Assessment of Health  Risks

to Garment Workers and Certain Home Residents

        from Exposure to Formaldehyde
                 April  1987
  Office of Pesticides and Toxic Substances
     U.S.  Environmental  Protection  Agency

-------
                         Table of Contents
                                                             Page
List of Tables 	     v

List of Figures 	  viii

Preface 	     x

Authors, Contributors, and Reviewers 	    xi

Executive Summary 	  xiii


1.   Risk Characterization 	   1-1

    1.1.  Non-Cancer Effects 	   1-1

          1.1.1.   Sensory Irritation 	   1-1
          1.1.2.   Cellular Changes 	   1-4

    1.2   Carcinogenic Effects 	   1-6

          1.2.1.   Studies of Humans 	   1-7
          1.2.2.   Studies in Animals 	  1-12
          1.2.3.   Additional Supportive Evidence 	  1-14

    1.3.  Exposure in Residential and Apparel
            Manufacturing Settings 	  1-16

          1.3.1.   Residential Exposure 	  1-17
          1.3.2.   Exposure in Apparel Manufacturing 	  1-19

    1.4.  Quantitative Risk Assessment	  1-19

          1.4.1.   Non-cancer Risk Assessment 	  1-19
          1.4.2.   Cancer Dose-Response Assessment 	  1-23
          1.4.3   Numerical Risk Estimates 	  1-29


2.   Background 	   2-1


3.   Physical-Chemical Properties 	   3-1


4.   Hazard of Carcinogenic Effects 	   4-1

    4.1.  Long- and Short-Term Animal Tests 	   4-1
    4.2.  Data Selection for Quantitative Analysis  	  4-18

          4.2.1.   Polypoid Adenomas/Other Tumors Observed..  4-19

-------
    4.3.  Short-Term Tests:  Genotoxicity and Cell
            Transformation 	  4-22
    4.4.  Other Effects/Defense Mechanisms 	  4-35

          4.4.1.  Introduction 	  4-35
          4.4.2.  Sensory Irritation 	  4-35
          4.4.3.  Cell Proliferation, Cytotoxicity,
                    and the Mucous Layer 	  4-37

    4.5.  Metabolism and Pharmacokinetics 	.-•	  4-53

          4.5.1.  Absorption	  4-53
          4.5.2.  Pharmacokinetics 	  4-53
          4.5.3.  Summary	  4-69

    4.6.  Structure-Activity Relationships 	  4-70
    4.7.  Epidemiologic Studies Reviewed 	  4-77

          4.7.1.  Introduction 	  4-77
          4.7.2.  Review of Studies - Overview
         *          and Discussion 	  4-81
          4.7.3.  Conclusion 	 4-104

    4.8.  Weight-of-Evidence 	  4-107

          4.8.1.  Assessment of Human Evidence 	  4-107
          4.8.2.  Assessment of Animal Studies 	  4-111
          4.8.3.  Categorization of Overall Evidence 	  4-114


5.   Hazard of Noncarcinogenic Effects 	    5-1

    5.1.  HCHO-Related Effects of the Eyes and
            Respiratory System 	    5-1

          5.1.1.  Eye 	    5-2
          5.1.2.  Olfactory System 	    5-4
          5.1.3.  Upper Airway Irritation 	    5-4
          5.1.4.  Lower Airway and Pulmonary Effects 	    5-4
          5.1.5.  Asthma 	    5-7
          5.1.6.  Summary 	   5-10

    5.2.  Irritation/Sensitization--Dermal and Systemic  ...   5-11
    5.3.  Cellular Changes 	:	   5-14
    5.4.  Central Nervous System Effects 	   5-19

          5.4.1.  Neurochemical Changes 	   5-20
          5.4.2.  Human Studies 	   5-21
          5.4.3.  Conclusion 	   5-24
                                ii

-------
Tables                       Title                      .       Page

 6-8          Comparison of Non-UFFI Canadian Homes            6-32
              by Average Formaldehyde Concentration

 6-9          ORNL/CPSC Mean Formaldehyde Concentrations       6-34
              (ppm,)  as a Function of Age and Season
              (Outdoor Means Are Less Than 25 ppb
              Detection Limit)

 6-10         Frequency Distribution of Formaldehyde Levels    6-36
              in Washington Conventional Non-UFFI Homes

 6-11         Pre-1980 Monitoring Data for Garment             6-40
              Manufacturing and Closely Related Industries

 6-12         Recent Monitorign Data for Formaldehyde          6-41
              in the Garment Manufacturing Industry

 6-13         NIOSH Monitoring  Results - Ranges by             6-44
              Deparment
         ^
 6-14         Formaldehyde Concentration Levels                6-45
              (ppm) - Garment Manufacturing

 7-1          Carcinoma/Adenoma Tumor incidence in Fischer      7-2
              344 Rats and Male B6C3F1 Mice

 7-2          Estimated Individual and Population Risks       7-101
              Based Upon Squamous Cell Carcinoma Data
              From CUT Study.   Population Risks (number
              of excess tumors) Appear in Parentheses
              Below Individual  Risk Estimates

 7-3          Risk Estimates Using Polypoid Adenoma Data       7-13

 7-4          Upper Bound Risk  Estimates Based on the          7-19
              CUT Data for Given exposures to HCHO

 7-5          Estimated Lifetime Excess Risks Calculated       7-20
              from the Epidemiological Studies

 7-6          Risk Estimates Based on the Tobe Study           7-35

 8-1          Summary of Selected Cross Sectional Studies       8-5

 8-2          Summary of Selected Controlled Human Studies      8-9

 8-3          Exposure Ranges for Selected Endpoints           8-20
                               vii

-------
                          List of Figures


Figures                       Title                          Page

  1-1         Relationship Between Concentrations of         1-20
              Formaldehyde Causing Irritation and Cellular
              Effects and Milestone Exposure Levels

  4-1         Frequency of squamous metaplasia in the         4-5
              nasal cavity of Fischer 344 rats exposed
              to 2.0 ppm (top),  5.6 ppm (middle), or
              14.3 ppm (bottom)  of formaldehyde gas for
              24 months.   Nasal  cavity Levels I,  II,  IV,
              and V were not evaluated at the 6- and 12-
              month interim sacrifices in the 14.3 ppm
              exposure group.

  4-2         Frequency of squamous metaplasia in the         4-7
              nasal cavity of BBCSF^ mice exposed to
              14.3 ppm of formaldehyde gas.
         *
  4-3         Drawing indicating the level of sections       4-38
              from the nasal passages of rats and mice.

  4-4         Simplified reaction sequence from drug         4-62
              N-demethylation (cytochrome-P-450-dependent
              monooxygenase) to  HCHO,  formate, and CO2
              production (from Waydhas et al., 1978).
              Reactions are:  la,  HCHO dehydrogenase
              (GSH); Ib,  aldehyde dehydrogenase;
              Ic,  catalase (peroxidatic mode);
              2a,  10-formyltetrahydro-folate sythetase;
              2b,  10-formyltetrahydro-folate dehydrogenase;
              2c,  catalase (peroxidatic mode).

  4-5         Tetrahydrofolic acid pathway and 1-carbon      4-64
              transfer for HCHO  metabolism.

  4-6         Overall metabolism of HCHO.                    4-70

  6-1         Levels of Mobile Homes Corresponding to        6-23
              Year of Manufacture.

  6-2         Frequency of Formaldehyde Levels,  By           6-25
              Home Age, Exceeding 1.0, 0.4,  and 0.2
              ppm In Clayton and Wisconsin Data
              Combined.

  6-3         Frequency Distribution of Levels in            6-39
              Conventional Homes.
                              Vlll

-------
                           List  of  Tables
Table                       Title                              _Page

1-1           Health Effects and Representative Exposure        1-2
              Levels

1-2       .    Summary of Cancer Risks Associated with          1-31
              Formaldehyde Exposure

 4-1          Summary of Neoplastic Lesions in Nasal            4-2
              Cavity of Fischer 344 Rats Exposed to
              Formaldehyde Gas

 4-2          Summary of Neoplastic Lesions in the Nasal       4-10
              Cavity of Sprague-Dawley Rats

 4-3          Incidence of Polypoid Adenoma as Reported        4-20
              by PWG

 4-4     '    Effect of Formaldehyde Exposure on Cell          4-39
              Proliferation in Level B of the Nasal
              Passages

 4-5          Effect of the Time of 3H-Thymidine Pulse         4-40
              on Cell Replication After HCHO Exposure to Rat

 4-6          Effect of HCHO Concentration vs. Cumulative      4-40
              Exposure on Cell Turnover in Rats (Level B)

 4-7          Effect of HCHO Concentration vs. Cumulative      4-41
              Exposure on Cell Turnover in Rats (Level A)

 4-8          Effect of HCHO Concentration vs. Cumulative      4-42
              Exposure on Cell Turnover in Mice (Level A)

 4-9          Frequency of Squamous Metaplasia in Level 2      4-45
              of the Rat Nasal Cavity

 4-10         Incidence of Lesions Other Than Tumors in        4-46
              the Larnyx of Rats Exposed to Acetaldehyde
              [Numeric]

 4-11         Incidence of Epidermoid and Adenoid              4-46
              Squamous Carcinomas in Rats Exposed to
              Hexamethylphosphoramide

 4-12         Nasal and Laryngeal Cancer in Rats Treated       4-76
              with Acetaldehyde by Inhalation for 27 Months

 4-13         Summary of Studies Relevant to Formaldehyde      4-78

-------
Table                             Title                        P&fi

 4-14         Formaldehyde Levels to Which Occupational        4-83
              Groups Might Be Exposed

 4-15         Power Calculations for SMR Studies               4-85

 4-16         Conditional Power Calculations for PMR           4-89
              Studies

 4-17         Power Calculations for Case-Control Studies      4-91

 4-18         Fisher's Combined p for SMR and PMR Studies     4-101

 4-19         Predicted Human Relative Risks                  4-103
              for Selected Occupations

 5-1          Reported Health Effects of Formaldehyde           5-1
              at Various Concentrations

 5-2          Delayed Type Hypersensitivity (Human)            5-13
         •*    Due to Low Levels of Formaldehyde

 5-3          Significant Findings in Nasal Turbinates         5-16
              in Rats

 5-4          Significant Findings in Nasal Turbinates         5-16
              in Monkeys

 5-5          Total Incidence by Groups of Monkeys             5-16

 6-1          Populations at Risk                               6-4

 6-2          Use of Pressed-Wood Products in                   6-7
              Home Construction

 6-3          Summary of Residential Formaldehyde              6-16
              Monitoring

 6-4          Summary of Residential Monitoring Data           6-21
              from Randomly-Sampled Homes

 6-5          Potential Effects of Temperature and      -       6-27
              Relative Humidity Changes on Formaldehyde
              Air Concentrations

 6-6          Frequency of Observations Found in               6-28
              Concentration Intervals by Clayton
              Environmental Consultants

 6-7          Frequency of Observations Found in               6-29
              Concentration Intervals by Wisconsin
              Division of Health
                               VI

-------
7.
J . J .


5.6.
5.5.1. Animal Studies 	 	
5.5.2. Human Data 	
5.5.3. Conclusion 	
Effects on Visceral Organs 	
Exposure Assessment 	
6. 1.
6.2.
6.3.



6.4.



6.5.





6.6.
Introduction 	
Estimates of Current Human Exposure 	
Populations at Risk 	
6.3.1. Home Residents 	
6.3.2. Garment Workers 	

Sources of HCHO in Population Categories
of Concern 	
6.4.1. Homes Containing Pressed-Wood Products...
6.4.2. Garment Manufacture 	
HCHO Levels in Homes and Garment
Manufacturing Sites 	
6.5.1. HCHO Levels in Homes 	
6.5.2. Manufactured Homes 	
6.5.3. Conventional Homes 	

Summary 	
5-24
5-26
5-28
5-30
6-1
6-1
6-2
6-3
6-3
6-4
6-4

6-5
6-5
6-14

6-15
6-15
6-20
6-30
6-38
6-46
7.1.
7. 2.
7. 3.
7 4



Risk Estimates Based on
Souamous Cell Carcinoma Data 	 • 	
Risk Estimates Based on Polypoid
Adenoma Data 	 	

Pyecont' a i- i nn of Ri 
-------
          7.4.4.  Other Considerations-Squamous
                    Papillomas 	  7-33
          7.4.5.  Conclusion 	  7-35

    7.5   Summary 	  7-36


8.  Estimates of Noncancer Risks 	   8-1

    8.1.  'Introduction 	   8-1
    8.2.  Studies Reviewed 	   8-2
    8.3.  Limitations of Studies 	   8-2

          8.3.1.  Study Design Limitations 	   8-3
          8.3.2.  Bias Limitations 	   8-4

    8.4.  Results 	   8-4
    8.5.  Discussion 	  8-17


9.  References  	   9-1

    Appendix 1    Expert Panel Report on HCHO Pharmacokinetic
                  Data and CUT Response
    Appendix 2


    Appendix 3


    Appendix 4



    Appendix 5
Individual Summaries of Epidemiologic
Studies Reviewed

Estimates of Risk Using Various Extrapolation
Models

Documentation of High to Low Dose Extrapolation
Models Used in Quantitative Risk Assessment-
Concise Description

Sensitivity Analysis of CUT Rat Data Using
the Linearized Multistage Model
                                IV

-------
Figures                           Title                      Page

  7-1         Comparison of the Upper Bound Risks Based'     7-21
              on the Animal Data to Estimated Lifetime
              Excess Risks Based on the Epidemiological
              Studies.

  8-1         Predicted Irritative Response Over A Range     8-22
              of HCHO Levels.   Data From Hanrahan et.al.
              (1984)

  8-2         Predicted Irritative Response Over A Range     8-23
              of HCHO Levels.   Data from Anderson and
              Molhave (1984)

  8-3         Predicted Irritative Response Over A Range     8-24
              of HCHO Levels.   Data from Kulle (1985)

  8-4         Eye Irritation Response Over a Range of        8-25
              HCHO Levels
                               IX

-------
                             PREFACE








     The Health Risk Assessment of Formaldehyde (HCHO) was




prepared to serve as source document for Agency-wide use.  This



document was developed primarily for use by the U.S.



Environmental Protection Agency's (EPA) Office of Toxic



Substances to support decision-making regarding possible



regulation of HCHO under Section 6 of the Toxic Substances



Control Act.  Because this document focuses on inhalation



exposure to HCHO, this document should not be regarded as a



comprehensive assessment of the health effects from oral and



dermal exposure.  In addition,  only two exposure categories are




extensively reviewed.  Assessment of other categories will be



done as needed by other EPA program offices.



     In the development of this assessment document, the relevant



scientific literature available through February 1, 1986,. has



been incorporated, except that the epidemiologic section reflects



studies available through March 1987.  Key studies have been



evaluated and the summary and conclusions have been prepared so



that the health effects and related characteristics of HCHO are



qualitatively identified.  Measures of dose-risk relationships



relevant to inhalation exposure are also discussed so that the



adverse health responses can be placed in perspective with



possible exposure levels.

-------
               Authors,  Contributors,  and Reviewers
     The Existing Chemical Assessment Division within the Office
of Toxic Substances was responsible for preparing this document.

Principal Authors

Richard Hefter, M.S.
Cheryl Siegel Scott, M.S.P.H.
Harry Milman, Ph.D.
Elizabeth Margosches, Ph.D.
Gary Grindstaff, M.S.P.H.
Gregory Schweer, M.S.
Jeanette Wiltse, Ph.D.

Contributing Authors

Mary Argus, Ph.D.
Angela Auletta, Ph.D.
Frederick Dicarlo, Ph.D.
William Parian, Ph.D.
David Klauder, Ph.D.
Carl Mazza, Ph.D.
George Semeniuk, Ph.D.

Reviewers
     The following individuals provided peer review of this
document and or earlier drafts of this document.

Irwin Baumel, Ph.D.
Office of Regulatory Support
Office of Research and Development
Washington, D.C.

Steven P. Bayard, Ph.D.
Carcinogen Assessment Group
Office of Health and Environmental Assessment
Washington, D.C.

David L. Bayliss, Ph.D.
Carcinogen Assessment Group
Office of Health and Environmental Assessment
Washington, D.C.

Robert Beliles, Ph.D.
Carcinogen Assessment Group
Office of Health and Environmental Assessment
Washington, D.C.
                                XI

-------
VicXi L. Dellarco, Ph.D.
Reproductive Effects Assessment Group
Office of Research and Development
Washington, D.C.

Karen East, M.S.
Chemical Review and Analysis Branch
Office of Policy, Planning, and Evaluation
Washington, D.C.

A. M. Jarabek, Ph.D.
Environmental Criteria and Assessment Office
Cincinnati, Ohio

Nancy Pate, Ph.D.
Pollutant Assessment Branch
Office of Air Quality Planning and Standards
Research Triangle Park, NC

Peter Preuss, Ph.D.
Office of Health and Environmental Assessment
Washi ngton, D.C.

Van M. Seabaugh, Ph.D.
Hazard Evaluation Division
Office of Pesticide Programs
Washington, D.C.

Paul White, B.A.
Exposure Assessment Group
Office of Health and Environmental Assessment
Washington, D.C.


EPA Science Advisory Board

     The May 1985 draft of this document was independently peer-
reviewed in public sessions of the Environmental Health Committee
of EPA's Science Advisory Board.
                               xii

-------
                         Executive Summary








     EPA has conducted an extensive analysis of the experimental



and exposure information on formaldehyde in order to characterize



the potential risk to humans from exposure to the chemical.



