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ToxicTrailers.com was launched after Hurricane Katrina in 2005 when the government spent more than $2 billion on FEMA trailers with high levels of formaldehyde that sickened thousands of people. The FEMA trailer tragedy exposed what is a widespread problem in RVs, mobile homes, modular buildings and even conventional buildings that use pressed wood products. Unfortunately, as we approach the tenth anniversary of Katrina, formaldehyde regulations are not being enforced in the U.S., and people's health is at risk. If you are having burning eyes, congestion, sore throat, coughing, breathing difficulties, frequent sinus infections or rashes, and difficulties concentrating, you may have a formaldehyde problem. For questions or to share your story, write 4becky@cox.net.

Monday, January 26, 2009

chemist urges adoption of formaldehyde standards

I am a Ph.D. organic chemist with years of industrial experience with resins made from formaldehyde and other chemicals (see White, K.B., US Patent 6,232,368 (2001), "Ester Cured Binders"). These types of resins are used in the manufacture of various wood products such as particle board.

It states on the EPA website, "The mission of the Environmental Protection Agency is to protect human health and the environment. Since 1970, EPA has been working for a cleaner, healthier environment for the American people."

I strongly urge you and others at the EPA that now is the time for the EPA to protect the American people from the dangers of airborne formaldehyde.

The Occupational Safety & Health Administration of the US Department of Labor (OSHA) has taken strong steps to protect American workers from the dangers of formaldehyde. It is time that the EPA also fulfills its mission to the American people and protects them from the dangers of formaldehyde.

Per Advanced Notice of Proposed Rulemaking for Formaldehydes, Docket ID: EPA-HQ-OPPT-2008-0627, I would like to strongly urge that the EPA to adopt the California Air Resources Board's (CARB) Airborne Toxic Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products, sections 93120-93120.12, title 17, California Code of Regulations.

The CARB regulation sets maximum exposure limits for various wood products such as particle board. In light of the unfortunate, disastrous health experiences of the FEMA trailer residents with high levels of formaldehyde, the EPA should adopt the CARB standards in order to protect the American people (see www.msnbc.msn.com/id/14011193/ and www.toxictrailers.com.

It should be noted that the CARB standards are in line with standards already in place in Japan and the European Union concerning formaldehyde emissions exposure from wood products.

The following are key reasons for adopting the CARB regulations for formaldehyde:

• Title 42 part 7412 of the US Code (The Clean Air Act) lists formaldehyde as a hazardous substance.

• The EPA considers that formaldehyde is a probable human carcinogen. It is well documented that exposure to formaldehyde causes serious health problems in humans (see http://www.epa.gov/iris/subst/0419.htm).

• The Occupational Safety & Health Administration of the US Department of Labor (OSHA) has classified formaldehyde as a hazardous and toxic substance. It has strict rules for formaldehyde exposure in the workplace. From OSHA Formaldehyde Regulations – Standards – 29 CFR Formaldehyde – 1910.1048, OSHA has set permissible exposure limit (PEL) = 0.75 ppm and a short-term exposure limit = 2 ppm for formaldehyde in the workplace.

• OSHA requires any product used in the workplace with more than 0.1 % free formaldehyde to have formaldehyde listed as a hazardous material on the material safety data sheet (MSDS) (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22543.

The Clean Air Act is the federal law designed to make sure that all Americans have air that is safe to breathe. Public health protection is the primary goal. The Clean Air Act requires that the EPA set health based air quality standards to protect against common pollutants. Under this act, formaldehyde is listed as a pollutant. The EPA should move to adopt the CARB standards and there by fulfill its mission and its legal responsibility as listed under the Clean Air Act.

American workers are protected from the hazards of formaldehyde in the workplace by OSHA. Japanese and European Union citizens are protected from the hazards of formaldehyde in their homes by various laws setting emissions limits of formaldehyde from wood products. It is time that the American people are protected from the hazards of formaldehyde emissions from wood products by the EPA. This can be achieved by the adoption of the CARB formaldehyde standards.

Many times, one hears that new regulations can not be met by the manufacturers affected by the new regulations. However, the proposed CARB regulations on wood products are presently being met in Japan and the European Union. Hexion, the largest manufacturer of formaldehyde based resins in the U.S. used to make wood products, is already advertising that it has the technology to allow wood product manufactures to meet the new CARB regulations (see http://www.ecobind.com/) with modest additional costs for the change over.

In conclusion, I urge the EPA to adopt the CARB formaldehyde emission standards and thereby protect the American people from the health hazards of formaldehyde.

Best Regards,
Kenneth B. White, Ph.D.
Schaumburg, IL
kenneth.b.white@gmail.com