Frequently Asked Questions: Public Health
(HWPW = hardwood plywood; HWPW-VC = hardwood plywood veneer core; HWPW-CC = hardwood plywood composite core; PB = particleboard; MDF = medium density fiberboard)
1. Formaldehyde emissions are significantly lower today compared to say 20 years ago on average. Why regulate composite wood products particularly when most raw board is finished or laminated that encapsulates formaldehyde? Studies show that formaldehyde emissions occur from both laminated and un-laminated boards and that current exposures still result in a public health threat. In our view, until the formaldehyde content of the board is reduced, the health risks from exposure to formaldehyde continue to exist. In the interest of public health protection, action is needed to lower formaldehyde contents from composite wood products, which have been identified as major source of formaldehyde in the context of total daily exposure to the general public.
2. What is the target population you are trying to protect? If it is the end users, wouldn't finished goods be the only products to regulate? Why target raw panels that will be laminated (industrial grade)? The target population is the citizens of California. Because large amounts of formaldehyde are released over time from composite wood products made with UF resins, the best solution for reducing public exposure is to reduce the amount of formaldehyde emitted by composite wood products, which is aligned with the principal of "pollution prevention." In doing this, the amount of formaldehyde emitted in California will be lowered over the useful life of the raw panel or finished product (i.e., decades), regardless of whether the product is laminated or not.
3. What are the specific goals of the proposed regulations and lower formaldehyde emissions? Improved air quality? By what measure will it be improved? Reduced risk of cancer? By what percent? The specific goal of the proposed regulation is to reduce formaldehyde emissions from HWPW, PB, and MDF through the application of Best Available Control Technology (BACT), in consideration of technological feasibility and cost. Improved air quality is a resulting benefit, and implementation of the Phase 2 standards are projected to lead to a reduction in statewide formaldehyde emissions of 500 tons per year. Reduced risk of cancer from formaldehyde exposure is also a resulting benefit, and implementation of the Phase 2 standards is estimated to reduce excess cancer cases per million people from formaldehyde exposure by about 40%.
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