     The major non-cancer effects posed by formaldehyde are due to



the irritation (i.e., irritation of the eyes, nose, throat and



lungs) and cellular changes (i.e., effects on the mucociliary



system of the nose).  A large number of observations of people in



various settings support a conclusion that the generally observed



range over which more than 95% of people respond is 0.1-3.0 ppm of



formaldehyde.  Generally, little risk from non-cancer health



effects from exposure to formaldehyde is attributed to cases where



exposures are one hundred-fold less than a no- or lowest-observed



effect level.  Although quantitative estimates of non-cancer risk



are not possible, fewer responses are expected to be associated



with fewer and less intense exposures.



     EPA has classified formaldehyde as a "Probable Human



Carcinogen" (Group Bl) under its Guidelines for Carcinogen Risk



Assessment.  Based on a review of epidemiologic studies, EPA has



concluded that there is "limited" evidence to indicate that



formaldehyde may be a carcinogen in humans.  Nine studies reported



statistically significant associations  between site-specific



respiratory neoplasms and exposure to formaldehyde or formaldehyde-



containing products.
                                XI 11

-------
     An examination of studies in animals has indicated that there



is "sufficient" evidence of carcinogenicity of formaldehyde in




animals by the inhalation route.  This is based on the induction by



formaldehyde of an increased incidence of a rare type of malignant



tumor (i.e., nasal squamous-cell carcinoma) in both sexes of rats,




in multiple inhalation experiments,  and in multiple species (i.e.,



rats and mice).  In these long-term laboratory studies, tumors were



not observed beyond the initial site of nasal contact.




     Supportive evidence for the carcinogenicity of formaldehyde



was obtained from short-term tests designed to measure effects on



DNA.  Formaldehyde is mutagenic in numerous bacterial test systems



and test systems using fungi and insects (Drosophila).  It also



tranforms cells in culture and causes DNA cross-linking, sister



chromatid exchange (SCE) and chromosome aberrations.   In addition/




formaldehyde has been shown to form adducts with DNA  and with



proteins in both in vivo and in vitro test systems.   Its ability to



interfere with DNA repair in human cells has also been shown.



     Structure-activity correlations support the prediction of



potential carcinogenicity.  Formaldehyde is one of several



aldehydes which have been shown to have carcinogenic activity in



experimental animals.  Acetaldehyde, the closest structural



analogue of formaldehyde, induces the same type of malignant tumor



in the respiratory and olfactory epithelium of the nose of rats as



does formaldehyde.



     Results from studies in rats by the Chemical Industry



Institute of Toxicology were used to estimate the human cancer
                                xiv

-------
risk.  The malignant tumor data were used to extrapolate human




cancer risk because only this response in formaldehyde-exposed rats



was definite and unequivocal in both sexes of rats, was dose-



related, and was confirmed in several rat inhalation studies.  In




the absence of compelling biological evidence on the mechanism of



action, as in the case for formaldehyde, EPA's Guidelines for



Carcinogen Risk Assessment specify the selection of the linearized




multistage procedure for estimating human cancer risk.  Using this



procedure, the upper bound estimate for excess lifetime risk of



developing cancer is 3xlO~4 (Group Bl) for apparel workers exposed



to formaldehyde at the 0.17 ppm level; 2x10"^ (Group Bl) for



residents of mobile homes who are exposed for 10 years to an



average level of 0.10 ppm; and lxlO~4 (Group Bl) for residents of



some conventional homes who are exposed for 10 years to an average



level of 0.07 ppm.  The upper bound estimate for an ambient



exposure of 1 ug/m^ (0.00082 ppm) for 70 years (the unit risk) is



1.3xlO~5 (Group Bl).



     Since some of the existing information supports the use of



non-linear risk assessment models to extrapolate cancer risk to



humans, and since considerable uncertainty exists in the risk



estimates, the real risk may be lower than that projected by the



upper bound, linear estimate.   The lower bound is always recognized



to be as low as zero.   However,  the predicted excess lifetime



cancer risk estimates using an upper bound based on the rat nasal



carcinoma data are about equivalent to the excess cancer incidence




observed in the epidemiologic studies.
                                 xv

-------
                    1.  Risk Characterization





     This risk-characterization presents the major conclusions of



EPA's risk assessment of formaldehyde.  It reviews the underlying



scientific foundation for the findings, describes the strengths



and weaknesses of the supporting data, and discusses the



uncertainties and potential sources of controversy attending



EPA's interpretation of the data and projection of risk.  The



risk characterization is divided into three sections which



discuss the qualitative aspects of the risk assessment,  the



exposure, and the quantitative risk estimations at current



exposure levels.  A summary of the health effects of formaldehyde



and representative exposure levels is presented in Table 1-1.



1.1. Non-cancer Effects



     The major non-cancer effects posed by exposure to



formaldehyde are due to the irritating nature of the chemical.



These effects are sensory irritation which is readily perceived



by the exposed individual and cellular changes which are less



evident but still important.



1.1.1.  Sensory Irritation



     The well documented health effects from acute inhalational



exposures are concentration dependent, with individuals



responding above a threshold concentration.  These effects



include irritation of the eyes,  nose, throat and lungs,  the



intensity of which is dependent upon the extent and duration of



exposure, and may result in extreme discomfort and inability to



function normally at work or in routine daily activities.
                               1-1

-------
                                     TABLE 1-1
                 HEALTH EFFECTS AND REPRESENTATIVE EXPOSURE LEVELS
 Formaldehyde
 Concentration
    (ppm).
                         Health Effects
                        (Exposure time)
a
Representative
   Exposure
    Levels
  <  0.05
    0.1
    0.5
    1.0



    2.0


    3.0
    5.0
   15.0
                Human eye irritation
                begins in sane people
                (minutes-hours)
                Human mucociliary inhibition
                and squamous metaplasia,
                mid-point of range in one study
                (0.1-1.1 ppm) (years)

                Human nose and throat irritation
                begins; most people have eye
                irritation (minutes-hours)

                Rat squamous metaplasia, and
                mucociliary system LOEL  (months)

                Human (most) experience nose and
                throat irritation (minutes)

                Monkey squamous metaplasia LOEL
                (weeks)

                Rat observed 1% cancer  incidence
                (years)

                Human lower airway effects begin
                (minutes-hours)

                Rat observed 50% cancer incidence
                (years)

                Mouse observed 1% cancer  incidence
                (years)
                                                         Ambient background
                  New mobile homes
                  10-yr average
                  Current OSHA PEL
                  (8 hr TWA)
                  Highest recorded
                  honec
a
b
c
Duration of exposure causing the effect  is  indicated  in parentheses.
LOEL = lowest observed effect  level
Urea-formaldehyde foam insulated home
                                      1-2

-------
     Due to varying sensitivities, all individuals do not exhibit
these acute effects at the same formaldehyde concentration.
Thus, the number of persons who respond in a population will
increase with increasing concentrations of formaldehyde.  A dose-
response relationship has not been quantitatively characterized
for the general population.  However, a large number of
observations of people in various clinical and nonclinical
settings support a conclusion that the generally observed range
over which most people respond (more than 95% response) is 0.1-
3.0 ppm of formaldehyde.
     Eye irritation occurs first at the lower end of the range;
the percentage of individuals that respond increases up to a
concentration of formaldehyde of 1.0 ppm,  the concentration at
which virtually all persons exhibit some degree of eye
irritation.  Irritation of the nose and throat frequently occurs
above 1.0 ppm with most persons responding by 3.0 ppm.  Exposures
greater than 3.0 ppm are generally intolerable for more than
short periods.  These acute effects are usually reversible.
Tolerance to low levels of formaldehyde can occur in individuals
after 1-2 hours of exposure, but symptoms can return if exposure
is interrupted and then resumed.
     In addition to its direct irritant effects on the
respiratory system, formaldehyde has been shown to cause
bronchial asthma-like symptoms in humans.   Although asthmatic
attacks may, in some cases, be due specifically to formaldehyde
sensitization or allergy, the evidence for this is
inconclusive.  Even so, a small number of reports indicate that
                               1-3

-------
formaldehyde may be an inhalant sensitizer causing allergic



reactions.  There are no sufficiently well controlled studies to



establish the extent of such sensitization in the population, nor



are induction concentrations of formaldehyde known.  However, the



concentrations of formaldehyde required to elicit such attacks



are higher than would be expected in most non-occupational



envi ronments.



1.1.2.  Cellular Changes



     The primary point of contact of formaldehyde upon exposure



by inhalation is the nose.  Inhalation of formaldehyde above a



threshold level which varies from person to person causes a



number of cellular effects which can impair the normal



functioning of the nose and are dependent on the concentration



and duration of exposure.



     A major function of the nose is to prepare the inhaled air



for the lungs.  This includes warming, moistening, and filtering



the inspired air.  Dust and many bacteria found in the inspired



air are precipitated in the mucus that bathes the mucous membrane



and are moved outward by the action of the cilia of the nasal



passage.  Research indicates that formaldehyde has a number of



effects on the workings of this mucociliary apparatus.



     Effects on the mucociliary system of laboratory animals have



been observed in several short-term exposure studies.  In one



study, male rats were exposed for 6 hours per day for up to 14



days, to 0.5, 2, 6, or 15 ppm of formaldehyde.  At 15 ppm, the



stopping of mucous flow (mucostasis) followed by cessation of



ciliary activity (ciliastasis) was clearly shown.  Only slight
                               1-4

-------
effects were noted in animals being exposed to 6 ppm or 2 ppm.




At 0.5 ppra no effects were observed.  In other short-term studies



formaldehyde caused cell proliferation in the nasal epithelium at



doses of 2 ppm and higher.  Cell proliferation is a part of the



restorative process to repair cellular damage.



     In chronic studies, cellular effects, i.e., rhinitis



(inflammation of the nasal mucosa), epithelial dysplasia



(displacement of one cell type with another one), and squamous



metaplasia (replacement of normal mucosal cells with squamous



cells), developed in the nasal cavities of rats and monkeys after




exposures for 12 months and 26 weeks,  respectively, to 2-3 ppm of



formaldehyde.  After 24 months of exposure,  the incidence of



squamous metaplasia in rats increased to nearly 100 percent.  In



both rats and monkeys, a NOEL (no observed effect level) of 1.0



ppm for squamous metaplasia was determined,  with a LOEL (lowest



observed effect level) of 2.0 ppm in rats and 3.0 ppm in



monkeys.  The potential relationship between squamous metaplasia



and carcinogenesis is presented in section 1.4.2.2.



     Evidence of cellular damage in humans is Limited.  One study



in which humans were occupationally exposed from four to nine



years (mean = seven years) to formaldehyde in the range of 0.1-



1.1 ppm, time-weighted average (TWA) concentration, showed loss




of ciliary activity and development of squamous metaplasia.



Caution must be used when generalizing from this study because of



the small number of exposed persons examined (20) and the




possibility of confounding exposure.  Five individuals in the



formaldehyde-exposed group exhibited nasal cavity changes.
                               1-5

-------
     The mucociliary system is an important defense mechanism in

the removal of foreign particles and bacteria which enter the

upper respiratory system.  A reduction in the efficient operation

of this defense mechanism,  including formation of squamous

metaplasia, by exposure to formaldehyde may increase the risk of

persons exposed to formaldehyde to develop infections and other

respiratory diseases.

1.2.  Carcinogenic Effects

     EPA has classified formaldehyde as a "Probable Human

Carcinogen" (Group Bl) under its Guidelines for Carcinogen Risk

Assessment.  This classification is based on the following:
         *
     o  limited evidence of carcinogenicity in humans (i.e.,

        several epidemiologic studies show positive associations

        between respiratory site-specific cancers and exposure to

        formaldehyde);

     o  sufficient evidence of carcinogenicity in animals (i.e.,

        formaldehyde induced an increased incidence of rare,

        malignant nasal squamous-cell carcinoma in mice and rats,

        and in multiple experiments); and

     o  additional supportive evidence (i.e., studies

        demonstrating formaldehyde's mutagenic activity in

        numerous test systems using bacteria, fungi, and, insects,

        and its ability to transform cells in culture and cause

        DNA damage in other in vitro assays for mutagenicity.

        Also,  structure-activity analysis indicates that

        formaldehyde is one of several carcinogenic aldehydes.)
                               1-6

-------
1.2.1.  Studies of Humans

     The EPA has examined 28 epidemiologic studies relevant to

formaldehyde.  Three of these studies, two cohort* (Blair et al.,

1986; 1987 in press; Stayner et al., 1986) and one case-control2

(Vaughan et al., in press), were well conducted and specifically

designed to detect small to moderate increases in formaldehyde-

associated human risks.  Each of these three studies observed

statistically significant associations between respiratory site-

specific cancers and exposure to formaldehyde or formaldehyde-

containing products.  These associations are noteworthy since

during inhalation,  tissues in the nose, nasal sinuses, buccal

cavity (mouth), pharynx,3 and lungs come into direct contact with

formaldehyde.  In each of the above three studies, the

populations studied were also undoubtedly exposed to other

chemicals and these exposures may have contributed to the

observed increases in cancer risk.   Only the study by Vaughan

et al. (1986a,b) controlled for smoking and alcohol consumption.
  A cohort study follows a group of exposed individuals for a
specified time period and measures the incidence of site-specific
deaths.  The observed number of site-specific deaths which
occurred in the time period are compared to the number of site-
specific deaths which would be expected based on mortality rates
of a standard population.

  A case-control study identifies cases with the disease of
interest and controls who do not have the disease.  The cases and
controls are compared with respect to past exposure.
^ The pharynx is the passage between the nasal cavity and the
larynx.  The nasopharynx, hypopharynx, oropharynx, and
laryngopharynx comprise the pharyngeal region.
                               1-7

-------
     The Blair et al. (1986; 1987 in press) cohort study observed



significant excesses in lung and nasopharyngeal cancers among U.S.



workers occupationally exposed to formaldehyde at 10 industrial



sites.  Blair et al. (1986), however, argued that the lung cancer



excesses provided little evidence of an association with



formaldehyde exposure since the lung cancer risk did not increase



consistently with either increasing intensity or cumulative



formaldehyde exposure.  EPA, after reviewing the data, has



concluded that the  significant excesses in total lung cancer



mortality,  in analyses either with or without a latency period



equal to or greater than 20 years, and together with nasopharyngeal



cancer mortality among formaldehyde-exposed workers are meaningful



despite the lack of significant trends with exposure.



Misclassification of exposure (or lack of specificity between



exposure categories) and categorization of deaths into four



exposure levels which lowers the power to detect small increases in



risk, may have accounted for the observed lack of a significant



dose-response relationship.  The significance of these findings is



reinforced by the fact that the site of the tumors seen in humans



(the nasopharyngeal region) is similar to that seen in animals.



Blair et al. (1987) performed further analyses of the



nasopharyngeal cancers regarding exposure to formaldehyde and



particulates.  For  those workers with particulate exposure, the



trend between increasing nasopharyngeal risk and increasing



cumulative formaldehyde exposure was not statistically significant,



however, the authors concluded that formaldehyde and particulates



appeared to be. a risk factor for nasopharyngeal cancer.
                               1-8

-------
     The Stayner et al. (1986) cohort study reported statistically

significant excesses in mortality from buccal cavity tumors among

formaldehyde-exposed garment workers.  The standardized mortality

ratio  (SMR), a ratio of the observed number of deaths to an age-

adjusted number of deaths expected in the group, was highest among

workers with a long duration of employment (exposure) and follow-

up period  (latency).  A significant excess in deaths from cancer

of the tonsils was also reported, but there were too few deaths to

examine any trends with exposure.

     Results from the case-control study by Vaughan et al.

(1986a,b) showed a significant association between nasopharyngeal

cancer and having lived 10 or more years in a "mobile home".

Persons for whom this association was drawn had lived in mobile

homes that were built in the 1950s to 1970s.  This study also

reported significant associations between sinonasal cancer and

orohypopharyngeal cancer and exposure to resins, glues, and

adhesives  (SAIC, 1986).   Mo significant trends were found in

cancer incidence at any of these sites with respect to

occupational formaldehyde exposure; however, the risk estimates

for the highest exposure level and cancers of the orohypo- and

naso-pharynx appeared elevated.  As stated earlier, however, this

population, like the two previously discussed, was also

undoubtedly exposed to other chemicals which may have contributed

to the observed increases in cancer risk.
 Several residential and occupational characteristics were _a
priori selected as likely surrogates for formaldehyde exposure.
Among these were mobile home residency and occupational resins,
glue, and adhesive exposure.
                               1-9

-------
     EPA previously had reviewed 25 other epidemiologic studies.




These studies had limited ability (lower power) to detect small to



moderate increases in formaldehyde-related risks due to (1) small




sample sizes; (2) small numbers of observed site-specific deaths;



and (3) insufficient follow-up.  Even with these potential



limitations, six of the 25 studies (Acheson et al., 1984a; Hardell



et al., 1982; Hayes et al., 1985; Liebling et al., 1984; Olsen et



al., 1984;  Stayner et al., 1985) reported significant associations



between excess site-specific respiratory (lung, buccal cavity, and



pharyngeal) cancers and exposure to formaldehyde.



     The Olsen et al. (1984),  Hayes et al. (1986), and Hardell et



al.  (1982)  studies reported significant excesses of sinonasal



cancer in individuals who were exposed to both formaldehyde and



wood-dust,  or who were employed in particleboard manufacturing



where formaldehyde is a component of the resins used to make



particleboard.  Only the Hayes et al. (1986) and Olsen et al.



(1984) studies controlled for wood-dust exposure; the detection



limits in both studies, however, exceeded corresponding expected



excesses in the incidence of sinonasal tumors and, therefore, no



significant excesses were likely to have been observed.



