Organizations Around the Country Support EPA’s Science-Based Reassessment of Formaldehyde

ACC applauds EPA’s updated draft risk evaluation, joining a broader and growing chorus of support from organizations across the country that recognize the importance of science-based decision-making at EPA. From industry groups and small businesses to policymakers and public health stakeholders, these voices underscore a common priority: ensuring that regulatory actions are grounded in the best available science, real-world exposure data, and a transparent, balanced process.

As the EPA continues its work under the Toxic Substances Control Act (TSCA), this support signals confidence in a more rigorous, evidence-driven approach; one that aligns with statutory requirements while protecting both public health and the industries and supply chains Americans depend on every day.

Here is what they are saying:

National Associations and Organizations

• National Taxpayers Union: “EPA’s Updated Draft is a constructive step in the right direction towards a readjustment of the formaldehyde risk evaluation toward chemical-specific evidence and away from unsupported default assumptions. This science-based approach by the Agency will strengthen broad confidence in the TSCA process and support regulatory outcomes that are both protective of human health and durable over time.”
• National Aquaculture Association:“The NAA strongly commends the EPA for revising its formaldehyde inhalation risk assessment, and for its renewed efforts to align with the best available science. We support the Agency’s decision to move away from IRIS derived values in favor of human controlled exposure studies and a threshold-based framework. This adjustment is scientifically justified and ensures a defensible risk evaluation under TSCA’s statutory mandates.”
• American Petroleum Institute: "Revisions to the formaldehyde inhalation risk assessment reflect best available science, address recommendations from scientific peer reviewers, and align with TSCA’s statutory mandates as well as Executive Order 14303 (Restoring Gold Standard Science). API supports EPA’s decision to move away from reliance on IRIS-derived values and instead base its evaluation on controlled human exposure studies, integrated mode of action evidence, and a threshold-based framework.”
• American Wood Council: "The purpose of the Memorandum and Notice is to correct serious scientific misjudgments in the December 2024 risk evaluation...AWC appreciates EPA’s willingness to reexamine those and other scientific judgments. The changes now proposed by EPA better reflect the best available science and the weight of the scientific evidence." 
• American Industrial Hygiene Association: "AIHA, in general, supports EPA’s application of the recommendations of federal advisory committees in using sensory irritation as an endpoint that is protective of chronic exposures. Sensory irritation is a sensitive and relevant end point in human risk assessment, for many chemicals. By one estimate, 40 % of the occupational exposure limit values (OELs) are based on the avoidance of sensory irritation (Brüning et al. 2014).”
• Methanol Institute: “EPA’s Draft Memorandum reflects meaningful progress toward a science-based framework by reconsidering prior hazard assumptions, relying on controlled human exposure data, integrating mode of action (MOA) evidence, and moving away from default extrapolation approaches that are not supported by the formaldehyde evidence base.”
• US Tire Manufacturers Association: “USTMA appreciates EPA’s development of a final formaldehyde risk evaluation that is science-based and includes accurate hazard and exposure information… The updated POD and UF reflect a comprehensive, integrated analysis of the vast amount of human data available to characterize the health effects of formaldehyde.”
• Society for Chemical Manufacturers and Affiliates: “SOCMA strongly supports EPA’s goal of these revisions, which is to use the highest standards of scientific integrity and reliance on the best available scientific information in evaluating chemicals under TSCA…We support EPA’s decision to move away from reliance on IRIS-derived values and instead base its evaluation on controlled human exposure studies, integrated mode of action evidence, and a threshold-based framework - an adjustment that is both scientifically justified and necessary to ensure a sound and defensible risk evaluation.”
• American Forest and Paper Association: “AF&PA supports the Memorandum, the Notice, and many of the corresponding draft changes to portions of the 2024 risk evaluation. These documents better reflect the best available science as required by TSCA § 26(h), the weight of the scientific evidence as required by TSCA § 26(i), and reasonably available information as required by TSCA § 26(k) as compared to the final risk evaluation issued in December 2024.”
• Alliance for Chemical Distribution: “EPA’s updated draft risk calculation memorandum for formaldehyde marks a significant and scientifically well-supported shift in the Agency’s approach to hazard identification and dose-response assessment. The December 2025 update reflects a deliberate move away from reliance on the IRIS’s IUR for cancer – an approach that has been repeatedly criticized by scientific reviewers for its dependence on uncertain epidemiological associations and its failure to incorporate mode-of-action evidence.”
• American Feed Industry Association: “The AFIA commends the EPA for revising its formaldehyde inhalation risk assessment to reflect the best available science. The AFIA feels this aligns with Toxic Substances Control Act’s (TSCA) statutory mandates as well as Executive Order 14303, Restoring Gold Standard Science.”
• National Association of Manufacturers: “The NAM supports the EPA’s revised inhalation risk calculations and the conclusion that protecting for sensory irritation will address risk from chronic exposures such as cancer and believes this is an important correction needed to align the evaluation with TSCA’s statutory mandate.”
• National Funeral Directors Association: “EPA’s decision to move away from IRIS‑derived values and instead rely on controlled human exposure studies, integrated mode‑of‑action evidence, and a threshold‑based framework represents a necessary and scientifically defensible course correction. This updated approach enhances both the credibility and long‑term durability of the risk evaluation.”
• CPAC Foundation Center for Regulatory Freedom: “The Updated Draft reflects a meaningful recalibration toward formaldehyde-specific evidence and away from assumptions that were not adequately supported by the weight of scientific evidence. EPA’s willingness to reassess prior analytical choices in light of peer review is not only appropriate under TSCA, but essential to maintaining the integrity of the chemical risk evaluation process. Such recalibration strengthens both public trust and regulatory durability.”

