“While we are reviewing the draft risk evaluation in detail, to date EPA’s peer review on formaldehyde has been limited and is insufficient to meet the scientific standards for a TSCA risk evaluation. Over 40 years of scientific studies by universities and independent scientists have been used by U.S. government agencies and international regulatory bodies to establish a safe level of formaldehyde exposure. There are dozens of peer-reviewed publications that support the safe use of formaldehyde at current regulatory levels.”
“We are particularly concerned with components surrounding suggested workplace limits. EPA’s suggested workplace limits are unworkable and ignore practices that are already in place to protect workers, including the use of personal protective equipment. They are 30 times below the recently updated European Union occupational limits of 300 parts per billion, lower than levels that can be detected, and below levels measured in ambient urban air and U.S. residences.”
“Any assessment of formaldehyde must begin with the best available science and the fact that formaldehyde is an ever-present part of the natural world that, through decades of responsible innovation and regulation, has become essential to goods including contributing to a sustainable future for wood products, electric vehicles, lifesaving vaccines, and medical devices. If EPA continues its current path, formaldehyde manufacturing and many of its downstream uses would be severely restricted or potentially banned in the U.S.” |