     The Acheson et al. (1984a) study conducted in the United




Kingdom supports the results of Blair et al. in that, when



compared to mortality rates of the general population, significant



excesses in mortality from lung cancer were observed in one of six



formaldehyde resin producing plants in England.  A trend of



borderline significance with dose was observed for this one



plant.  Acheson et al. concluded that the increases in mortality
                               1-10

-------
from lung cancer were not related to formaldehyde exposure since
the elevation and trend were not statistically significant when
compared with local lung cancer rates.  EPA believes that the
risks and trends from analyses using local lung cancer rates as
the comparison risks appeared sufficiently increased for
corroborative use.
     The remaining two studies reported significant excesses of
buccal cavity cancer among garment workers in 3 plants (Stayner et
al., 1985) and excesses of buccal cavity and pharyngeal cancer
among formaldehyde resin workers in 1 plant (Liebling et al.,
1984).  Portions of the Liebling et al. (1984) and Blair et al.
(1986, 1987) studies overlapped as did portions of the two Stayner
et al. (1985; 1986) studies.  However, the non-overlapping
portions and improved design of the more recent studies (i.e.,
Blair et al. 1986, 1987; Stayner et al. 1986)  reinforce the
conclusions of the earlier studies.
     Analyses of the remaining 19 epidemiologic studies have
indicated the possibility that observed leukemia and neoplasms of
the brain and colon may be associated with formaldehyde
exposure.  The biological support for such postulates,  however,
has not yet been demonstrated.
                               1-11

-------
     Based on a review of these studies, EPA has concluded that

there is "limited" evidence to indicate that formaldehyde may be a

carcinogen in humans.^  Nine studies reported statistically

significant associations between site-specific respiratory

neoplasms•and exposure to formaldehyde or formaldehyde-containing

products.  This is of interest since inhalation is the primary

route of exposure in humans.  Although the common exposure in all

of these studies was formaldehyde,  the epidemiologic evidence is

categorized as "limited" primarily due to possible exposures to

other agents which may have confounded the findings of excess

cancers.
         •
1.2.2.  Studies in Animals

     The principal evidence indicating that formaldehyde causes

cancer in animals comes from studies conducted by the Chemical

Industry Institute of Toxicology (CUT) (Kerns et al. ,  1983) and

those by Albert et al. (1982) and Tobe et al.  (1985).  The CUT

study was a well conducted, multidose inhalation study in rats and

mice.  In this study, a statistically significant increase in

malignant tumors (i.e., squamous cell carcinomas) was seen in the

nasal cavities of male and female rats dosed at 15 ppm.  In

addition, a small increased incidence of squamous cell carcinoma,

while not statistically significant, was seen in male mice.
  EPA's Guidelines for Carcinogen Risk Assessment define limited
evidence of carcinogenicity in humans as indicating that "...a
causal interpretation is credible, but that alternative
explanations, such as chance, bias, or confounding, could not
adequately be excluded."
                               1-12

-------
Because this.type of nasal Lesion is rare in mice, these data can

be considered to have biological importance.  Benign tumors (i.e.,

polypoid adenomas) were seen in male rats in the CUT study at all


dose levels and in female rats exposed to 2 ppm of formaldehyde.

Notably, the dose-response curve for the benign tumors in this

study was not linear; the tumor, incidence was highest at 2.0 ppm

and decreased at higher doses.

     Tobe et al.  also observed a statistically significant

increase in the numbers of squamous cell carcinomas in the same

strain of male rats as was used in the CUT study.  Albert et al.

reported a statistically significant elevation of the same
         *
malignant tumor type in male rats of a different strain.  In both

the Tobe et al. and Albert et al. studies benign squamous cell

papillomas were seen.  This observation was in contrast to the

CUT study in which polypoid adenomas were the only benign tumors

observed.  Hamsters have been tested in long-term inhalation

studies (Dalbey,  1982) but no increased incidence of tumors was

seen in formaldehyde-treated animals.  However, deficiencies in

the study design and poor survival limit the interpretation of the

results from these studies.

     Additional studies in animals that indicate an association

between exposures to formaldehyde and cancer are those by Dalbey

(1982) in which formaldehyde enhanced the production of tumors

induced by a known animal carcinogen (i.e., diethylnitrosamine);

Mueller et al. (1978) in which formalin (a water solution of

formaldehyde) produced lesions in the oral mucosa of rabbits which

showed histological features of carcinoma in situ; and studies by
                               1-13

-------
Watanabe et al. (1954; 1955) in which injections of formalin and

hexamethylenetetramine (from which formaldehyde is liberated in

vivo) produced sarcomas (malignant tumors) and one adenoma (benign

tumor) at the site of injection.

     Based upon a review of these studies, EPA has concluded that

there is "sufficient" evidence of carcinogenicity of formaldehyde

in animals by the inhalation route.    This finding is based on the

induction by formaldehyde of an increased incidence of a rare type

of malignant tumor (i.e., nasal squamous-cell carcinoma) in both

sexes of rats,  in multiple inhalation experiments, and in multiple

species (i.e.,  rats and mice).  In these long-term laboratory

studies, tumors were not observed beyond the initial site of nasal

contact nor have other mammalian in vivo tests shown effects at

distant sites.

1.2.3.  Additional Supportive Evidence

     Other relevant information which is considered in carcinogen

assessments include results from short-term tests designed to

measure effects of a chemical on DNA.  Tests for point mutations,

numerical and structural chromosome aberrations, DNA

damage/repair,  and in vitro cell transformation provide evidence

for the potential mechanisms of carcinogenicity.  A battery of
  EPA's Guidelines for Carcinogen Risk Assessment define
sufficient evidence of carcinogenicity from studies in
experimental animals as indicating that "...there is an increased
incidence of malignant and benign tumors:  (a)  In multiple
species or strains; or (b)  in multiple experiments (preferably
with different routes of administration or using different dose
levels); or (c)  to an unusual degree with regard to incidence,
site or type of tumor, dose-response effects, as well as
information from short-term tests or on chemical structure."
                               1-14

-------
tests which measure different endpoints helps to characterize the



chemical's response spectrum.  In general, the wider the range and



the greater the intensity of response of a substance in short-term



tests, the more likely it is that the substance may cause cancer.



     Formaldehyde is mutagenic in numerous bacterial test systems



and test systems using fungi and insects (Drosophila).   It also



transforms cells in culture and causes DNA cross-linking, sister



chromatid exchanges (SCE) and chromosome aberrations.  In


addition, formaldehyde has been shown to bind with DNA and with



proteins in both in vivo and in vitro test systems.  Its ability



to interfere with DNA repair in human cells has also been shown.
         »

     Structure-activity correlations support the prediction of



potential carcinogenicity.  Formaldehyde is one of several



aldehydes which have been shown to have carcinogenic activity in


experimental animals.   Of those tested, acetaldehyde, is the



closest structural analogue of formaldehyde.  Like formaldehyde,



acetaldehyde damages the respiratory and olfactory epithelium,



however, formaldehyde appears to be more potent than



acetaldehyde.  The main impact of formaldehyde, probably because



of its greater reactivity, occurs more in the anterior portion of


the nose than that of acetaldehyde.  Exposure to either aldehyde



leads to the formation of nasal squamous cell carcinoma;



acetaldehyde, however, also induces another type of malignant



nasal tumor, adenocarcinoma.  Polypoid adenoma (benign tumor) were



seen following exposure to formaldehyde whereas squamous-cell



papilloma (benign tumor) were found following treatment with



acetaldehyde.  The utility of benign tumors in risk assessment is



discussed in sections 1.4., 4.2.1., and 7.4.




                               1-15

-------
1.3. Exposure in Residential and Apparel Manufacturing Settings




     EPA's risk assessment focuses on two large populations



chronically exposed to low levels of formaldehyde.  These



populations include: (1) persons who reside in mobile and




conventional homes constructed using "significant amounts" of



urea-formaldehyde (UF) pressed-wood (i.e, homes in which UF



pressed wood is used for floor underlayment and, in some cases,



for wall paneling),  and (2) apparel workers who are exposed to



formaldehyde that is emitted from durable press fabrics.



     Available air monitoring data, although not collected under




any comprehensive nation-wide survey,  indicate that exposure



levels in both settings have declined over the last 5 years.  This



is consistent with the increased commercial use of lower-emitting




formaldehyde source material (pressed wood products and durable



press resins).



     Measurements of formaldehyde levels are strongly affected by



a number of factors that add to the overall uncertainty of the



data.  These factors include the monitoring methods employed, the



amount and age of the formaldehyde source material present at the



site, the extent of ventilation at the site, and the ambient



temperature and humidity.   High temperature and humidity, for



example, are known to increase emissions of formaldehyde from



pressed wood products and  durable press fabrics.  However, many of



the formaldehyde monitoring efforts did not report or document



adequately these variables.




1.3.1.  Residential Exposure



     Most of the monitoring data collected in residences over the
                               1-16

-------
last decade have been in older homes, homes in which urea-



formaldehyde foam insulation (UFFI) has been installed, or homes



in which the occupants have expressed health complaints.  Perhaps



more representative of current formaldehyde levels in new mobile



arid conventional homes are several recent monitoring studies



conducted in California, Tennessee and Texas.   These studies



evaluated homes built after 1980, when builders were using energy-



efficient (tighter) construction and most pressed wood producers



had begun to use low-emitting resin adhesives.



     Recent monitoring results indicate that formaldehyde levels



in new (less than one year old) conventional homes generally fall



within the range of 0.05 ppm to 0.2 ppm; few measurements exceeded



0.3 ppm.  In new mobile homes, formaldehyde levels monitored



generally fall within the range of 0.2 ppm to 0.3 ppm with the



highest levels measured near 0.4 ppm, the ceiling level targeted



by Department of Housing and Urban Development regulations that



govern mobile home construction.  The larger range of values



observed in conventional homes is attributed primarily to the



greater variation in design and use of UF pressed wood products in



their construction.  By contrast, mobile homes have less design



variation and, for the most part, generally use pressed wood



products more extensively.  EPA has developed computer models to



estimate initial formaldehyde levels in conventional homes built



using significant amounts of pressed wood.  Although these models



have not been fully validated, they yield expected values that



fall within the range of 0.1-0.2 ppm.



     EPA estimates that every year approximately 631,000 persons
                               1-17

-------
move into new conventional homes that contain significant amounts

of pressed wood.  In the same period, about 780,000 persons move

into new mobile homes.

     Under normal conditions, the amount of formaldehyde released

from pressed wood products decreases with time, lowering the

levels in these residences.  Although numerous studies have

investigated the decrease in emissions from uncoated pressed wood

in the months immediately after its manufacture,  little

quantitative information is available on long-term (10-year)

formaldehyde emissions from pressed wood.  In lieu of long-term

emission decay data, EPA derived a decay curve function by
          *
combining the results of two large monitoring surveys and

statistically determining the best-fit curve to the data as a

function of home age.  Combined, the two surveys reported almost

1,200 measurements in 400 mobile homes that were constructed

during 1970-1980 and ranged .in age from one day to nearly 10

years.  EPA has used the exponential function derived from these

data for quantitative cancer risk assessment purposes to calculate

expected 10-year averages for formaldehyde levels in homes built

today.  The calculated 10-year averages are 0.07 ppm for

conventional homes built using significant amounts of UF pressed

wood and 0.1 ppm for mobile homes.  As these estimates are derived

from historical data, a significant source of uncertainty

associated with these estimates is the unknown long-term emission

characteristics of the UF resins used today to manufacture the

pressed wood products used in these homes.
                               1-18

-------
1.3.2.  Exposure in Apparel Manufacturing



     The U.S. apparel industry employed over 1.1 million workers



in 1983.  There are approximately 22,600 apparel manfacturing



establishments located in every state of the country, and each



employs an.average of 59 workers.



     Monitoring data collected by the National Institute for



Occupational Safety and Health (NIOSH),  the Occupational Safety



and Health Administration (OSHA), or otherwise reported in the



literature indicate that formaldehyde levels in these facilities



were generally below 3.0 ppm prior to 1980.  In later years, the



levels have generally fallen below the 1.0 ppm level.  Recent



industrial hygiene studies by NIOSH of two large manufacturing



sites that produce mens' shirts indicated that the mean exposure



level for both plants was 0.17 ppm.



1.4.  Quantitative Risk Assessment



     The risk assessment identified two biological effects for



which the data are sufficient to evaluate quantitatively.  These



are acute sensory/cellular effects of the upper respiratory tract



and cancer.   A combination of results obtained from studies in



animals and humans were used to assess the acute sensory/cellular



effects while the cancer risk estimates were derived from modeling



data obtained from studies in animals.



1.4.1.  Non-cancer Risk Assessment



     Figure 1-1 illustrates the relationship between the doses



associated with sensory irritation and cellular effects in the



nasal cavity and the exposure levels for a number of population



groups.  Instead of using high-to-low dose extrapolation models,
                               1-19

-------
I
to
o
      a)
      b)
           10-yr awj.
           scneoorv.
             homes
                    NIGEH
                    gatnent
                    vorters
              10-yr avg.
             ncbile tares
                    avg. new
                   ncbile hones
                                             with <%e, nose, and ttroat aerBoty irritation
                 taige vhere most persons
                                         NJtL
                                      ciliaty ettects
                                         (rats)
                                                                    t&L       IfJtL
                                                                  squamae     aqiaicus
                                                                  metaplasia   metaplasia
                                                               (cats and nonkeys)   (cats)
nutaolasia
        "oL'UJ'oU'oL'UJUJ'o^UJUJUo        ,,a
                                                                                              3.0
FK1RE 1-1, I^lationEhip between ccnoentcations ct
                                                  caLeinj asreoty irritation and cellular effects and mikstor^ exposure luvels.

-------
the degree of concern from these effects is approximated by

comparing existing exposures to lowest effect levels.  Generally,

little risk is attributed to cases where exposures are one

hundred-fold less than a no- or lowest-observed effect level.

1.4.1.1.   Sensory Irritation

     The onset of sensory irritation in humans exposed to

formaldehyde occurs over a wide range of formaldehyde

concentrations (i.e., 0.1-3.0 ppm).  This range overlaps the

expected human exposures identified in this assessment.  This

means that there is no margin between existing exposures and

levels of formaldehyde that are associated with sensory irritation

in some humans.  Thus, it would seem that some humans may be

currently experiencing some degree of sensory irritation to
                                 f
existing levels of formaldehyde in new to moderately new mobile

homes and garment manufacturing operations (see Figure l-l(a)).

Due to the large variations in human sensitivity to the irritative

effects of formaldehyde,  the prediction of response for a

population would require a characterization of both the frequency

of individual human responses and the severity of effects with

increasing exposure.  However, available data do not allow the

development of a well defined dose-response relationship for these

irritation effects.  For the exposure conditions presented in

Figure 1-1(a),  only a small percentage of persons would respond

and in all likelihood the eye irritation would be very mild and

transitory when an individual enters the home or workplace.  The

people at greatest risk of experiencing discomfort due to
                               1-21

-------
formaldehyde-induced irritation are new homeowners during the



first year of occupancy, particularly under conditions of high



temperature and humidity which are typically associated with



elevated levels of formaldehyde in these homes.




1.4.1.2. •  Cellular Effects



     Formaldehyde causes cellular changes in the upper respiratory



tract.  Studies in animals have shown that formaldehyde can



inhibit mucociliary action after only a few days of exposure, with



a NOEL of 0.5 ppm in rats.  Long-term exposure studies have shown



squamous metaplasia in the nasal cavities of rats and monkeys.



The NOEL for this effect in both species is 1.0 ppm, with  LOELs



of 2.0 ppm (rats) and 3.0 ppm (monkeys).  One study of humans



showed nasal cavity effects in some persons exposed in the range



of 0.1-1.1 ppm (Edling, -et al., 1985).



     From these values, it appears that humans and animals may



respond similarly (within a factor of 10) to the cellular effects



of formaldehyde in the nose.  Formaldehyde exposures in mobile and



conventional homes and to garment workers fall somewhat below the



NOELs and LOELs for cellular effects as determined from studies in



animals (Figure l-l(b))  Since the anticipated exposures in  the



identified populations are close to those associated with effects



in humans and animals, it is expected that home residents and



garment workers may be at some risk of experiencing these non-



cancer effects.



     Although quantitative estimates of risk are not possible, the



frequency and severity of response are dose related.  Fewer



responses are expected to be associated with less frequent and
                               1-22

-------
less intense exposure.  In addition, the cellular effects are



expected to be reversible once formaldehyde exposure is



eliminated.



1.4.2.  Cancer Dose-Response Assessment



     In principal, data from studies of humans are preferred for



making numerical risk estimates.  However, as is often the case,



the available epidemiologic data on formaldehyde were not suitable



for low dose quantitative cancer risk estimation, mainly because



of a lack of adequate exposure information in the studies.



Accordingly, results from studies in animals were used to estimate



low-dose human cancer risk.  In addition, even though the



epidemiolggic studies were not suitable for quantifying a dose-



response curve, those studies with observed statistically elevated



cancer risks provided some support for the animal-based predicted



upper bound risk.  This comparison, while yielding valuable



information to the assessment, should be viewed with caution since



exposure levels in these epidemiologic studies were subject to



some variation.



1.4.2.1.  Selection of Data



     Of the carcinogenicity studies with formaldehyde in animals,



EPA has selected the CUT study in rats as the best study for



cancer risk extrapolation.  This study was well designed, well



conducted,  included multiple doses, and used a large number of



animals per dose.