Companies

• Arauco North America: “EPA’s proposed updates to the formaldehyde risk evaluation are meaningful improvements from the December 2024 risk evaluation because these updates move the risk evaluation towards a more science-based and durable foundation to inform risk management.”
• Bakelite: “Bakelite strongly supports EPA’s commitment, to uphold and align with the Toxic Substances Control Act (TSCA) and Executive Order 143031, Restoring Gold Standard Science, by adhering to rigorous scientific standards.”
• Celanese: “Celanese supports much of what EPA has proposed with respect to amending the December 2024 Final Risk Evaluation… EPA is obligated to base its risk evaluations on the best available science and the weight of the scientific evidence. The proposed changes will do much to achieve that goal. EPA should finalize those changes in a revised risk evaluation.”
• Hexion: “We support the approach in EPA’s Draft Memorandum to move away from use of IRIS-derived hazard values… Both EPA’s approach to identifying a POD and selection of an appropriate uncertainty factor are consistent with TSCA’s requirements for best available science and weight of the scientific evidence.”
• Littlefuse: “Finally, we commend EPA’s decision to move away from reliance on IRIS-derived values and instead base its evaluation on controlled human exposure studies, integrated mode of action evidence, and a threshold-based framework.”

Farmers & Agricultural

• Frank Granberry, a Cattle Farmer - Alabama: “I’ve learned…just how important it is to maintain clean and sanitary conditions for our cows. Formaldehyde is among one of the important tools we have to do so, as it helps disinfect our cow barns from any bad bacteria. To help ensure other farmers across the state also have access to this important compound, I encourage the EPA to move forward with finalizing their new risk assessment for formaldehyde.”
• Pennsylvania Farm Bureau: “Pennsylvania Farm Bureau members stand ready to assist EPA in finding workable solutions grounded in sound science on this issue (and others under EPA’s authority) affecting the Commonwealth’s agricultural industry. To find such solutions, EPA must consider the extensive scientific data and real-world applications that demonstrate the safety and necessity of formaldehyde in agriculture.”
• The Fertilizer Institute: “TFI commends EPA for undertaking a substantive reassessment of its prior assumptions and, as a result, for revising its methodology in a manner that better reflects the best available science, the chemistry of formaldehyde, and realistic exposure pathways.”
• Adam Stewart, Vice President of Sweet Brew: “Under the previous administration’s approach, formaldehyde access would have been severely limited. It threatened businesses across the agriculture, transportation, and construction industries, not to mention the countless others that rely on formaldehyde. The economic ripple effects would have also been significant, costing Alabama jobs, discouraging investment, and slowing growth. All this while doing little to meaningfully advance public health protections.”

