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Citizen Petition to EPA Regarding Formaldehyde in Wood Products


March 5, 2008

Stephen Johnson, Administrator
Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460

Re: Citizen Petition to EPA Regarding Formaldehyde in Wood Products

Dear Administrator Johnson:

Hurricane Katrina wreaked its havoc on the Gulf Coast more than 30 months ago. For the residents forced to live in FEMA trailers, the damage continues every day. Many struggle with formaldehyde from composite wood products used in the trailers. Their lungs burn. Their eyes tear. Many suffer from headaches and other illnesses that have required frequent doctor visits and, in some cases, hospitalization. Some can now barely tolerate any exposure to formaldehyde. (1)

On February 14, 2008, the U.S. Centers for Disease Control and Prevention (CDC) released its preliminary analysis of testing done in FEMA trailers in December 2007 and January 2008. (2) CDC and FEMA announced that the high levels of formaldehyde it found necessitate moving all disaster victims out of trailers as soon as possible because of serious health concerns. The government's admission of the harm done to trailer residents by exposure to formaldehyde was shocking. The agency found that:
  • In many trailers, mobile homes, and park models tested, formaldehyde levels were elevated relative to typical levels of U.S. indoor exposure.
  • Average level of formaldehyde in all units was about 77 parts per billion (ppb). This level is higher than U.S. background levels. Levels measured ranged from 3 ppb to 590 ppb.
  • These measured levels are likely to under-represent long-term exposures since formaldehyde levels tend to be higher in newer travel trailers and mobile homes and during warmer weather.
  • Indoor temperature was a significant factor for formaldehyde levels in this study independent of trailer make or model.
  • Formaldehyde levels varied by model (mobile homes, park homes, and travel trailers), but all types of trailers tested had some high levels.
  • At the levels seen in many trailers, health could be affected.

This week, the California Air Resources Board (CARB) finalized a regulation that will dramatically reduce formaldehyde emissions from three types of wood products: hardwood plywood, particleboard, and medium density fiberboard.(3) These products are commonly used for paneling, flooring, cabinets, furniture, countertops, molding, and door skins. The rules will reduce formaldehyde emissions from these products by 57% or 700 tons per year by 2011 in California alone. (4)

We call on you to use your authorities under Section 6 of the Toxic Substances Control Act (TSCA) to protect all citizens, especially victims of disaster, from the dangers of formaldehyde by following California’s lead.  Pursuant to Section 21 of TSCA, we petition the U.S. Environmental Protection Agency to adopt the California regulation and apply it nationally.  The regulation should apply also to composite wood products used in manufactured housing. 

The rule is necessary because there are no federal rules to protect the public from formaldehyde from composite wood products in their home except for the U.S. Department of Housing and Urban Development’s Manufactured Housing Standards.(5)  The HUD standards were adopted almost 25 years ago in 1984, and provide inadequate protection of human health.  They reflected our understanding of the dangers of formaldehyde exposure and the science to eliminate it at that time.  We now know that formaldehyde is a known human carcinogen with no safe level of exposure.(6)

 We also know that the manufacturers can do better.  The California standards make clear that lower levels of formaldehyde are feasible at minimal additional cost to consumers.  This Airborne Toxic Control Measure (ATCM) cuts formaldehyde emissions by 50 to 75% compared to the HUD standards and includes a comprehensive enforcement and quality assurance requirement to ensure a fair and level playing field for all manufacturers.  California’s enforcement and quality assurance requirements are far superior to HUD's standards.(7)

EPA has adopted standards to protect the public around the facilities that manufacture these wood products.(8)  OSHA also has standards to protect workers.(9)   But no federal standards protect consumers other than those living in manufactured housing.  High levels of formaldehyde recently found in HUD manufactured homes are evidence that of the need for additional standards to protect public health. 

In adopting the proposed ATCM, the CARB found (10) that:

  • Existing federal, State, and local regulations do not sufficiently protect the public's health from formaldehyde emissions from hardwood plywood, particleboard, medium density fiberboard, and finished goods containing these materials;
  • Hardwood plywood, particleboard, medium density fiberboard, and finished goods containing these materials emit potentially harmful airborne concentrations of formaldehyde, which pose a significant health risk to exposed members of the public;
  • The proposed ATCM would reduce formaldehyde emissions from hardwood plywood, particleboard, medium density fiberboard, and finished goods containing these materials, consistent with the principle of pollution prevention;
  •  The benefits to human health, public safety, public welfare, or the environment justify the costs of the regulatory requirements;
  • No reasonable alternative that has been identified and brought to the attention of CARB would be:
    -- More effective in carrying out the purpose for which the ATCM is proposed, or
    -- As effective to affected private persons and businesses than the proposed ATCM;
  • The proposed ATCM is consistent with CARB's environmental justice policy of reducing health risks in all communities where hardwood plywood, particleboard, or medium density fiberboard is manufactured, imported, distributed, sold, or used to fabricate finished goods;
  • The proposed ATCM is necessary in order to protect public health by reducing formaldehyde exposure from hardwood plywood, particleboard, medium density fiberboard, and finished goods containing these materials.

We believe the documentation by the California Air Resources Board more than fulfills the requirements for EPA to adopt a rule under TSCA Section 6(a). EPA should follow the lead of California. All Americans deserve to be protected from this risk.

For more information or questions, please contact:
Tom Neltner, Sierra Club
1701 Tilton Dr.
Silver Spring, MD 20902
317-442-3973
neltner@ikecoalition.org

Respectfully submitted,


  1. See http://www.toxictrailers.org/.  The website is dedicated to providing information about formaldehyde poisoning in FEMA trailers and RVs sold to the general public.
  2. http://www.cdc.gov/Features/FEMAtrailersFindings/. See also www.cdc.gov/nceh/ehhe/trailerstudy/pdfs/SummaryofStudyFindings.pdf for the summary of preliminary findings.
  3. See California Air Resources Board's webpage on its composite wood products rulemaking at http://www.arb.ca.gov/toxics/compwood/compwood.htm
  4. See California Air Resources Board, Proposed Airborne Toxic Control Measure to Reduce Emissions from Composite Wood Products, March 2007 at www.arb.ca.gov/regact/2007/compwood07/isor.pdf. Page ES-5.
  5. 24 CFR 3280.308. See U.S. Department of Housing and Urban Development, Manufactured Housing and Standards at www.hud.gov/offices/hsg/sfh/mhs/mhshome.cfm .
  6. See note 3. Page ES-2 and 13. See also California Air Resources Board Resolution 07-14 adopted April 26, 2007 at http://www.arb.ca.gov/regact/2007/compwood07/res0714.pdf
  7. See Section 93120-93120.12, title 17, California Code of Regulations
  8. U.S. Environmental Protection Agency, National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products, 40 CFR Part 63 Subpart DDDD. See http://www.epa.gov/ttn/atw/plypart/plywoodpg.html
  9. U.S. Occupational Safety and Health Administration, Formaldehyde Standards for Toxic and Hazardous Substances in General Industry, 20 CFR 1910.1048. See http://www.osha.gov/SLTC/formaldehyde/standards.html.
  10. See California Air Resources Board Resolution 07-14 adopted April 26, 2007 at http://www.arb.ca.gov/regact/2007/compwood07/res0714.pdf

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