     Each of the remaining inhalation studies suffered from



various limitations which precluded their use in quantitative risk



assessment.  The CUT study in mice showed a limited tumor
                               1-23

-------
response oaly at. the highest dose of formaldehyde, while the


Albert et al.  (1982) study had only a single formaldehyde-exposed


group.  Although the Tobe et al. (1985) study contained multiple


dose groups, a tumor response was seen only at the highest dose,


and the number of animals per group was relatively small.  Lower


cancer risks than those estimated from the CUT study in rats


would have been predicted had the Agency been able to use the CUT


study in mice for risk extrapolation, while higher cancer risks


would have been estimated had the results from the Tobe et al.


(higher by a factor of ten)  or Albert et al. studies been used.


     Two types of nasal tumors were observed in the CUT study in
         ^

rats,  squamous cell carcinomas (malignant tumor) and polypoid


adenomas (benign tumor).  EPA's risk assessment relied only on the


malignant tumor data of the CUT study to predict human cancer


risks because: (1) the malignant tumor response in formaldehyde-


exposed rats was definite and unequivocal in both males and


females, whereas the frequency of benign tumors reached


statistical significance only when the incidences in males and


females were pooled; (2) the malignant tumor response in the CUT


study in rats showed an increasing dose-related trend, while the


benign tumor response showed a decreasing trend;  (3) unlike the


benign tumor response which was not confirmed by the other rat


inhalation studies, similar malignant tumor types were found both


in all rat and mouse inhalation studies with formaldehyde and in a


study of acetaldehyde, a close structural analogue of formaldehyde,


     The appearance of benign nasal tumors in rats following


inhalational exposure to formaldehyde in the CUT study
                               1-24

-------
contributes-to the qualitative weight-of-the-evidence that


formaldehyde may pose a carcinogenic hazard, but because of the


attendant uncertainties they were not included in the


quantitative estimate of human cancer risk.  Had the Agency


chosen to use the benign tumor response in the quantitative


estimation of human cancer risk, the predicted values would have


been about ten-fold greater than those reported in Section 1.4.3


using the malignant tumor response alone.


1.4.2.2.  Choice of Mathematical Extrapolation Model


     Since risks at low exposure levels cannot be measured


directly either by experiments in animals or by epidemiologic
         4

studies, a number of mathematical models have been developed to


extrapolate from results at high doses to expected responses at


low doses.   The Office of Science and Technology Policy (OSTP)


published principles on model selection which states that:


     "No single mathematical procedure is recognized as the most


     appropriate for low dose extrapolation in carcinogenesis.


     When relevant biological evidence on mechanism of action


     exists,  the models or procedures employed should be


     consistent with the evidence.  When data and information are


     limited,  however, and when much uncertainty exists regarding


     the mechanism of carcinogenic action, models or procedures


     which incorporate low dose linearity are preferred when


     compatible with the limited information."


     Data relevant to selecting a model for extrapolation of


cancer risk associated with exposure to formaldehyde were


reviewed; some of the biological information support a direct
                               1-25

-------
relationship between exposure and carcinogenicity while other

data are consistent with a non-linear response.  The Agency,

however, did not conclude that enough information was available

to propose an extrapolation model for formaldehyde that was

different from the one recommended by the OSTP and EPA's

Guidelines for Carcinogen Risk Assessment (i.e., linearized

multistage procedure).   The Agency has presented various other

models for comparative purposes.

     Biologic evidence on mechanism of action, which can aid in

model selection,  largely is inferred from a variety of types of

studies.  These are limited and suggestive of several mechanisms
         t
for formaldehyde.  Mutagenicity studies suggest a direct

relationship (i.e., a linear one) between exposure to

formaldehyde and carcinogenicity.  Thus, the ability of

formaldehyde to cause point mutations, chromosome aberrations and

DNA damage is consistent with the chemical's ability to initiate

the carcinogenic reaction.

     The steep curvilinearity of the rat nasal carcinoma dose-

response data in the CUT study in rats suggests, however, that

cancer development is greatly accentuated above certain con-

centrations.  In keeping with this observation are the results of

experiments on DNA synthesis and cell proliferation following

short-term formaldehyde exposures and the conversion of normal

mucosal cells to squamous cell epithelium (squamous metaplasia)

following longer exposures which indicate that certain toxic

effects are only noted above certain formaldehyde

concentrations.  Any relationship between cell proliferation
                               1-26

-------
following formaldehyde exposures and the carcinogenic process is


currently unknown.  Likewise, although squamous metaplasia may


represent a step in the formation of squamous cell carcinoma, its


specific role is uncertain.  No lesions that may represent stages


in a continuum between the squamous metaplasia and carcinoma were


identified in the CUT study.


     The CUT also conducted molecular dosimetry experiments


attempting to relate ambient exposures to formaldehyde with


tissue-specific levels of formaldehyde-DNA adducts.  Use of the


data generated by these experiments in risk extrapolation models


yields lower estimates of risk, sometimes significantly lower
          >

than use of the experimental doses.  The CUT data have been


reviewed by EPA scientists and a review panel of non-government


scientists to determine whether or not they should be used in the


quantitative risk assessment.  Both groups concluded that the


study had several shortcomings which preclude its use in


modifying the doses used in quantitative risk assessment, and


they provided three reasons for their conclusion.  First, the


experimental methodologies must be validated to assure that the


experimental assumptions were scientifically sound and that the


formaIdehyde-DNA-protein complexes were identified properly;


second, the single intracellular target used in the study may be


inadequate; and third, and perhaps most important, the use of an


acute exposure model in the CUT study may not be appropriate


because chronic, not acute exposure is most relevant to risk


assessment.
                               1-27

-------
     Different extrapolation models fit the observed data


reasonably well but there are large differences among them in the


risks calculated at low doses.  EPA's Guidelines for Carcinogen


Risk Assessment state, however,  that goodness of fit to the


observed tumor data by a given model is not an effective means of


discriminating among models.  In the absence of compelling


biological evidence on the mechanism of action, as in the case


for formaldehyde, EPA's guidelines specify that the linearized


multistage procedure will be used, with the possible presentation


of various other models for comparative purposes.  The analysis


showed that of the models examined, only the one-hit model
          *

produced higher risk estimates (about ten fold higher).


     Studies show that non-human primates and rats respond


similarly to formaldehyde exposure.  Accordingly, an interspecies


scaling factor was not used in the risk extrapolation.  This


position was supported by the Consensus Workshop on


Formaldehyde.  Consequently, the response of rats and humans was


judged to be the same at equivalent exposure levels and


durations.  However, if a conversion factor, such as nasal


surface area, had been used the estimated human cancer risks


would have been about an order of magnitude higher.
                               1-28

-------
1.4.3.  Numerical Risk Estimates

     The risk estimates for the linearized multistage procedure,

upper bound  (UB) and maximum likelihood estimates  (MLE)7 at

various exposure levels are presented in Table 1-2.  Risks at any

exposure level range from the upper bound to zero.  An

established procedure does not yet exist for making "most likely"

or "best" estimates of risk within the range of uncertainty

defined by the upper bound and zero.  The upper bound estimate

for excess lifetime risk of developing cancer is 3 x 10~4

[Group Bl]8 for apparel workers exposed to formaldehyde.at the

0.17 ppm level, 2 x 10   [Group Bl] for residents of mobile homes

who are exposed for 10 years to an average level of 0.10 ppm; and

1 x 10~4 [Group Bl] for residents of some conventional homes who

are exposed for 10 years to an average level of 0.07 ppm.  The

upper bound unit risk estimate for an ambient exposure of 1 ug/m^
' The shapes of most models' upper bound estimates tend to
parallel the shapes of the models themselves, unless a procedure
has been devised to provide otherwise.  This is the case for the
linearized multistage procedure, which provides a linear upper
bound estimate at low dose.  The maximum likelihood estimate
(MLE), which is the estimate given by a fitted model, takes only
the experiment to which the model has been fitted into account.
The upper bound estimate, on the other hand, is intended to
account for experiment to experiment variability as well as
extrapolation uncertainties.
° EPA's Guidelines for Carcinogen Risk Assessment recommend
categorizing chemicals in Group B (Probable Human Carcinogen)
when "the evidence of human carcinogenicity from epidemiologic
studies ranges from almost 'sufficient1 to 'inadequate.1  To
reflect this range, the category is divided into higher and lower
degrees of evidence.  Usually, category Bl is reserved for agents
for which there is at least limited evidence of carcinogenicity
to humans from epidemiologic studies."
                               1-29

-------
(0.00082 ppm) for 70 years is 1.3 x 10~5 [Group Bl].  The fitted



model gives the maximum likelihood estimate curve and, specific



to the CUT study, it has a pronounced S-shape.  By contrast, as



the linearized multistage procedure's upper bound estimate is



traced toward lower doses, its linear nature accomodates



increasing variability and extrapolation uncertainty.  Both



estimates are shown in Table 1-2 to illustrate how the



perspectives they give on risk differ.  Thus at 3 ppm (which is



in the experimental range), the difference between the MLE and



the UB is ten-fold, whereas at about one-tenth of that exposure,



a 100,000 fold difference is generated.



     The lower bound on risk is always recognized to be as low as



zero.  The upper bound estimate is ordinarily shown to allow for



extrapolation uncertainty.  It is for this reason, along with



adherance to EPA's Guidelines for Carcinogen Risk Assessment,



that the upper bound was selected to represent potential human



risk.  While some of the existing information on formaldehyde is



consistent with non-linear interpretations, some support for a



linearized upper bound comes from the epidemiologic studies.  The



excess cancer incidences observed in the epidemiologic studies



are about the same as the upper bound on lifetime risk based on



the rat nasal carcinoma data.
                               1-30

-------
                               TABLE 1-2


     SUMMARY OF CANCER RISKS ASSOCIATED WITH FORMALDEHYDE EXPOSURE
    Population Segement
     (Exposure Level)
     Lifetime
  Individual Risk
  Current OSHA std. (3 ppm)
UBb   6 x 10'3, [B1J
MLEC  6 x 10"4 [81]
  Garment Workers

    NIOSH
   (0.17 ppm)
UB  3 x 10"* [Bl]
MLE 4 x 10"9 [Bl]
       Mobile Home
       Residents
  (0.10 ppm 10-yr average)
UB-   2 x 10~   [Bl]
MLE 2 x 10"10 [Bl]
  Conventional Home*
     Residents
  (0.07 10-year average)
UB  1 x 10"4 [Bl]
MLE 6 x 10"11 [Bl]
  Home/Environment
    Background Upper Limit
    (0.05 ppm)

       10 yr.
       70 yr,
UB  7.0 x 10"f [Bl]
MLE 1.0 x 10"11 [Bl]
                                               "*
[Bl]
UB  5.0 X 10
MLE 1.0 x 10"10 [Bl]
*  For homes containing substantial amounts of urea-formaldehyde
   pressed wood (e.g./ floor  underlayment and/or paneling)

b  upper Bound

°  Maximum Likelihood Estimate

d  Airborne Unit Risk, 1 ug/m3 - 70 yrs; Lifetime individual risk,
   UB = 1.3 x 10~5  [Bl]
                              1-.11

-------
                         2.   BACKGROUND



     In November 1979, EPA received information that the interim



results of a 24-month bioassay in rats conducted by CUT showed



that a number of the rats had developed nasal cancer after



inhalation of HCHO.



     In November of 1980, the Federal Panel on Formaldehyde,



formed by several Federal agencies under the aegis of the



National Toxicology Program, published a report finding that



CIIT's bioassay methodology was consistent with accepted testing



standards.  Using the data available through the 18-month point



of the CUT study, the Federal Panel concluded that "formaldehyde



should be presumed to pose a risk of cancer to humans."  Also- in



November 1980, CUT presented the preliminary results of the full



study.  CUT pathologists reported finding statistically



significant increases, as compared with controls, in the



incidence of malignant tumors in rats exposed to HCHO vapor at



the highest of the three levels they tested (14.3 ppm).



     In February 1982, based on its evaluation of the toxicity



and exposure data on HCHO then available,  EPA decided that,



although HCHO had been found to be carcinogenic under the



conditions of the test, the available information as to HCHO's



cancer risk to humans did not meet the statutory criteria for



priority designation under section 4(f) of TSCA.



     To assist its evaluation of HCHO the Agency funded the



National Center for Toxicological Research to sponsor a Consensus



Workshop on Formaldehyde (the Workshop).  The Workshop was held
                               2-1

-------
in Little Rock, Arkansas from October 3 through 6,  1983.   Overj  D



government, industry,'university, and public interest



organization scientists served on the following eight Panels:



(1) Exposure; (2) Epidemiology; (3) Carcinogenicity/



Histopathology/Genotoxicity; (4) Immunology/Sensitization/



Irritation; (5) Structure Activity/Biochemistry/Metabolism;



(6) Reproduction/Teratology; (7) Behavior/Neurotoxicity/



Psychological Effects;  and (8) Risk Estimation.  Each Panel



(except the Risk Estimation Panel) was charged with the task of



reviewing the major scientific studies relevant to that Panel's



area.  The Panel members were also asked to address a number of



discussion topics and prepare a consensus report addressing those



topics.



     When the Panel deliberations were finished, draft reports



were provided to the Risk Estimation Panel.  The Risk Estimation



Panel was charged with the task of determining how the data could



be assessed to make reasonable risk estimates for humans exposed



to HCHO at various levels and through different routes.



     The decision process of the February 1982 decision under



section 4(f) of TSCA generated considerable controversy and



formed the basis for a lawsuit by the Natural Resources Defense



Council (NRDC) and the American Public Health Association (APHA)



(NRDC v. Ruckelshaus, No. 83-2039, filed in the United States



District Court for the District of Columbia, July 18, 1983).



     In view of public controversy concerning the process and



policy issues associated with the Agency's section 4(f) decision
                               2-2

-------
on  the cancer hazard of HCHO, EPA announced  in  the  FEDERAL



REGISTER of November 18,  1983 (48 FR 52507)  its decision to



rescind its February 1982 decision, and  to ask  the  public to



submit views, arguments,  and data relevant to determining whether



HCHO should be given priority consideration  under section 4(f) of



TSCA.  Comments were due  at EPA by January 17,  1984; EPA



announced that it expected to reach a new decision  by May 18,



1984.



     On May 23, 1984 EPA  announced in the Federal Register (49 FR



21898) that two HCHO exposure categories triggered  section 4(f)



of TSCA (possible widespread cancer risk).   The exposures which



led to the decision are those associated with manufacture of



apparel from fabrics treated with HCHO-based resins and residence



in conventional and manufactured homes containing construction



materials in which certain HCHO-based resins are used.



     In addition to HCHO's potential cancer  risks,  HCHO's other



effects should be considered in any action to reduce health



effects from HCHO.  The assessment of the risks from acute



respiratory effects was prepared to be considered along with the



carcinogenic risk assessment in the overall  investigation of



HCHO.  The hazard discussion of noncarcinogenic effects in the



risk assessment is based in part on reports  from the Consensus



Workshop on Formaldehyde, a report of the Cosmetic  Ingredient



Review Expert Panel, a hazard assessment by  Ulsamer et al.



(1984), and the National Research Council report titled HCHO and




other Aldehydes prepared under contract to EPA.  The risk
                               2-3

-------
assessment focuses on the possibility of determining a dose-



response for these noncancer effects because while many of the



effects are well documented, the dose-response patterns in the



human population are not.  Methods used by HUD and OSHA to relate




the proportion of the human population responding at particular



exposure levels have been analyzed.   In addition, EPA has



reviewed selected human studies to determine if dose-response



relationships can be described.
                               2-4

-------
                 3.   PHYSICAL-CHEMICAL PROPERTIES

     HCHO is the simplest member of.  the aldehyde  chemical

category.  It exists in many different  forms.   Both  liquid  a-t-i

gaseous HCHO polymerize readily at ordinary  temperatures and  can

bo kept in pure monomeric state only  for a limited time.   Pure

monomeric HCHO is a colorless, pungent gas.  Agueous  HCHO,  called

formalin, is a clear/ colorless solution containing  about  37

percent by weight of dissolved HCHO  in water (room temperature),

usually with 6 to 15 percent methanol added  to  prevent

polymerization.  Solutions containing over 30 percent by weight

become cloudy on standing and precipitate polymer at  ordinary

temperatures.  Concentrated  liquid HCHO-water systems containing

up to around 95 percent HCHO are obtainable, but  the  temperature

necessary to maintain solution clarity and -irevent separation of

solid polymer increases from around  room t-e-iperature  to  120°C as

the solution concentration is increased.  !"••>.e other  forms  of  HCHO

are polymers, the best known of which are para-HCHO  and  trioxane

(trioxymethylene).  HCHO is sold and  transported  only in solution

or in the polymerized state.

     The molecular weight of HCHO is  30.  It has  the  followinq

structural formula:

                         0
                         II
                       H-C-H
                                3-1

-------
     The chemical name used by Chemical Abstracts  Service  is



HCHO, and its Chemical Abstract number is  50-00-0.   Synonyms*



include HCHO; HCHO qas; HCHO solution; formalin;  formalin  40;



formalin 100%;  formic aldehyde; methaldehyde; methanal; methyl




aldehyde; methylene glycol; methylene oxide; oxomethane;



oxymethylene; paraform; oara-HCHO; polyoxymethvlene  qlycols;



 0(-polyoxymethylene; fl -polyoxymethylene; tetraoxymethylene;



 ai. -tr ioxane ; trioxane; and c(-tr ioxymethylene .



     Dry HCHO qas condenses on chillinq to qive a  liquid that



boils at -19°C and freezes to a crystalline solid  at -188C.



