States . It also directs the Administrator of the Environmental Protection Agency (EPA) to prom ulgate implementing re gulations by January 1, 2013, that ensure complian ce equivalent to compliance with the California standard.

With these two measures, particleboard manufactu red in the United States will need to be below 0.09ppm and MDF manufacturers below 0.11ppm by 2013.

Also, please find attached a copy of pa ge 18 of CPA’s 2009 North American Shipments Report which shows 83% of particleboard ship ments being at or below 0.18ppm and 73% of MDF shipments at or below 0.21ppm during 2009.This indicates that for 2010 and 2011, manufacturers will be meeting the CARB 2 ceilings in the same proportion meaning that 83% of the industry on Janu ary 1, 2011 will probably be at or lower than 0.09ppm for particleboard and 73% at or lower than 0.11p pm for MDF. Carrying this to 2013, when the federal legislation is expected to take effe ct all (100%) manufacturers will be at those

levels.Also attached is the 2009 CPA Laboratory Report which shows that out of a total of over 800 tests the industry was well below 0.15ppm. Note that CPA represents over 92% of the industry in the United States consequently those results fairly represent wher e the industry is at on the formaldehyde front.



### Please let me know if you have any questions on this information.

I’m in the process of pulling together additio nal data on wastewater treatment residuals and will get them to you as soon as possible.

Best,

Amy


# Amy Schaffer

American Forest & Paper Association telephone: 202.463.5156

mobile: 301.742.2697