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ACC Comments on EPA’s Draft Formaldehyde TSCA Risk Evaluation

Evaluation Not Based On Best Science And Sets Up Unachievable Workplace Limits That Threaten Vital Industries

Charlotte Anthony

WASHINGTON (March 15, 2024) – Today, the American Chemistry Council’s (ACC) Formaldehyde Panel issued the following statement on the U.S. Environmental Protection Agency’s (EPA) draft formaldehyde risk evaluation under the Toxic Substances Control Act (TSCA): 

“Formaldehyde is one of the most well-studied chemicals in use today. ACC’s Formaldehyde Panel has strong concerns with the draft risk evaluation published on Friday, March 15th, by EPA. 

“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.

“Formaldehyde is a critical building block for essential applications including agriculture, food safety, medical devices, semiconductors, automobiles/electric vehicles, and affordable housing. Formaldehyde technologies have broad roles in the economy, supporting 987,000 jobs and $552.7 billion in sales in 2022 in the United States.

“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 on its current path, formaldehyde manufacturing and many of its downstream uses would be severely restricted or potentially banned in the U.S.

“Effective implementation of the TSCA program has been plagued with challenges. Today's draft risk evaluation is not based upon the best available science. EPA is obligated to recommit to meaningful stakeholder input, including from other federal agencies and small businesses, and independent peer review. ACC stands ready to work with the EPA and other decision-makers to help inform the evaluation about the important uses and innovations this substance enables.

American Chemistry Council

The American Chemistry Council’s mission is to advocate for the people, policy, and products of chemistry that make the United States the global leader in innovation and manufacturing. To achieve this, we: Champion science-based policy solutions across all levels of government; Drive continuous performance improvement to protect employees and communities through Responsible Care®; Foster the development of sustainability practices throughout ACC member companies; and Communicate authentically with communities about challenges and solutions for a safer, healthier and more sustainable way of life. Our vision is a world made better by chemistry, where people live happier, healthier, and more prosperous lives, safely and sustainably—for generations to come.

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