Vapor pressure  is 400 mn at -33°C.  HCHO qas is flammable  havinq



a heat of combustion of 4.47 kcal per qram.  It forms explosive



mixtures with air and oxygen.  At atmospheric pressure,



flammability is reported to ranqe from 12." to 80  volume oercent,



HCHO-air mixtures containinq 65 to 70 Derc--,t beinq  the most



readily flammable.  HCHO is soluble in wat~r, acetone, benzene,



diethyl ether, chloroform and ethanol (IARC, 1982).  Solutions



obtained with the nonpolar solvents are somewhat more stable but



also precipate polymer on storage.  HCHO solutions have a



definite flash point which is lowered by the oresence of



methanol.  The flash point of commercial HCHO 37.5%  solution with



14.0% methanol (by weight) is 56°C (132°F).  In view of their



unique nature, it is recommended that flash ooint  values for HCHO



solutions be regarded as approximations and that the solutions be



regarded as potentially flammable at least 10°F below the




reported figures.





*Includes synonyms for polymeric forms of  HCHO.





                               3-2

-------
     The partial pressure of  HCHO vanor over commercial solutions




is  also increased by methanol.   The partial  pressure of HCHO over



37 percent solution containing  9 percent methanol is 4.2 mm at



35°C, whereas a 37 percent solution containina 1 percent methanol




has a partial pressure ot 2.7 mm under the same conditions




(Walker, 1975).
                                3-3

-------
                4.   HAZARD OP CARCINOGENIC EFFECTS
4.1.   Long- and short-term Animal Tests
     The first long-term study reporting  the carcinogenicity of
HCHO in animals by the inhalation route was one by Kerns et al.
(1983) (CIIT-sponsored study performed at Battelle Columbus
Laboratories) which reported statistically significant increased
levels of squamous cell carcinomas in the nasal cavities of rats
at 14.3 parts per million (ppm).  In the study, groups of
approximately 120 male and 120 female Fischer 344 strain *rats and
C57BL/6 X C3HFj strain mice, were exposed by inhalation to 0,
2.0, 5.6, or 14.3 ppm of HCHO gas for 6 hours per day, 5 days per
week, for 24 months.  The exposure oeriod was followed by up to
six months of nonexposure.  Interim sacrifices were conducted at
6, 12,  18, 24, 27 and 30 months.  All major tissues from each
organ system (approximtely 50 tissues/animal) in the control and
high exposure groups were examined histologically.  Sguamous cell
carcinomas were observed in the nasal cavities of 103 rats (52
females and 51 males) and 2 male mice exposed to 14.3 ppm of HCHO
and in 2 rats (one male and one female) exposed to 5.6 ppm of
HCHO gas.  The first tumor clinically observed in female rats of
the 14.3 ppm group was at 358 days past first exposure and 432
days for males.  The adjusted cumulative  incidence rate (Kaplan-
Meier life table analysis) of squamous cell carcinomas in -nale
and female rats of the 14.3 ppm exposure group at 24 months was
67 and 87%, respectively.  Tumors in male mice were discovered at
the 24-month sacrifice.  The incidence of nasal carcinomas in
rats showed a dose-response relationship.  See Table 4-1 for a
summary of tumor response in rats.
                               4-1

-------
                                                                 Table 4-1.
                      9MMKT Of NBQPIAST1C UNIONS IN TOE NASAL CAVITY Of FISCHER 344 RATS EXFOSO) TO KXMAUEHYIE GAS*
Formaldehyde
(ppm)
0
2.0
5.6
14.3
Sex
H
F
N
F
N
F
H
f
tto. of nasal
cavities
evaluated
118
114
118
118
119
116
117
115
Squanous cell
carcinoma
0
0
0
0
1
1
51
52
ftiorly
Differentiated
carcinoma
0
0
0
0
0
0
0
1
Adeno-
carcinona
0
0
0
b
0
0
1
0
Undi f f erent iated
carcinoma or
sarcoma
0
0
0
0
0
0
2*
0
Carci no-
sarcoma
0
0
0
0
0
0
1
0
Iblypoid
adenoma
1
0
4
4
5
0
2
0
Cfetao-
chondrau
1
0
0
0
0
0
0
0
I
K)
*Table adapted from Kerns et al.  (1983)

a A rat in this group also  had a  squamous cell carcinoma.

-------
     Although  the  two squamous carcinomas  in mice at  14 ppm were



not statistically  significant in comparison with the  incidence in



control mice in  the study, the finding suggests that  the effect



is related to  HCHO exposure because the natural background rate



for such nasal cancers  is very low  in this strain of  mice, with



only one neuroepithelioma and one angiosarcoma having been



reported by Stewart et  al., 1979 (Kerns et al., 1983).



     The difference in  susceptibility of rats and mice may be



due, in part,  to a greater reduction in respiratory minute volume



in mice than in rats during exposure to an irritating agent.  In



a study by Chang et al. (1983) changes in minute volume, nasal



cavity disposition, and cell proliferation were examined.  It was



found that mice exposed to 15 ppm HCHO for 6 hours experienced an



approximately  50%  reduction in minute volume whereas  rats



exhibited at 20% decrease.  If a "dose" of HCHO is calculated



from adjusting for reduction in minute volume and other data, it



can be seen that for mice the dose  received at 14.3 ppm in the



Kerns et al. (1983) study is one-half that received by rats at



14.3 ppm (see  also Swenberg et al., 1983).  Thus, the tumor



response in mice at 14.3 ppm is comparable to the response in



rats at 5.6 ppm.   Interestingly, mice and rats at these exposures



showed nearly  identical tumor responses, i.e., two squamous cell



carcinomas out of  approximately 240 mice and rats.



     In addition to the squamous cell carcinomas, small numbers



of benign tumors characterized as polypoid adenomas were observed



in rats at each dose level.  These  benign tumors exhibited a
                               4-3

-------
dose-response relationship with a negative trend.  However,



because this type of benign nasal tumor is rare  in control rats



it  is  likely related to HCHO exposure.  For a  further discussion



of  these lesions and their use in this risk assessment see Data



Selection for Quantitative Analysis after this section.



     Significant squamous metaplasia was also observed.  See



Figure 4-1 for frequency and locations (also see Figure 4-3).  In



rats at 2.0 ppm, purulent rhinitis, epithelial dysplasia, and



squamous metaplasia were present in the anterior portion of the



turbinates (Level I) at 12 months.  The frequency of metaplasia



increased up to 24 months and then decreased significantly



(p<0.05) at 27 months (three months post exposure).  In the 5.6



ppm group, purulent rhinitis, epithelial dysplasia, and squamous



metaplasia were observed in the anterior and middle portions of



the nasal cavity (Levels I, II, and III).  Siqnificant (p<0.05)



regression of squamous metaplasia was noted at 27 months (post



exposure).  Similar but more severe and extensive lesions were



observed in the 14.3 ppm exposure group in all regions of the



nasal cavity.  Significant regression of squamous metaplasia was



only observed in the posterior portion of the nasal cavity



(Levels IV and V).  In all exposure groups, epithelial dysplasia



was detected earlier than squamous metaplasia.
                               4-4

-------
Figure 4-1.  Frequency of squamous metaplasia in the nasal
cavity of Fischer 344 rats exposed to 2.0 ppm (top), 5.6
ppm (middle), or 14.3 ppm (bottom), of formaldehyde yas for
24 months.  Nasal cavity Levels I, II, IV, and V were not
evaluated at the 6- and 12-month interim sacrifices in the
14.3 ppm exposure group.  Figure taken from Kerns et al.
(1983).
                           4-5

-------
     Inflammatory A dysplastic, and squamous metaplastic alterations



of the respiratory epithelium of mice were observed.  These



lesions were most severe in the 14.3 ppm exposure group (see



Figure 4-2).  .\ few mice in the 5.6 ppm group had dysplastic



changes'with serous rhinitis at 18 months in Level  II.  By 24



months, a majority (<90%) of mice in the 14.3 ppm group had



dysplastic and metaplastic changes that were associated with



seropurulent rhinitis.  At that time period, only a few mice in



the 5.6 ppm exposure group had dysplasia, metaplasis or serous



rhinitis in Level II.   Mice in the 2.0 ppm group were generally



free of significant lesions with only a few animals with serous



rhinitis at 24 months.



     One complication noticed during the Kerns et al. (1983)



study was a spontaneous outbreak in rats of sialodacryeo-



adenitis.  The evidence for this consisted of (a) decreased body



weight in all dosed and control rat groups at about the 52nd week



of the experiment/ followed by prompt recovery of body weight;



and (b) histopathologic demonstration of typical lesions in



lacrimal and salivary glands of dosed and control rats in the



12-month sacrifice groups.  Evidence of sialodacryeoadenitis was



not found in rats sacrificed at 6 or 18 months or in those with



unscheduled deaths.  Virus isolation, viral antigen



demonstration, and serologic tests for.antibodies were not



attempted in rats or mice.
                               4-6

-------
     Figure 4-2.  Frequency of squamous metaplasia in the nasal
     cavity of B6C3F] mice exposed to 14.3 ppm of formaldehyde
     gas.  Figure taken from Kerns et al. (1983).


     With regard to HCHO in the exposure chamber in the Kerns

study, a panel of experts reviewed the method of generation of

HCHO and monitoring and agreed that "the Battelle approach to

HCHO vapor generation (heating paraformaldehyde) was a suitable

adaptation of accepted methods and principles and, therefore, was

sound and based upon the best available technology.  The same

type of assessment applied to the chamber air monitoring system,

which also combined two well established procedures" (Gralla et

al., 1980).

     Other studies support the results of the Kerns (CIIT)

study.  In two studies reported by Albert et al. (1982) (comolete

results for one study and preliminary results for the other),

rats were exposed for life by inhalation to HCHO alone, mixtures

of hydrochloric acid (HCL) and HCHO, or HCL alone.

     In the first study, 99 male Sprague-Dawley rats were exposed

to a mixture of HC1 and HCHO (premixed at high concentrations


                               4-7

-------
before introduction into the exposure chamber to maximize the



production of bis(chloromethyl) ether (BCME)).  This was done



because the investigators were studying the hazard associated



with the use of HC1 and HCHO in close proximity in the



workplace.  A report had suggested the production of BCME from



mixing HCL and HCHO gas.  The average concentrations were 10.6



ppm HCL, 14.7 ppm HCHO, and about 1 part per billion (ppb)



BCME.  Of the 99 animals exposed to the test mixture, 25



developed squamous cell carcinomas of the nose.  The contribution



by the BCME was thought to be minimal because the expected



response to 1 ppb of BCME was estimated to be less than 1.5



percent (based on authors' comparison of 20 exposure days at 100



ppb of BCME with 500 exposure days at 1 ppb of BCME) and there



was a 25 percent incidence of nasal tumors in the study.  In



addition, BCME normally produces neurogenic carcinomas (mainly



esthesioneuroepitheliomas), none of which were seen in the



study.  The uncertainty of comparing different factors involved



in dose-rate versus total delivered dose in tumore induction is



not resolved, however.



     The second Albert et al. (1982) study, in which male



Sprague-Dawley rats (100 per oroup) were exposed to HCL alone



(10.2 ppm), premixed HCL-HCHO mixture (14.3 ppm HCHO/10.0 ppm



HCL), nonpremixed HCHO-HCL mixture (14.1 ppm HCHO/9.5 ppm HCL),



or HCHO alone (14.2 ppm), showed statistically significant



numbers of squamous cell carcinomas of the nasal cavity in the



rats exposed to HCHO alone and the HCL-HCHO mixtures.  A control
                               4-8

-------
group of  100 rats was used.  No nasal cancers were seen in the
HCL-only  exposed rats or in the controls.  Also, it appeared that
the  irritant HCL gas did not enhance the carcinogenic response of
HCHO because the frequency of tumors was similar in the HCHO
alone and HCHO-HCL groups.  Table 4-2 displays final results of
the study (Sellakumar, 1985).  Work by Swenberg et al. (1984) in
which Sprague-Dawley and Fischer 344 rats were exposed to 0, 10,
20 or 50 ppm of HCL gas for 6 hours per day, 5 days per week, for
up to 90 days, indicates that HCL may be considerably less
irritating to the uoper respiratory tract of rats than HCHO.  For
those rats exposed for four days and killed 18 hours later, only
the 50 ppm group had significant HCL-induced lesions, consisting
of focal degeneration, epithelial hyperplasia, and early sguamous
metaplasia on the dorsal tip of the maxilloturbinate of the most
anterior section.  Since maximum nasal irritation in rats from
HCHO occurs within a few days after exposure begins, the lack of
significant nasal.irritation from HCL in the 10 and 20 ppm groups
indicates that HCL in the Albert study was not sufficiently
irritating to draw conclusions regarding the role of irritation
in HCHO-related carcinogenesis.
     In a study reported by Tobe et al. (1985), groups of 32 male
Fischer 344 rats were exposed to HCHO for 6 hours per day, 5 days
per week, for 28 months.  The five test groups were as follows:
colony control, room control, 0.3, 2.0, and 15 ppm HCHO.  The
significant finding was sguamous cell carcinoma (14 cases) and
papilloma (5 cases) in the 15.0 ppm group.  No tumors were
                               4-9

-------
                                                         Table 4-2.
                          SUMARY CF NEOPLASTie LESIONS  IN THE NASAL CAVITY GP SPRAGUE-CAWLEY RATS*
Air controls
(99 rats)
Squamous cell carcinoma 0
Pap i llama or polyps 0
i
o
Fibrosarcona 0
Adenocarcinana 0
Esthesioneuroepitheliama 0
Colony
controls
(99 rats)
0
0

0
0
0
10 ppm HCL 14 ppm HCHO
(99 rats) (100 rats)
0 38
0 10

0 1
0 0
0 0
PremixecJ 14 ppm
HCHO & 10 ppm
HCL (100 rats)
45
13

1
1
1
Nan-premixed 14 p|*n
HCHO & 10 ppm HCL
(100 rats)
27
10

0
2
0
*Fron Sellakurar (1985)

-------
observed  in the 0.3 and 2.0 ppm groups.  Rhinitis, squamous
metaplasia and hyperplasia of the nasal respiratory epithelium
were observed in all HCHO exposed groups.
     It should be noted that while the carcinoma response was
similar between the Kerns, Albert and Tobe studies, the benign
tumor response was markedly different.  In the Kerns study only
benign polypoid adenomas were observed, whereas in the Albert and
Tobe studies benign papillomas were observed.  The basis for
these differences is difficult to explain.   It could represent a
strain difference or some unknown factor.  (Tobe used the same
strain of rats as Kerns, Fischer 344, but the small number used
at each dose as compared to Kerns (32 vs. 240) may explain the
failure of polypoid adenomas to be detected.)  Consequently,
statements about the significance of' these lesions in discussions
of human risk must be approached with caution.
     Two other chronic inhalation studies with HCHO designed to
investigate possible cocarcinogenic effects of this agent in the
upper and lower airways have been reported (Horton et al., 1963,
and Dalbey et al., 1982).  Since the nasal tissues were not
systematically examined histologically, the value of these
studies in assessing the carcinogenicity of HCHO is accordingly
limited.  In spite of these reservations, the studies have some
bearing on HCHO carcinogenicity.
     In the study reported by Horton et al.  (1963), C3H mice were
exposed to coal tar aerosol and/or to HCHO at concentrations of
40, 80, 160 ppm.  Exposures were carried out  for 1 hr/day, 3
                               4-11

-------
days/week for 35 weeks, except for the 160 ppm group which was



exposed only for 4 weeks because of toxicity.  Only 15 mice



survived to 1 year.  There is no mention of histopathological



evaluation of nasal tissues,  so presumably no grossly visible



tumors were observed.  Coal tar aerosol exposure resulted in lung



tumor formation in 5 animals (1 invasive carcinoma), but HCHO



exposure did not.  No evidence was found for any cocarcinogenic



effects of HCHO.  The major shortcomings of this study for



evaluating the carcinogenicity of HCHO are that too few animals



survived past one year, the individual exposures were short, most



groups were exposed only for 35 weeks, and complete



histopathology of nasal tissues was not reported.



     In a study by Dalbey (1982) male Syrian golden hamsters were



used to study the chronic effect of HCHO and diethylnitrosamine



(DEN).  In the first part of the study, 88 hamsters were exposed



to 10 ppm HCHO,  5 times/week .for life.  There were 132 untreated



controls.  The second part of the study examined HCHO's



promotional potential.  For the second part of the study the



hamsters were divided into 5 groups:  50 untreated controls; 50



hamsters exposed to 30 ppm HCHO, 5 hrs/day, 1 day/week for life;



and 3 groups receiving DEN injections of DEN (0.5 mg, once per



week for 10 weeks).  Of the three groups receiving DEN, one



consisted of 100 hamsters receiving only DEN, a second group of



50 hamsters were exposed to 50 ppm (5 hrs) of HCHO 48 hours prior



to each injection of DEN, and the third group was exposed to 30



ppm HCHO (5 hrs/day, 5 days/week) for life, beginning 2 weeks



after the last DEN injection.
                               4-12

-------
      In  the hamsters exposed  to  10 ppm HCHO for  life  there was no



evidence of carcinogenic activity/ but survival  time  was reduced



(p<0.05) relative to controls.   Toxic effects of HCHO in the



nasal cavity were limited to  hyperplastic and metaplastic areas



in  5% of the hamsters.  No hyperplasia or metaplasia  was observed



in  the controls.  The incidence  of rhinitis was similar in both



control and exposed hamsters, and was not considered  to be



related to exposure of HCHO.



     Caution must be exercised when comparing this part of the



Dalbey (1982) study with the  Kerns et al. (1983) study.  One



factor that should be considered is that the pathology evaluation



in the Dalbey (1982) study was less rigorous.  Only 2 sections of



the nasal turbinates were examined as compared to sections taken



from 5 anatomical levels of the  nasal cavity of  rats  in the Kerns



et al. (1983) study.



