ACC Formaldehyde Consortium Submits Comments on EPA Prioritization Dossier

The American Chemistry Council (ACC) Formaldehyde Consortium submitted comments today on the EPA’s dossier regarding the proposed designation of formaldehyde as a high-priority substance for risk evaluation.  The dossier marks that last step in the prioritization stage of the Toxic Substances Control Act (TSCA) risk evaluation process. The dossier details EPA’s rationale for selecting formaldehyde as “high priority”, identifies potentially exposed or susceptible populations and provides some analysis of hazard and exposure.  It also identifies all possible conditions of use publicly reported to EPA through various Agency programs. 

The Consortium’s comments address a number of issues related to how EPA will undertake both its hazard and risk analyses should formaldehyde be designated as a priority chemical.  It also identifies a number of federal regulations already in place that address formaldehyde exposures for consumers and workers.  Notably, the comments include a long paragraph making the point that TSCA Title VI was recently completed and emphasizes that the purpose of the regulation, as stated in the final rule, is “to reduce formaldehyde emissions from composite wood products in order to protect human health.” 

In addition to participating as a member of the ACC Consortium, CPA is leading a group of nine other trade associations under the Federal Wood Industries Coalition (FWIC) to engage EPA throughout the risk analysis process.  Should EPA classify formaldehyde as a priority chemical, it must still determine whether composite wood products will be included as a condition of use in the final risk analysis. EPA will make this determination in its Scoping Document, which is expected to be released in March/April of 2020.  CPA is actively working through the Consortium and FWIC to engage EPA and make the case that formaldehyde emissions from composite wood products are adequately regulated under TSCA Title VI and therefore do not pose an unreasonable risk that would necessitate review under the TSCA risk evaluation.  See ACC TSCA Comments and Consortia Release.  More Info: Jackson Morrill


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