Healthcare & Medical

• Dr. Larry Amberg, Anesthesiologist at Westlake Anesthesia Group in Texas: “Formaldehyde is essential to healthcare. It's a key building block in numerous medical devices, including key surgical devices like pacemakers, artificial heart valves, and prostheses. And every day, across more than 500 hospitals in Texas, doctors and nurses like me rely on it for high-level disinfection and sterilization, which helps eliminate bacteria, viruses, fungi, and spores in our facilities.”
• Keenan Williams, CEO of Tridia Health: “Moving forward with this proposal ensures that not only the medical industry has access to the products it needs but that a myriad of others do as well. I urge the EPA to finalize this risk assessment quickly. It's the right approach for protecting health while supporting the jobs and industries that Texas depends on.”

Other Businesses & Organizations

• Matt Wills, Executive Director of Upstate Chamber Coalition in South Carolina: “Updating the risk evaluation to ensure that formaldehyde can continue to be produced and accessed in the United States is essential to protecting these businesses and the jobs they support. The revised evaluation, however, finds the balance between protecting both public health and the economy.”
• Joseph Summers, CEO of Minerva Defense in Alabama: “Expanding access to formaldehyde will not only strengthen domestic production of national security equipment but also American competitiveness at large.. This will keep jobs in the U.S. and ensure states like Alabama with major defense manufacturers remain competitive globally.”
• Matt Coday, Chairman of the Oil & Gas Workers Association in Texas: “Formaldehyde utilization supports approximately 1.5 million U.S. jobs and $1.6 trillion in economic output across industries like automotive, semiconductor manufacturing, and agriculture. Here in Texas and across the nation, this matters enormously. Our oil and gas sector employs hundreds of thousands of workers in drilling, completion, and production operations that depend on formaldehyde-based fluids.”
• Brad Boney, Former Commissioner for Galveston-Texas City Pilots: “The economic numbers also show just how valuable formaldehyde is to our state’s economy. Formaldehyde supports hundreds of thousands of jobs in our agricultural, manufacturing, and chemical industries, just to name a few. Countless businesses also spend billions of dollars on formaldehyde-based materials for their daily operations. As a result, maintaining and expanding access to this critical compound is essential to sustaining economic growth, supporting key industries, and protecting jobs.”
• Michael Campbell, President & CEO of the South Carolina Timber Producers Association: “As President and CEO of the South Carolina Timber Producers Association, I was glad to see the EPA propose a revised risk evaluation for formaldehyde. Contrasting with the extreme and unscientifically sound approach previously used, this revision will ensure the continued domestic production and access of formaldehyde by the industries that need it, including our state’s timber industry.”

Current & Formerly Elected Officials

• Attorneys General of Iowa et al.“We commend the Environmental Protection Agency for reaffirming its commitment to the use of the best available science and for aligning its analysis with the principles articulated in the Executive Order 14303, Restoring Gold Standard Science. The undersigned Attorneys General write to express our appreciation for the Agency’s recent efforts to reconsider key scientific assumptions underpinning the Toxic Substances Control Act risk evaluation for formaldehyde.”
• Former Ohio U.S. Congressman Bob Gibbs: “The revised evaluation gets it right and is a positive step forward in the deregulation agenda that President Trump is working to implement.”
• South Carolina State Representative Patrick Haddon: “Our farmers…need it to fight diseases and maintain sanitary conditions. Restricting access would mean billions in economic losses and food supply disruptions. The EPA's draft evaluation is the right step forward.”
• Brad Drake, Walton County Commissioner in Florida: “As a County Commissioner, it is my responsibility to help these farms continue to grow these key products. For many of these farms, that includes having access to resources like formaldehyde, which is invaluable for daily farming operations.
• Jamie Caudle, Chair of the Anson County Commission in North Carolina: “As Chair of the Anson County Commission and a local farmer here in North Carolina, I would like to voice my support for the EPA’s revised risk evaluation for formaldehyde. Formaldehyde plays a key role in our state’s farming and agricultural industry, and this proposal will ensure that our farmers continue to have access to this critical product and can continue to deliver for North Carolina’s economy and our nation’s food supply.”