by HIGH POINT – On January 2, the U.S. Environmental Protection Agency (EPA) released its final risk evaluation for formaldehyde conducted under the Toxic Substances Control Act (TSCA). As anticipated, the EPA determined that formaldehyde presents an unreasonable risk of injury to human health, specifically to workers and consumers, under specific “conditions of use.”
Based on this determination, EPA is expected to begin work on a proposed rule under TSCA section 6 to protect workers and consumers from the identified risks.
The American Home Furnishings Alliance (AHFA) is analyzing the voluminous report to determine its impact on the residential furniture industry.
“It is a complex report of over 1,200 pages, and, while it contains a positive determination for wood articles and composite wood component parts, it also includes some ambiguous inferences for finished goods,” said AHFA Vice President of Regulatory Affairs Bill Perdue this week. “We are reviewing the risk evaluation in detail and plan to consult EPA directly in an effort to provide clarity for our industry.”
On the consumer level, EPA’s evaluation states that the agency did not identify unreasonable risk to the general population from long-term exposure to wood articles and composite wood products that are already regulated for formaldehyde emissions under TSCA section 6.
However, under “conditions of use (that) significantly contribute to the unreasonable risk” posed by formaldehyde, EPA lists both commercial use and consumer use of “foam seating” as well as “furniture & furnishings.”
“It’s not clear exactly what the EPA intends to include under these ‘conditions of use.’ These broad terms require further explanation,” said Perdue, who has overseen the regulation of formaldehyde in home furnishings on behalf of the industry since 1992, when the California Air Resources Board first listed formaldehyde as a “toxic air contaminant” and named composite wood products as a “major source” of formaldehyde emissions. The EPA followed with a federal standard for formaldehyde in composite wood products in 2016, although implementation did not begin until 2018.
In 2019, EPA listed formaldehyde as a “priority chemical” under TSCA, triggering the comprehensive risk evaluation just released.
Unlike the ambiguous language related to consumer exposure, the EPA’s evaluation is clear when it comes to workplace exposure. The agency determined that workers may be exposed to formaldehyde concentrations high enough to result in sensory irritation and proposed an occupational exposure limit of 110 to 170 parts per billion. The American Chemistry Council has described that limit as “inconsistent with the best available science.”
The current U.S. Occupational Safety and Health Administration (OSHA) exposure limit for workers is 750 parts per billion. The European Union recently updated its workplace limits to 300 parts per billion.
AHFA currently is researching how the new worker exposure limit might impact domestic furniture operations.
Earlier this year, AHFA submitted comments on EPA’s draft risk evaluation for formaldehyde. Formaldehyde-based resins are used in the manufacture of composite wood, including hardwood plywood, particleboard and medium-density fiberboard. It also is used in some fabrics and is a by-product within foam. Perdue describes it as a “building block” within nearly all home furnishings.
AHFA’s comments to the agency in May included more than 60 attached documents outlining research and testing data on formaldehyde exposure from finished products as well as data from wood article production. The data on furniture production included evaluation of exposure levels collected at AHFA member facilities in 2011, 2017 and 2024, all showing exposures below current OSHA occupational limits.
