Formaldehyde Update: EPA Releases Final TSCA Risk Analysis

In December, the Environmental Protection Agency (EPA) issued the final Toxic Substances Control Act (TSCA) Risk Analysis for formaldehyde. Despite the unfavorable initial draft, the final TSCA Risk Analysis includes several notable changes that are outstanding for the industry and align with AWC’s extensive oral and written comments. Specifically, EPA stated several times in the draft that wood products do not contribute to unreasonable risk from indoor exposure (inhalation), citing specifically TSCA Title VI. In addition, the draft included broad language that the EPA did not find an unreasonable risk from indoor air exposures, fence line exposures, or to the environment. Taken together, these are significant findings that reflect important initial wins for the industry.

Unfortunately, concern remains around the current analysis related to occupational exposure. The EPA did move its original occupational exposure value (OEV) from 11 ppb up to 170 ppb and 110 ppb as the acute non-cancer hazard value for sensory irritation and chronic cancer Inhalation Unit Risk for nasopharyngeal cancer. While these levels are significantly better than the initial 11 ppb proposal, they are still well below the internationally recognized exposure limits.

In the final Risk Analysis, EPA continued to rely on the flawed science in its previously released Integrated Risk Information System (IRIS) risk assessment. This is one of the key concerns for our industry in the report. As such, AWC is already developing a strategy to continue to work with EPA on an OEV that reflects the best available science and more closely aligns with the international consensus.

In 2025, the EPA’s review of formaldehyde under TSCA will advance to the risk management phase. During this stage, the agency will set the occupational exposure limit and clarify its assessments of unreasonable risk concerning wood products, indoor air quality, and fence line exposures. Once completed, risk management is a final regulatory action. If the process continues as intended, it will likely last throughout 2025 and possibly into 2026. AWC will continue to work with its partners at the American Chemistry Council and Composite Panel Association as the industry develops a broad collaborative strategy to continue to advocate for EPA to employ the best available science and fight against regulations that unduly burden our industry.