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 valuable 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 wood 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 Association. 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 compliance with the California rule and the new 

federal law that codifies the CA limits into federal law. 

 

The following is from Donald Bisson 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 formaldehyde content in 

coal or other fossil fuels. We did, however, 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 YAU, 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) 

 140أ

 

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 effective 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 Obama 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-density 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 promulgate implementing regulations by January 

1, 2013, that ensure compliance equivalent to compliance with the California standard. 

 

With these two measures, particleboard manufactured 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 page 18 of CPA’s 2009 North American Shipments 

Report which shows 83% of particleboard shipments 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 January 1, 2011 will probably be at or lower than 0.09ppm for 

particleboard and 73% at or lower than 0.11ppm for MDF. Carrying this to 2013, when the 

federal legislation is expected to take effect 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 where 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 additional 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