Daily News
From Home Furnishing Business
AHFA Comments on EPA Evaluation for Formaldehyde
May 20,
2024 by HFBusiness Staff in Business Strategy, Industry 
The American Home Furnishings Alliance (AHFA) joined with the International Wood Products Association (IWPA) and the National Retail Federation (NRF) to submit comments on the U.S. Environmental Protection Agency (EPA) 2024 draft risk evaluation for formaldehyde.
EPA prepared the risk evaluation as required by the Toxic Substances Control Act (TSCA). It was released for public comment and peer review on March 14. Comments were due May 14.
In its draft risk evaluation, EPA preliminarily found that formaldehyde poses unreasonable risk to human health. The evaluation notes that these risks may not apply to everyone, everywhere and describes some of the sources of uncertainties within the EPA’s findings.
“Formaldehyde is found nearly everywhere,” notes Bill Perdue, AHFA’s vice president of regulatory affairs. “The air we exhale contains formaldehyde. Formaldehyde is produced when organic materials like leaves and plants decay, and it is produced when some things burn, like furnaces and stoves and cigarettes. Formaldehyde is also released in the production of many products, including composite wood used as component parts in many types of residential furniture.”
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.
“These are the building blocks of all home furnishings. The EPA’s draft risk evaluation is of significant interest to the industry,” Perdue continues, “because it will be used to determine future exposure limits set for industrial settings like furniture factories. Most AHFA members have extensive operations that will be affected by an incorrect determination of ‘unreasonable risk.’”
In evaluating exposures, EPA is challenged with sorting out where exposure originates – from natural sources versus commercial activities. EPA found that people in workplaces where formaldehyde is used are at the most risk for formaldehyde exposure.
In the joint comments, AHFA, IWPA and NRF urged EPA to consider actual data from furniture production – supplied to the agency in more than 60 attached documents to the coalition’s comments – and find that the use of formaldehyde in furniture and interior wood finishes does not present an unreasonable risk to consumers and the general population. Nor does the use of formaldehyde in wood article production present an unreasonable occupational risk to human health.
Specifically, AHFA’s testing data show that formaldehyde emissions from furniture, including component parts such as fabric, foam and composite wood elements, along with the furnishings produced from these parts, are lower than the benchmarks EPA has proposed for acute and chronic exposure. AHFA supplied three sets of monitoring data collected at AHFA member U.S. facilities in 2011, 2017 and 2024. All of the AHFA data show exposures below occupational limits.
More than 200 entities submitted comments on the EPA’s formaldehyde report. Interested parties can view the docket and accompanying comments as they are posted by EPA here: https://www.regulations.gov/docket/EPA-HQ-OPPT-2023-0613.