CPA Supports Coalition Comments on Oregon Air Emissions Rulemaking
CPA signed onto industry comments prepared by the American Wood Council (AWC) calling for the Oregon Department of Environmental Quality (DEQ) to not move forward with a proposed reduction of the existing Ambient Air Benchmark Concentrations (ABCs) for formaldehyde from 3 ug/m3 to 0.2 ug/m3. The comments make clear that in addition to not being supported by the science, the proposed reduced formaldehyde ABC falls below ambient air concentrations in most urban areas. The comments also encourage DEQ to have the Air Toxics Science Advisory Committee (ATSAC) further review, evaluate, and revise the ABC to incorporate the current science for formaldehyde, especially the World Health Organization (WHO) guideline.
While the ABCs are not regulatory and have no legal effect, they may be adopted directly into air emissions regulations through Risk Based Concentrations (RBCs). One such regulatory activity will be a draft air toxics rule that Oregon DEQ is currently preparing, which is expected to be released for comment in the near future. There is concern that the draft will include a revised RBC level for formaldehyde emissions derived from the proposed 0.2 ug/m3 formaldehyde ABC level. CPA will work with member companies active in the Oregon Business and Industry coalition and AWC to advocate for a more scientific, rational approach to setting the formaldehyde ABC. See Coalition Comments. More Info: Jackson Morrill