     Also, the Kerns et al. (1983) study used three HCHO exoosure



levels (  2.0, 5.6, and 14.3 ppm) whereas only 10 ppm of HCHO was



used in the Dalbey (1982) study.  If one compares the ppm-hrs/week



received  by rats at 5.6 ppm in the Kerns study and hamsters at 10



ppm, one sees that the ppm-hrs/week for the hamster is equivalent to



a  hypothetical dosing regimen of 8.3 ppm for rats (5.6 ppm X 6



hr/days X 5 days = 168 ppm-hrs/week vs. 10 ppm X 5 hr/days X 5



days = 250 ppm-hrs/week; this is equivalent to 250 ppm-hrs/wk * 6



hr/day X 5 d/wk =8.3 ppm).   Since only two squamous  cell



carcinomas were seen in the Kerns et al. (1983)  study out of 240



rats at 5.6 ppm, the likelihood  of detecting a tumor  in the
                               4-13

-------
Dalbey (1983) study, which used 88 hamsters, is poor.  in fact,



there is a 30% probability that the absence of tumors is due to



chance.



     Finally, it is well established  (Kane et al., 1979 and



Buckley et al., 1984) that many sensory irritants decrease the



respiratory rate of exposed animals.  For rats the RD50



(concentration required to reduce respiratory rate by 50%) for



HCHO is approximately 32 ppm and for mice it is 3.1 ppm.  If one



assumes that a HCHO-related sensory irritant response is found in



hamsters (little data have been developed on the  hamster in this



regard)  (see Alarie, 1985), it is possible that the hamsters in



the Dalbey (1982) study reduced their respiratory rate, which



would further lessen the dose to target tissue.



     Although an RD50 value for HCHO has not been reported for



hamsters,  a study by Feron et al. (1978) comparing the responses



of hamsters, rats,  and rabbits to .acrolein vapor  indicates that



hamsters may resemble mice more in their respiratory response to



HCHO than rats.  The hamsters were slightly affected (nasal



cavity lesions) at  1.4 ppm and severely affectd at 4.9 ppm by the



acrolein.   In contrast/ rats were slightly affected at 0.4 ppm



and were more severely affected at 1.4 and 4.9 ppm.  This



response is similar to the difference in response (nonneoplastic



lesions) between rats and mice in the Kerns et al. (1983) study



where rats were affected at all dose  levels whereas mice, because



of a lower RD50 value for HCHO, were affected only slightly at



5.6 ppm and more seriously at 14.3 ppm.  However, in studies by
                               4-14

-------
Kendrick et-al.  (1976) and Rubin et al. (1978) in which the



effects of tobacco smoke inhalation were investigated for rats



and hamsters, it was found that at least for tobacco smoke, rats



and hamsters had similar reductions in breathing rate and minute



volume and in the amount of particulate matter retained in the



test animals.  Consequently, conclusions regarding the comparison



of HCHO-induced respiratory changes in rats and hamsters must



await further research.



     In the second part of the Dalbey  (1982) study no tumors were



observed in untreated hamsters or those hamsters receiving only



HCHO.  However, 77% of the DEN-treated controls had a tumor



(adenomas) at ten or more sites in the respiratory tract.



Although HCHO exposure concurrent with, or after, DEN treatment



did not increase the number of tumor-bearing animals (TBA), the



number of tumors per animal (tracheal  tumors) was nearly doubled



over DEN-only controls when HCHO was administered 2 days prior to



each of 10 weekly DEN treatments, whereas post-HCHO treatment had



no measurable effect.  Thus, under conditions of the test, HCHO



was a cofactor in chemical carcinogenesis.   However, there was a



corresponding decrease in lung tumors  in hamsters exposed to both



agents; this suggests that the effect  on the trachea may be



within the limits of experimental variability (Consensus Workshop



on Formaldehyde, 1984).  In addition,  survival in the HCHO-DEN



groups was poor, which further complicates  the findings of this



part of the Dalbey study.
                               4-15

-------
     In a study by Rusch et al. (1983), groups of 6 male



Cynomologus monkeys, 20 male and 20 female Fischer 344 rats, and



10 male and 10 female Syrian golden hamsters were exposed to 0,



0.20, 1.0 and 3.0 ppm HCHO for 22 hrs/day, 7 days/week, for 26



weeks.  The most significant finding was squamous metaplasia/



hyperplasia in rats and monkeys at 3.0 ppm; little or no response



was seen at the lower exposure levels.  Hamsters did not show any



significant responses at any exposure level.   The results from



this study indicate that concentration may be more important than



total dose if squamous metaplasia/hyperplasia is the response



measured, when the results are comoared to those of the Kerns et



al. (1983) study.   In the Kerns study, squamous metaplasia was



found in rats in the 2.0 ppm exposure group during the course of



the exposure (2.0 ppm 6 hr/day, 7 days/week,  for life).  However,



in the Rusch et al. (1983) study rats exposed to 1.0 pom HCHO had



no squamous metaplasia, even though they received a total dose



2.5 times that received by the rats at 2.0 ppm in the Kerns et



al. (1983) study.   This study design was unlikely to show any



neoplastic response because of its small number of animals and



short duration.



     The carcinogenicity of HCHO also has been tested by a



variety of other routes of administration including subcutaneous



injection in rats (Watanabe et al. 1954, 1955), ingestion by mice



and rats (Delia Porta et al. 1968, 1970), and application to the



buccal mucosa in rabbits (Meuller et al., 1978).  Because of the



experimental protocols used, none of these studies permits firm
                               4-16

-------
conclusions  regarding HCHO carcinogenicity.  Nonetheless, some of
the studies  give definite clues that HCHO may be carcinogenic to
a variety of target tissues as well as  to a variety of animal
species  (and not only to the nasal epithelium of rats).
     In  one  experiment, Meuller et al.  (1978), applied a solution
of 3% formalin to the oral mucosa of rabbits, using an "oral
tank."   Each exposure lasted for 90 minutes and was repeated 5
times per week for a period of 10 months.  As a result, 2 out of
6 rabbits developed grossly visible leukoplakias that, according
to the authors, showed histological features of carcinoma in
situ.  Unfortunately, the information given on the
histomorphology of the lesions is very  scanty.
     Other experiments which suggest that HCHO produces
carcinogenic effects are those by Watanabe et al.  (1954, 1955),
who injected rats (strain unknown) subcutaneously with formalin
and with hexamethylenetetramine (HMT, from which HCHO is
liberated in vivo) and produced injection-site sarcomas.
     However, several other studies carried out with HMT by
Brendel  (1964) who administered HMT by  gavage to rats and Delia
Porta et al. (1968, 1970) who administered HMT in drinking water
to mice and  rats, resulted in negative  findings.  The
significance of these finding must be tempered by the fact that
chemicals often give disparate results  by different routes of
exposure.  For example, hexamethylphosphoramide (HMPA) is a
potent nasal carcinogen by inhalation,  but was not carcinogenic
in rats fed  HMPA for 2 years (Lee and Trochimowicz, 1984).
                               4-17

-------
     A study by Klenitzky (1940) in which "formol oil" was



applied 50 times to the cervix uteri of mice resulted in no



tumors.



     Finally, a study by Spangler and Ward  (1983) has been



interpreted as showing weak promoting activity of HCHO:acetone



solutions on Sencar mouse skin.  However, in another study by



Krivanek et al. (1983) on CD-I mice, no promotion was observed



when nonirritating applications of HCHOracetone solutions were



used (Consensus Workshop on Formaldehyde, 1984).



4.2.   Data Selection for Quantitative Analysis



     As discussed above, there are a number of studies available



which indicate the carcinogenic potential of HCHO.  For the



purpose of Quantitative Risk Assessment, the Agency generally



chooses a well-designed and conducted study that uses the most



sensitive species of animal (EPA, 1986).



     In the case of HCHO, the Kerns et al.  (1983) study (CUT



study)fits these criteria.  This study has  been reviewed by a



number of panels (IRMC, 1984; Consensus Workshop on Formaldehyde,



1984) and has been found to be of sufficient quality for risk



estimation purposes.  The selection of the  Kerns et al. (1983)



study is consistent with EPA's Carcinogen Risk Assessment



Guidelines (EPA, 1986).  Since squamous cell carcinomas were the



only statistically significant malignant tumors observed in the



study,  they are the primary end point used  for quantitative risk



assessment.  A small number of benign tumors, were also



observed.  The Guidelines state that benign tumors should be
                               4-18

-------
combined with malignant  tumors  for  risk  estimation  unless  the
benign tumors are not considered  to have  the  potential  to
progress to  the associated malignancies.  The  following discusion
explores this question.
4.2.1.   Polypoid Adenomas/Other  Tumors  Observed
      In the  Kerns et al.  (1983) study, a  small number of polypoid
adenomas were reported in the rats: 1, 8, 6, and 5  adenomas in
the 0, 2.0,  5.6, and 14.3 ppm groups, respectively.  Because a
number of questions were  raised about the accuracy  of the
diagnosis of these lesions, they  were reexamined by a pathology
working group (PWG) (Boorman, 1984; Consensus Workshop, 1984).
The results  of the PWG reexamination are  as follows:  1, 8, 5,
and 2 adenomas in the 0,  2.0, 5.6, and 14.3 ppm groups,
respectively.  However,  two adenomas diagnosed at 2.0 ppm  and one
at 5.6 ppm were borderline calls  between  focal hyperplasia and
small benign tumors.  See Table 4-3 for  a breakdown by dose and
sex.   In addition, two lesions originally diagnosed as nasal
carcinomas were rediagnosed as adenocarcinoma and poorly
differentiated carcinoma  which were thought to be morphologically
related.  This has relevance to the following discussion of the
potential of polypoid adenomas to progress to a cancer.
     The PWG was asked to speculate about the possible
progression of the polypoid adenomas.  The consensus of the PWG
was that there was no evidence that polypoid adenomas progressed
to squamous cell carcinomas and that they should not be combined
with squamous cell carcinomas for statistical purposes  (Boorman,
1984).  This recommendation was accepted  by the Risk Estimation
                               4-19

-------
                            Table 4-3.

                 INCIDENCE OP POLYPOID ADENOMA AS

                         REPORTED BY PWG




                          DOSE (ppm)                  Statistically

Sex              _0	2.0	5.6   14. 3    Total    Significant3



 M                1      4*      5**    2       12           No

Nasal cavities

 evaluated***   (118)  (118)  (119)  (117)




 F                04004           No

Nasal cavities

 evaluated      (114)  (118)  (116)  (115)



Combined          1      8       5      2       16     Yes at 2.0 ppm

Nasal cavities

 evaluated      (232)  (236)  (235)  (232)
aOne tailed Fisher exact test.  Significance determined for each
 dose level.

*Two tumors in this grouo were judged to be borderline
 lesions between small benign tumor and focal hyperplasia.

**0ne tumor in this group was judged to be a borderline
  lesion between small benign tumor and focal hyperplasia.

***From Kerns et al. 1983.
                               4-20

-------
Panel of the Consensus Workshop on Formaldehyde (1984).  In
addition, an analysis of the localization of the tumors observed
in the Kerns study by Morgan et al. (1985) revealed that the
squamous cell carcinomas generally occurred on the anterior
portion of the lateral aspect of the nasoturbinate and adjacent
lateral wall (57%) or the mid-neutral nasal septum (26%).  In
contrast, the polypoid adenomas were confined to a small area of
the anterior nasal cavity and were restricted to the margins of
the naso- and maxilloturbinates and lateral wall adjacent to
these margins.  Consequently, it appears unlikely that polypoid
adenomas represent the benign counterpart of squamous cell
carcinomas.
     A small number of other cancers were seen in the Kerns et
al. (1983) study.  These included one adenocarcinoma, one poorly
differentiated carcinoma, one carcinosarcoma, and two poorly
differentiated carcinoma/sarcoma.  The Carcinogenicity/
Histopathology/Genotoxicity Panel of the Consensus Workshop on
Formaldehyde (1984) stated that "[f]he polypoid adenomas can be
evaluated separately and in combination with the nonsquamous
carcinomas that were observed in the 14 ppm rats."
     Since an adenocarcinoma and a morphologically similar
carcinoma were seen in the study, the polypoid adenomas may
represent the benign counterpart of these lesions.  The PWG
stated that  these lesions might arise de novo, originate from
submucosal glands, arise in polypoid adenomas, or a combination
of the above.  Also, the PWG stated that "not enough information
                               4-21

-------
was available about nasal cavity tumors  to predict the



possibility of benign tumors progressing to carcinomas."



However, a recent analysis by Swenberq and Boreiko (1985) states



that polypoid adenomas are likely to be the benign counterpart of



adenocarcinomas and may be more common in control animals than



previously thought.  In the Kerns study, one polypoid adenoma was



present in the same section as an adenocarcinoma in the  15 ppm



exposure group.  In contrast, no adenocarcinomas were found in



the 2 or 6 ppm exposure group, even though more polypoid adenomas



were found at each of these two exposure levels than at  15 ppm.



Even if polypoid adenomas are considered to be the benign



counterpart of adenocarcinomas, the conversion rate is low (a



conversion ratio of 1:15).  As for the possibility that  the



polypoid adenomas may be the benign counterpart of



carcinosarcomas, this seems unlikely due to different tissue



type.   Added to this are the lack of dose-response, diagnostic



uncertainties (3 of the 12 tumors were borderline calls), and the



poor statistical significance of these lesions.



     Finally, as discussed earlier, in the Albert et al. (1982)



and the Tobe et al. (1985) studies, papillomas rather than



polypoid adenomas were observed and in the Kerns et al.  (1983)



study only polypoid adenomas were observed.  This intraspecies



(and intrastrain since Tobe et al. and Kerns et al. used Fischer



344 rats)  difference also adds to the uncertainty in using the



polypoid adenoma data for risk estimation purposes.  Whether the



difference in benign tumors observed is due to a strain  difference^
                               4-22

-------
 is  not clear.  However, the separate appearance of two distinct
 types of benign tumors further calls into question the significance
 of  these lesions regarding their ability to progress to squamous
 cell carcinomas and their relevance in estimating human risk.
     Because the nature and progression of benign nasal tumors is
 not well understood, studies on other chemicals can be looked to
 for elucidation.
     Studies by Lee and Trochimowicz (1984), Takano et al (1982),
 and Reznik et al. (1980) have examined the morphology of nasal
 tumors in rats caused by exposure to hexamethylphosphoramide
 (HMPA), 1,4-dinitrospiperazine (DtfP), and 1,2-dibromo-3-
 chloropropane (DBCP), respectively.  In the Reznik et al. (1980)
 study on DBCP, 78% of the tumors in male and 66% in female F-344
 rats in the low dose group were benign (adenomas and squamous-
cell papillomas).  However, in the high dose group 89% and 76% of
 the tumors in males and females, respectively, were malignant
 (adenocarcinomas and squamous-cell carcinomas).  It does not
appear that the shift from primarily benign tumors at the low
dose to primarily malignant tumors at the high dose means that
 the benign tumors were progressing to their malignant
counterparts.  Most of the benign tumors were located in the
anterior part of the nasal cavity, while most of the malignant
 tumors were located in the region of the ethmoturbinates and the
posterior part of the nasal septum.  Adenomas and adenocarcinomas
 were often seen in rats at the same time and dose, but in
different parts of the nasal cavity.
                               4-23

-------
     In the'Takano et al .  (1982) study with DNP using F-344 rats!



5 different proliferative  Lesions were seen:  simple hyperplasia,



papillary hyperplasia, nodular hyperplasia, papilloma, and



carcinoma (mostly adenocarcinomas).  Papillary hyperplasia and



papilloma were mainly located in the anterior regions of the



nasal cavity.  Nodular hyperplasia and adenocarcinoma, on the



other hand, were found in the posterior regions.  Also, these



pairs of lesions often coexisted in their respective locations.



The conclusion of the authors was that papillary hyperplasia



progresses to papilloma and that nodular hyperplasia progesses to



adenocarcinoma.



     The studies by Lee and Trochimowicz (1982, 1984) using



Sprague-Dawley rats showed that HMPA caused mainly epidermoid



(squamous cell) carcinomas (71%), adenoid squamous carcinoma



(15%) and squamous cell papilloma (8.2%).   (A small number of



adenomatous polyps were seen with adenoid squamous carcinomas.)



The squamous cell papillomas were mostly exophytic, which may



indicate that they may not represent the benign counterpart of



the epidermoid carcinomas  for two reasons.  First, in the Takano



et al.  (1982) study/ nodular hyperplasias rather than papillomas



seemed  to progress to adenocarcinomas.  Second, the papillomas



and nodular hyperplasias are similar to human exophytic and



inverted papillomas, respectively.  In humans, squamous



carcinomas apparently arise from inverted papillomas rather than



exophytic papillomas (Takano et al., 1982).



     The experience with other chemicals (see Lee and
                               4-24

-------
Trochimowicz,  1982) and the  foregoing  illustrate  the variability



of the  types and locations of the tumors  found.   Also, except in



limited  cases,  the progression of preneoplastic and benign



neoplasms  to malignant neoplasms is not known with any



assurance.  Although some studies of chemicals show a tumor



profile  that is predominantly benign at low doses and malignant



at high  doses  (MTP, 1982a; NTP, 1982b) other studies, such as of



HMPA, show primarily malignant tumors at  all dose levels



eliciting a response.  This may be the result of  a speed-up of



the carcinogenic process at higher doses  in the former case or as



in the  latter  one the chemical may be  so 'potent that even at low



doses progression is completed before termination of the study.



     Because there are so many uncertainties associated with the



polypoid adenoma data, it is recommended  that (1) they not be



combined with  squamous cell carcinomas (pooling)  for statistical



purposes, and  (2) risk estimates should be generated separately



using the polypoid adenoma data for analysis purposes (see



Sections 7.2 and 7.4).



