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NAM to EPA: Updated Formaldehyde Risk Calculations Will Help Manufacturers


Formaldehyde is “an essential chemical building block used in a wide range of products across many industries,” and the Environmental Protection Agency is right to be updating risk calculations for it under the Toxic Substances Control Act, the NAM said  this week. 
 
What’s going on: In December, the EPA released an updated draft risk-calculation memo for formaldehyde, which is critical to products that support a modern standard of living, from cars, to furniture, to fertilizer and insulation.  

  • The EPA’s updated inhalation risk calculations adopt a threshold framework, which is supported by the “weight of scientific evidence” and brings the agency’s conclusions in line with the broader scientific consensus, the NAM told EPA Office of Chemical Safety and Pollution Prevention Assistant Administrator Douglas Troutman on Monday in response to a December request for comment by the EPA.
  • The updated risk calculations incorporate key peer review feedback from the EPA’s own advisory bodies and are consistent with conclusions reached by other international scientific bodies that have evaluated formaldehyde rigorously. 
  • “[W]hen there is a robust base of scientific evidence to draw from, it is more appropriate to take a pragmatic approach that applies the ‘weight of the scientific evidence’ approach to select the best-available science to inform policy decisions,” said NAM Director of Chemicals, Materials and Sustainability Policy Reagan Giesenschlag. “This is the case for formaldehyde, which has been widely studied for decades.” 

More competitive manufacturing: The updates also bring the EPA in line with international bodies on the evaluation of formaldehyde, which will make manufacturing in the U.S. more competitive. 

  • “[M]anufacturers operate and compete in global markets with complex supply chains,” Giesenschlag told Troutman. “When U.S. requirements dramatically diverge from international approaches … it creates regulatory uncertainty that undermines domestic investments, increases compliance burdens and disadvantages U.S. production relative to foreign imports.” 

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