4.3.   Short-Tern Testa:  Genotoxicity and Cell Transformation



     HCHO affects genetic material in  a wide range of test



systems  (Auerbach et al. (1977); Ragan and Boreiko (1981):



Boreiko  et al.  (1982); Golmacher and Thilly (1983); Ulsamer et



al. (1984); Consensus Workshop on Formaldehyde (1984); Dooley et



al. (1985); Ma  et al. (1985); Scott et al. (1985); Cantoni and



Cattabeni  (1985), and Stankowski et al.  (1986)).  Mutajenic



activity of HCHO has been demonstrated in viruses, Escherichia
                               4-25

-------
coli,  Pseudomonas pluonescens, Salmonella  typhimur ium, and



certain strains of yeast, fungi,  Pro soph ilia, grasshopper, and



mammalian cells (Ulsamer et al.,  1984).  HCHO's  ability  to  cause



gene mutations, single strand breaks in DNA, DNA-protein cross-



links, sister chromatid exchanges  (SCE), and chromo.some



aberrations has been demonstrated  (Consensus Workshop on



Formaldehyde, 1984).  In vitro studies have shown HCHO's ability



to transform BALB/c 3T3 mouse cells, BHK 21 hamster cells,  and



C2H-10T1/2 mouse cells and to enhance the  transformation of



Syrian hamster embryo cells by SA7 adenovirus, and to inhibit DNA



repair (Consensus Workshop on Formaldehyde, 1984).  In a study by



Ragan and Boreiko (1981), treatment of C3H/10^/2 cells with  HCHO



did not result in significant rates of transformation.   However,



if HCHO treatment was followed by continuous treatment with the



tumor promoter 12-0-tetradecanoyl phorbol-13-acetate, significant



transformation occurred.  HCHO also causes increases in  the



frequencies of observed mutations  in the presence of other



mutagens,  such as X-rays, ultraviolet radiation, and hydrogen



peroxide.   Compared to its effects on strains of E. coli and



Saccharomycea cereviaiae with normal repair mechanisms,  HCHO



caused greater lethal and mutagenic effects in excision  repair-



deficient strains (Ulsamer et al.,  1984).



     In reviewing much of the above literature,  the Consensus



Workshop on Formaldehyde (1984)  "found that the  recent work is



more likely to find HCHO a mutagen  than earlier  studies, and is



also more likely to show a dose-response relationship.   These
                               4-26

-------
results are-most probably attributable to the greater



sophistication in the way the later assays were carried out.  It



should be noted that in the above studies, the relationship



between the cytotoxicity induced by HCHO and mutagenicity or



transformation induced by this agent is typical of most mutagens/



carcinogens that are positive in these assays.  The data we have



reviewed are consistent with HCHO acting as a weak mutagen (i.e.,



less than a ten-fold increase over background)."  In certain



bacterial tests it might be considered weak acting, but in a



recent NTP Drosophila sex-linked recessive lethal test, HCHO



would not be considered a weak acting mutagen (Woodruff et al.,



1985).  In fact,  in some cases HCHO is used as a test standard.



In vitro Cytogenetic studies have shown HCHO to be an efficient



inducer of sister chromatid exchanges (SCEs) and chromosomal



aberrations (Natarajan et al., 1983).



     In a study by Grafstrom et al. (1983) using cultured



bronchial epithelial and fibroblastic cells, HCHO's ability to



cause the formation of cross-links between DNA and proteins,



cause single-strand breaks in DNA, and to inhibit the resealing



of single-strand breaks produced by ionizing radiation has been



shown.  HCHO also inhibited the unscheduled DNA synthesis that



occurs after exposure to ultraviolet irradiation or to benzo-



[a]pyrene diolexepoxide, but at doses substantially higher than



those required to inhibit the resealing of X-ray induced single-



strand breaks, suggesting HCHO could exert its effects by both



damaging DNA and inhibiting DNA repair.
                               4-27

-------
     As a follow-up to the above study, Grafstrom et al. (1984)



investigated the repair of DNA damage caused by HCHO in human



bronchial epithelial cells and fibroblasts, skin fibroblasts, and



DNA excision repair-deficient skin fibroblasts from donors with



xeroderma pigmentosum.  Exposure of these cell types to HCHO



caused similar levels of DNA-protein cross-links and removal of



such cross-links in all cell types.  The half-life for the cross-



links was about 2-3 hours.  An examination of the induction and



repair of DNA single-strand breaks showed that the production of



the breaks was .dose dependent, and that there removal occurred at



rates similar to the removal of cross-links.  In addition, the



results indicate that exposure to HCHO causes single-strand



breaks without the involvement of excision repair, and that



excision repair of HCHO damage may increase the single-strand



break frequency.  HCHO also enhanced cytotoxicity of ionizing



radiation and N-methyl-n-nitrosaourea in normal bronchial



epithelial cells and fibroblasts.  The authors speculated that



the inhibition of DNA-repair probably involves the interaction of



HCHO with cellular proteins of importance in DNA repair.  They



noted that the repair of DNA lesions caused by ultraviolet



radiation has been shown to be inhibited by alkylating agents.



     In a related study, Grafstrom et al. (1985) investigated the



effect of HCHO on the repair of 0^-methylguanine and the ability



of HCHO to potentiate the mutagenicity of N-methyl-N-nitrosourea



(NMU) in normal human fibroblasts.  When rate of DNA repair was



measured for NMU-treated cells that were incubated with HCHO, a
                               4-28

-------
significantly lower rate of DNA repair was observed compared to



NMU-treated cells.  The authors proposed that HCHO inhibits DMA



repair by binding to the active site of 0 -alkylguanine DMA



alkyltransferase.   Also, although NMU and HCHO are weak mutagens,



addition of HCHO to NMU-treated cells resulted in a significantly



higher mutation frequency than was found with HCHO or NMU



alone.  The increase may be due to HCHO's inhibiting O -methyl-



quanine repair (Grafstrom et al., 1985).



     However, the results of a study by Snyder and Van Houten



(1986) question the finding of Grafstrom et al. (1983) that HCHO



inhibits UV-induced, unscheduled DMA synthesis.  They found that



the inhibition only occurs when thymidine is used as a precursor,



which suggests an uptake artifact.  Also, their results indicate



that HCHO has no significnat effect on the rate of repair of



x-ray-induced strand breaks or those by bleomycin.  Consequently,



Snyder and Van Houten believe that it is likely that HCHO has no



significant effect on the sealing of most DMA breaks in human



fibroblasts; their work did not support a conclusion that the



ligation step of excision repair is preferentially sensitive to



HCHO.



     In a study by Craft and Skapek (1986) using human



lymphoblasts, it was found that when these cells were exposed in



vitro to HCHO using single or multiple treatment regimens, a



difference in the cumulative induced mutant fraction was  .



observed.  Single treatment exposures (0-150 uM X 2 hr) resulted



in a nonlinear increase in induced mutant fraction.  The multiple
                               4-29

-------
exposure experiment u^ing either three treatments of 50 uM X 2



hr, five treatments of 30 uM X 2 hr, or ten treatments of 15 uM X



2 hr, all treatments administered on alternative days, resulted



in additive (linear) increases in mutant fraction.



     The multiple treatment regimen produced a lower rate of



mutations compared to an equivalent single dose; an induced



mutant fraction of 2.2 ± 0.2 X 10"6 for the five 30 uM exposures



vs. 4.8 ± 0.4 X 10~6 for the single 150 uM treatment.



     A recent study by Casanova-Schmitz et al. (1984) has



reported the difference between metabolic incorporation and



covalent binding in the labelling of macromolecules in rat nasal



mucosa and bone marrow by inhaled [*4C]- and C^H] HCHO.  Rats



were exposed to labelled HCHO at concentrations of 0.3, 2, 6, 10,



or 15 ppm for 6 hrs, one day following a single pre-exposure to



the same concentration of unlabelled HCHO.  The principal finding



reported by the authors was the apparent nonlinearity in the



amount of covalent binding of HCHO to DNA of the respiratory



mucosa.   The amount of HCHO covalently bound to mucosal DNA at 6



ppm was reported to be 10.5 times higher that at 2 ppm, whereas



covalent binding to protein increased in a linear manner with



increases in HCHO concentration.  No covalent binding was noted



in tissues from the olfactory mucosa or bone marrow.  The



apparent nonlinear covalent binding of DNA between 2 and 6 ppm



has been used as an input in quantitative estimation of risk from



HCHO exposure (Starr and Buck, 1984).  Whether Casanova-Schmitz



et. al. measured covalent binding of HCHO to macromolecules has
                               4-30

-------
been questioned.  See section 4-5.2 for a  further discussion of

this issue.

     Various studies have been undertaken  to determine whether

HCHO has genotoxic effects in vivo.   In mice, the dominant lethal

test was' found to be negative (doses  up to 40 mg/kg,  IP).

However, in a more recent dominant lethal assay using higher

doses (50 mg/kg, IP) and a different  mouse strain specify,

marginally positive results were obtained, but only in the first

and third week of the seven weeks studied  (Consensus Workshop on

Formaldehyde, 1984).  However, the positive response obtained may

not be indicative of a mutagenic change for the following

reasons:

    "1.  The week to week variation in implantations data are
         common in dominant lethal studies.  Therefore,
         concurrent controls should be included in each weekly
         mating.  It is not clear from the paper how the control
         matings were conducted; the  control value is shown as a
         mean with no indication of the extend of weekly
         variation in control population.

    2.    The index of implantation deaths should probably be
         analyzed on the basis of "per pregnant female" and not
         on the total numbers as done in the paper.

    3.    Preimplantation losses as shown in week 1 and 3 should
         be viewed as an index of dominant lethal effect only if
         the losses were found to be  due to death of preimplants
         and not due to failure of oocytes to become fertilized."
(IRMC Report on Systemic Effects, 1984)

Negative results were obtained when the induction of micronuclei

or chromosomal aberrations were used  as an endpoint.  A small

increase in .sister chromatid exchanges (SCE's) has been reported

in the bone marrow of mice exposed to high (>25 ppm) HCHO

concentrations.  Unfortunately, technical problems were
                               4-31

-------
encountered during the HCHO exposures, and the actual



concentrations required to elicit this effect are not known



(Consensus Workshop on Formaldehyde, 1984).  In a recent study by



Ward et al. (1984) measuring changes in sperm morphology, mice



were treated by gavage with five consecutive daily doses of



formalin  (100 mg/kg; 10 animals).  No increase in abnormal sperm



morphology was observed in the treated mice.



     The possibility of genetic effects in humans caused by



inhalation of HCHO has been investigated by a number of persons.



     In a study reported by Spear (1982), significant numbers of



SCE's in eight students exposed to HCHO during an anatomy



laboratory class were found.  Mean HCHO levels were 1 ppm during



dissections.  Mierouskiene'  and Lekevicius (1985) have reported a,



statistically significant increase in chromosome aberrations in a



group of 50 workers exposed to phenol, styrene, and HCHO.  The



control group consisted of 25 individuals which had no



occupational exposure to chemical substances.  The finding of



increased chromosome aberrations was independent of age, exposure



length, and smoking habit.  In a study by Bauchinger and Schmid



(1985)  using lymphocytes from 20 males exposed to HCHO and



unexposed males employed by a paper factory, a significantly



increased incidence of dicentrics or dicentrics and ring



chromosomes was observed for 11 exposed workers employed as



supervisors.  Their total mean exposure time was 2.5 times longer



than for the 9 exposed paper machine operators.  SCE values were



not significantly different for smoking and nonsmoking HCHO



workers when compared with the control group.





                               4-32

-------
     No  genetic  effects in humans were  seen  in  studies by FLeig



et al.  (1982), Ward et al. (1984), and  Thomson  et al.  (1984).  In



the  study by  Fleig et al. (1982), 15 employees  exposed to HCHO



during HCHO manufacture and processing  were  studied.  The



employees had 23 to 35 years of exposure.  Mean HCHO levels did



not  exceed 5 ppm before 1971 and 1 ppm  after that date, with most



workers  exposed  to a maximum of 0.25 ppm  (post  1971).  No



increase in chromosome aberrations was  observed as compared to



controls.  Similarly, in a study of pathology staff exposed to



HCHO by  Thomson et al. (1984), no difference in chromosome



aberrations induction and SCE frequencies was seen between the



exposed and control groups (6 exposed and 5  controls).  Time-



weighted average levels of HCHO ranged  from  1.14 to 6.93 mg/m^,



with peaks greater than 11.0 tng/m^.   The pathology workers were



generally exposed to HCHO for 2-4 hours per  day, 2-3 days per



week.  In the Ward et al (1984) study,   sperm count, morphology,



and  fluorescent body frequency in 11 autopsy service workers



exposed to HCHO and 11 controls were evaluated.  Time-weighted



average HCHO levels ranged from 0.61 to 1.32 ppm (weekly exposure



range 3-40 pm hours).  No significant differences in the



endpoints studied were observed between exposed and control



groups.



     Finally, Connor et al.  (1985) examined  the mutagenicity of



urine from HCHO-exposed autopsy service workers.  An exposed



group of 19 and a control group of 20 were matched by sex, age,



and use of tabacco, alcohol,  and recreational drugs.  Urine
                               4-33

-------
samples were tested using 5. typhinurium TA100 and TA98 with and



without S9 activation.  Except for a sample  from a smoker in the



control group and three samples from an individual receiving



metronidazole therapy, most samples produced little'or no



increase in revertants using either strain.  However, a



significant number of the samples from the exposed group were



toxic to TA100 and TA98.  Similar findings have been reported for



aluminum workers (exposed and control) and in nursing



personnel.  The toxicity from the three studies appear to be



identical, but the toxicant has not been identified  (Connor et



al., 1985).



     As noted above, the literature reports  conflicting data



concerning chromosomal effects in humans.  However, the weight of,



these data seems to indicate little potential for these effects



in the workplace, but this judgement must be tempered by the



limitations of the studies.
                               4-34

-------
 4.4.   Other  Effects/Defense Mechanisms
 4.4.1.    Introduction
     The  cancer  response observed  in  the Kerns et al.  (1983)
 study was very nonlinear,  1% of the rats responded at  5.6 ppm
 while 50% responded at  14.3 ppm.   A number of hypotheses have
 been developed which attempt to explain this response  and the
 different responses seen in rats and mice in that study.  These
 hypotheses are based on the noncarcinogenic effects of HCHO.
 Although  these noncarcinogenic effects are not easily  separated,
 it is possible to discuss  the nature of the effects themselves,
 and how they may relate to results seen in long-term animal tests
 of HCHO, by examining three subject areas:  sensory irritation;
 cell-proliferation; and the mechanics of the mucous layer
 "defense" system.
 4.4.2.   Sensory Irritation
     In the Kerns et al. (1983) study/ the response observed  in
mice as compared to rats is markedly different, 2 mice responding
 at 14.3 ppm versus 103  rats responding at this concentration.
 Also, in studies using hamsters (Dalbey, 1982), no tumor response
was seen.  One of the reasons given for the difference between
 rats and mice is the observation that mice exposed to  14.3 ppm
 reduce their breathing  rate in response to the irritant
 properties of HCHO.  Such an effect may be occuring in hamsters
 at the doses tested, but experimental evidence is lacking.  How
 reduction in breathing  rates (which is an effective defense.
mechanism at certain concentrations)  is weighed in terms of HCHO
cancer risk assessment  is discussed below.
                               4-35

-------
     It  is well established  that sensory  irritants  evoke
responses by stimulating the free nerve endings of  the afferent
trigeminal nerve  located in  the corneal,  nasal, and oral
mucosa.  Besides  burning sensations, sensory  irritants cause a
number of physiological reflex responses, one of which is a
decrease in respiratory rate.  A number of chemicals have been
studied  in this regard and have RDSO's established  for them.  The
RD50 value is the concentration of an irritant that causes a 50%
reduction in respiratory rate.  A proposal to use RDSO's to
establish concentration standards for human exposure to sensory
irritants has been made (see Kane et al., 1979; and Buckley et
al., 1984).  A number of chemicals have been  investigated and
RD50 values established, including HCHO and hydrogen chloride.
Consideration of  this effect may be important in interpreting
inhalation bioassays because a doubling of a  nominal
concentration to  which an animal is exposed may not result in a
doubling of the dose actually received by the animal.  For
instance, the RD50 value of HCHO for Swiss-Webster mice is 3.13
ppm.  Consequently* results from a study  using a dosing regimen
with concentrations above and below this  number should be
interpreted in the light of the fact that the dose  actually
received by the test animals does not increase in the same
proportion as the nominal concentration.  Also, it  should be
noted that respiratory rate suppression could change over the
course of a chronic study (Dallas et al.  1985).
                               4-36

-------
      In  the  case of  the  Kerns  study/  experimental  data  (Chanq  et



al.,  1981; 1983) indicate that mice exposed  to  14.3 ppm  HCHO



reduced  their  breathing  rate to such  an  extent  that an  adjusted



exposure concentration would show the mice being dosed  with



approximately  the same amount  of HCHO as  rats at 5.6 ppm, where



the same cancer response was observed.   If this factor  is wholly



responsible  for the  difference in response between rats  and



mouse, then  adjusted doses can be used to calculate risks from



mouse data.  Thus, it can be postulated  that  if mice could be



exposed  to levels of HCHO that would approximate the amount rats



received at  14.3 ppm, then the response  in mice would be similar.



     The evidence indicates that mice are more  sensitive or



better able  to respond to the  sensory effects of HCHO than rats,



and it may be  this response which accounts for  the different



carcinogenic response observed in rats and mice in the  Kerns et



al. (1983) study.  Adjusting dose levels  for  this  response shows



that mice may  be as  sensitive  as rats to  the  carcinogenic



potential of HCHO.   Hamsters, on the other hand, appear  to be



less sensitive to HCHO,  although the  response of hamsters and



rats to  tobacco smoke is similar (as discussed  in  the section  on



animal testa,  two factors may  account for the absence of an



observed effect in hamster; limited pathology work in the study,



and a low test dose.



4.4.3.   Cell  Proliferation, Cytotoxicity, and  the Mucous Layer



     Another important consequence of HCHO's  irritant properties



is its effects on cell proliferation and  damage it can  cause to
                               4-37

-------
the mucociliary clearance system  (resoiratory and olfactory
epithelium) of the nasal cavity.  These effects have been cited
(Starr et al., 1984) as important factors in HCHO induced
carcinoaenicty from the standpoint of their impact on the
mucociliary clearance system/ as a orereouisite for HCHO induced
cancer, and in understanding the importance of concentration
versus cumulative exposure.  These factors have an important
impact on the model chosen for quantitative risk assessment and
the weighing of noncarcinogenic effects as a cancer risk factor.
4.4.3.1.   Cell Proliferation and Cytotoxicity
     Studies by Swenberg et al. (1983) and Chang et al. (1983)
have reported the relationship between HCHO concentration and
cumulative exposure on cell turnover in the nasal cavity of rats
and mice.  A diagram indicating the codina of the nasal cavities
of rats and mice for the test data discussed below is provided  in
Figure 4-3.
    Figure 4-3.  Drawing indicating the level of sections from
    the nasal passages of rats and mice. Figure taken from
    Swenberg et al. 1983.
                               4-38

-------
In one test, rats and mice were exposed to 0, 0.5, 2, 6, and  15
ppm HGHO 6 hrs/day for 3 days, and then to 3H-thymidine 2 hours
after the end of exposure.  As illustrated in Table 4-4,
increased cell proliferation as measured by increased
incorporation of labelled thymidine into cells was evident in
rats at 6 and 15 ppm and in mice at 15 ppm.
                            Table 4-4.
      EFFECT OF FORMALDEHYDE EXPOSURE ON CELL PROLIFERATION
                IN LEVEL B OP THE NASAL PASSAGES*
Exposure*
Control
0.5 ppm
2 ppm
6 ppm
15 ppm
% of Labelled Respiratory
Rat
0.22 _+ 0.03
0.38 _+ 0.05
0. 33 _f 0.06
5.40 +_ 0.82
2.83 jf 0.81
Epithelial Cells***
Mouse
0.12 _+ 0.02
0.09 _+ 0.04
0.08 _f 0.04
0.15 _+ 0.06
0.97 _+ 0.04
   *Table taken from Swenberg et al. (1983).
 **A11 animals exposed for 6 hrs/day for 3 days
***Mean + standard error.
     When the labelled thymidine is administered 18 hours after
the last exposure, a greater increase in cell turnover is seen as
illustrated in Table 4-5.  The increase in cell  labelling may be
because 2 hours post exposure may not be the most sensitive time
for DNA synthesis due to initial inhibition by HCHO {Swenberg et
al., 1983).
                               4-39

-------
                            Table 4-5.
         EFFECT OF THE TIME OP JH-THYMIDINE PULSE ON CELL
        REPLICATION AFTER  HCHO EXPOSURE TO RAT  (LEVEL B)*
Post-Exposure
Time of Pulse
2 hours
18 hours
% Labelled Cells**
0/ppm 6 ppm***
0. 26 jf 0.03 1.22 + 0. 17
0.54 _f 0.06 3.07 +_ 1.09
  *Table taken from Swenberg et al. (1983).
 **Mean ± standard error.
***6 ppm, 6hr/day for three day.


     To determine whether concentration is more  important than

cumulative dose, a series of concentration time  products were

tested.  Each product equaled 36 ppm-hrs of exposure.  The

results of this test, which appear in Table 4-6, indicate that,

at least for the effect measured, concentration  has a greater

affect in level B of the rat nasal cavity.
                            Table 4-6.
           EFFECT OF HCHO CONCENTRATION vs. CUMULATIVE
           EXPOSURE ON CELL TURNOVER IN RATS (Level B)*
% Labelled Cells**
Exposure
Control
3
6
12
ppm
ppm
ppm
X
X
X
12 hrs
6 hrs
3 hrs
3 days +
0
1
3
9
.54 +
.73 _+
.07 _+
.00 _+
18 hrs
0
0
1
0
.03
.63
.09
.88
10 days +
0.
0.
0.
1.
26 _+
49 +.
53 jf
73 _+
18 hrs
0
0
0
0
.02
.19
.20
.65
  *Table taken from Swenberg et al.  (1983)
 **Mean •»• standard error.
                               4-40

-------
     However,  the amount of  labeling measured  in  the most

anterior region of the nasal cavity indicates  the opposite.  The

extent of labeling was essentially the  same  at  each HCHO exposure

level.  See Table 4-7 for details.
                            Table 4-7.
            EFFECT OF HCHO CONCENTRATION vs. CUMULATIVE
           EXPOSURE ON CELL TURNOVER IN RATS (Level A)*
                                          % Labelled Cells
	Exposure	After 3  Days Exposure**	

    Control                                   3.00 jf   1.56
     3 ppm X  12 hrs                         16.99 _*   1.50
     6 ppm X  6 hrs                          15.46 _* 10.01
    12 ppm X  3 hrs                          16.49 _*   2.07


  *Table taken from Swenberg et al.  (1983)
 **Mean _+ standard error.


     Whether  this difference in cell  proliferation between  levels

A and B is due to differences in mucociliary  clearance in the

respective regions, to HCHO-laden  mucous  flowing from posterior

to anterior regions (Swenberg et al., 1983) or simply that  the

"capture" capacity of Level A is exceeded which allows pass-by of

HCHO to L«v«l B and beyond, or some  other reason, is  unknown.

     The data developed on mice regarding cell proliferation  are

not as clear.  In a test  to measure  differences between

concentration and cumulative exposure there was an  inverse

response as illustrated in Table 4-8.   Perhaps the ability  of

mice to reduce their breathing rate  at  high HCHO concentrations

played a role.
                               4-41

-------
                            Table 4-8.
           EFFECT OP HCHO CONCENTRATION vs. CUMULATIVE
           EXPOSURE ON  CELL  TURNOVER IN NICE (Level A)*
                                       % of Labelled Cells
    Exposure	After 10 Days Exposure**

    Control                                  1.24 _* 0.57
     3 ppm X 12 hrs                         10. 14 jf 3.20
     6 ppm X 6 hrs                           4.72 +_ 1.61
    12 ppm X 3 hrs                           1. 76 _+ 0.49
  *Table taken from Swenberg et al. (1983)
 **Mean •*• standard error.
     The difference between rats and mice has not been adequately

explained, except that there appears to be a significant species

difference regarding cell proliferation.

     A study by Rusch et al. (1983) supports the concept that

concentration may be more important than cumulative exposure, at

least for rats.  In the study, five qroups of 6 male Cynomoloqus

monkeys, 20 male and 20 female Fischer 344 rats, and 10 male and

10 female Syrian golden hamsters were exposed to 0, 0.2, 1.0, and

3.00 ppm for 22 hrs per day, 7 days per week for 26 weeks.

     The most significant finding was squamous metaplasia/

hyperplasla in rats and monkeys at  3.0 ppm.  Hamsters were  not

affected at any dose level.  However, the most significant

finding is that even though rats at 1.0 ppm  in the Rusch et  al.

(1983) study received a cumulative  exposure  2.5 times greater

than rats at 2.0 ppm in the Kerns et al.  (1983) study, which

experienced squamous metaplasia, they were largely free of
                               4-42

-------
squamous metaplasia.  This strengthens  the conclusion of  the
Swenberg et al.  (1983) study which  indicates that, at least for
rats, concentration  is more of a  factor  than cumulative exposure
for metaplasia.
     In- the Kerns et al.  (1982) study, significant levels of
noncarcinogenic  lesions were noted  in rats at all dose levels.
The severity and extent of these  lesions were concentration and
time dependent and seem to be correlated with the cancer
response, i.e.,  these lesions preceded the appearance of squamous
cell carcinomas and their severity  increased with increasing
cancer response.  This observation, tied with the data showing
increases in cell proliferation due to HCHO exposure and a
threshold for squamous hyperplasia/metaplasia of between  1 and 2
ppm, leads some  to the hypothesis that these effects are
important determinants in HCHO induced carcinogenicity and that
they help explain the nonlinearity  of the cancer response.
Another factor suggested  to contribute to the possibility of a
nonlinear response is the role of the mucous layer in trapping
and removing HCHO.  This  hypothesis is that when its removal
capacity is exceeded or its flow  impeded, HCHO can then impact
the respiratory epithelium, thus  causing the noncarcinogenic
effects noted above.  A discussion  of the role of the mucous
layer follows this section.
     As noted previously, there was a 50 fold increase in cancer
response due to a slightly more than a doubling of the dose in
the Kerns study  (5.6 to 14.3 ppm).  What was the change in
                               4-43

-------
response of the noncarcinogenic effects?  Using data developed
for the incidence of s-quamous metaplasia in rats in the Kern
study, a rough comparison can be made.  The incidence of squamous
metaplasia in level 2 (level B in Figure 4-3) of the rat nasal
cavity was chosen because it showed a positive correlation with
concentration rather than cumulative dose, moreover/ it is in the
middle of the anterior part of the nasal cavity where the
squamous cell carcinomas were observed, and it is of the same
cell type as the carcinomas.  If one compares the percentage
incidence of squamous metaplasia in the three dose groups at the
sacrifice points in Table 4-9, one sees a clear dose-response,
but not a 50-fold increase between 5.6 and 14.3 ppm; there
appears to be only a 2-fold increase or less.  While increased
cell turnovers could lead to greater interaction of HCHO and
single-strand DNA, and thus an enhancement of the cancer
response, incidence of squamous metaplasia alone does not appear
to explain the extreme nonlinearity observed.  A major  limitation
of this comparison is that it does not account for the  severity
and extent of the lesions which presumably increased at higher
concentrations.
          t
                               4-44

-------
                            Table 4-9.
           FREQUENCY OP SQUAMOUS METAPLASIA  IN LEVEL 2
                     OP THE RAT NASAL CAVITY*

                     Incidence  (Percent) of  Squamous Metaplasia
 Dose (ppm)                     Month of Sacrifice
                            6     12      18       24     27

 5.6   •                   50     45      60       65     30
14.3                       75     90      98       100    100
'Estimated from Figure 4-1.


     Other chemicals such as acetaldehyde and hexamethyphos-

phoramide (HMPA) are cytotoxic and cause cancer in rats.  Data on

these chemicals may provide some insight.

     If one examines the incidence and severity of the

noncarcinogenic lesions seen in the Woutersen (1985) acetaldehyde

study and the tumor response, one sees a roughly dose-related

response, i.e., a doubling of dose doubles the response seen

(cancer and noncancer).  Although the olfactory epithelium was

severely affected at the highest dose/ the cancer response is

hardly increased over the next lower dose (see the section on

Structure Activity Relationships for a full discussion of the

data on acetaldehyde).

     An anatomical region that had a high incidence of noncancer

lesions that was dose-related was the larnyx (mostly squamous

metaplasia).  Table 4-10 illustrates this response.  However,

only one tumor was observed in the larnyx.
                               4-45

-------
                           Table 4-10.
              INCIDENCE OP LESIONS  OTHER THAN TUMORS
                 IN THE LARNYX OF RATS EXPOSED TO
                     ACETALDEHYDE  [NUMERIC]*
                                           Dose  (ppm)
                              0     750      1500      3000/1000
Number of Male Rats          50      50       51          47

Squamous metaplasia           3       6       23          41
Hyperkeratosis                1       4       13          32
*Data from Feron (1984)


     The relationship between the noncancer and cancer  response

seen in rats exposed to HMPA is unremarkable.  As Table  4-11

indicates, an increase in dose did not lead to a many  fold

increase in the cancer response although HMPA severely  damaged

the nasal mucosa of the rats.
                           Table 4-11.
           INDIGENCE OP EPIOERMOID AND ADENOID SQUAMOUS
                  CARCINOMAS  IN RATS EXPOSED  TO
                     HEXAMETHYLPHOSPHORAMIDE*
Dose (ppb)              0     10     50      100      400      4,000
No. of Rats
  Examined             396    200    194     200      219       215

                          Tumor  Incidence  (%)

Epidermoid carcinoma     0       0    12.4    29.5     62.6      55.8
Adenoid squamous
  carcinoma              0       0      2.1     2.5      9.6      19.1


*Data from Lee and Trochimowicz  (1982)
                               4-46

-------
     As a general matter, it appears that there is no clear



relationship between cell proliferation/cytoxicity and tumor



response.   It is clear that there is much variation in the way



tissues respond to carcinogens, and no firm conclusions can be



drawn.  .The appearance of noncancer lesions is not surprising



given the acute toxicity of many carcinogens.  However, it is



impossible at this time to clearly link the noncancer effects in



the Kerns study to the appearance of cancers and the nonlinearity



of the  response.  On the other hand, it is plausible that the



noncancer effects may enhance the cancer response of HCHO and



other carcinogens by providing an increased opportunity for HCHO



to interact with single-strand DNA during cell replication or to



promote an initiated cell.  Consequently, prudence would dictate



that situations which cause cell proliferation or lesions shouli



also be avoided.  This includes short-term peaks especially if



cell proliferation and cytoxicity contribute to the carcinogenic



process.  Also, it must be remembered that there is a natural



background rate of cell turnover in the nasal mucosa which can



provide the opportunity for mutagenic/carcinogenic events to



occur.   Although such events may be rare, only one such sequence



of events may need to occur in a population of 10,000 persons



over 70 years to give a cancer risk of 1 X 10" .



     Finally when discussing acute responses to a chemical such



as irritating effects, it should be remembered that there can be



a no-effect level in individuals at or below which no response is



observed no matter how many days of exposure occur.  However,
                               4-47

-------
once a minimum effect concentration  is reached,  the duration of



the exposure may have a major  impact on the severity of the



effect.  Although the occurrence of  squamous metaplasia and other



responses to acute effects may influence the expression of a



carcinogenic response, the absence of these acute responses does



not signify a no-effect level or the absence of a carcinogenic



response.  For instance, the well-known carcinogen urethan causes



skin tumors (papillomas and squamous cell carcinomas) in mice,



but not epidermal hyperplasia or inflammatory reactions (Iversen,



1984).



4.4.3.2.   Mucous Layer



     Besides HCHO's effect on cell proliferation and respiratory



response, it also has a major  impact on the mucociliary system o,fi



the nasal cavity through its ability to cause ciliastasis and



cell mortality at elevated concentrations.  In addition, it has



been postulated that below certain HCHO concentrations  (1-2 ppm)



the mucous layer can trap and remove much inhaled HCHO, thus



preventing it from reaching underlying cells.  However, once the



mucous  layer is saturated, HCHO can  then begin to affect the



underlying cells as described  in the section above.  When this



occurs, the mucociliary clearance system is seriously compromised



which allows a greater amount of HCHO to reach the respiratory



epithelium.  If the mucous layer removed most inhaled HCHO below



1 ppm then it would represent a threshold phenomenon at least for



the nasal cavity.  However, the evidence for this is lacking.



The discussion below describes the effects caused by HCHO on the



mucociliary system and its role in protecting the nasal mucosa.
                               4-48

-------
     The  nasal cavity  is primarily composed of ciliated
respiratory and olfactory epithelium which is covered by a moving
blanket of mucus.  Mucus is composed of approximately 95% water,
0.5-li glycoproteins, and other minor constituents.  The human
nose has  three functions, two of which depend on the presence of
a mucous  layer.  The first function of the nose is to inform us
of the presence of noxious gases, if these stimulate the
receptors of the olfactory nerves.  The second function of the
nose is to drain the secretions of the sinuses and of the
lacrimal  (tear) glands.  The third function of the nose is to
prepare the inhaled air for the lungs.  This includes warming,
moistening, and filtering inspired air.  Dust and many bacteria
found in  the inspired air are impinged in the mucous that bathes
the mucous membrane and, by the action of the cilia of the nasal
passage,  are moved outward (Tuttle et al., 1969).
     As research by Morgan et al. (1983, 1984, 1986) indicates,
HCHO has  a number of effects on the workings of the mucociliary
apparatus.  Using in vitro and in vivo techniques, Morgan et al.
(1983a) examined mucous flow patterns in the rat nasal cavity and
the effect of HCHO on the mucociliary apparatus.  Results of the
in vitro  analysis indicate that mucus was present as a flowing
continuous coat over the respiratory epithelium except on the
most anteriorcentral extremity of the nasoturbinates and the
anteriomedial extremity of the maxilloturbinates.  Mucous flow
rates ranged from 0.28 to 9.02 mm/minute.  When rats were exposed
to 15 ppm HCHO, 6 hrs per day for 1, 2, 4, or 9 days, mucostasis
                               4-49

-------
accompanied by ciliastasis was evident  in a  number of  anatomicaT



regions of the rat nasal cavity.   In another study by  Morgan et



al.  (1986), male  rats were exposed  for  6 hours per day for  1,  2,



4, 9, or 14 days, to 0.5, 2, 6 or  15 ppm HCHO.  There  was a clear



dose-dependent affect on mucociliary activity.  At 15  ppm there



was significant inhibition of mucociliary activity.  Only slight



effects were noted in animals exposed to 2 or 6 ppm.   At 0.5 ppm



no effects were observed.  Finally, using frog palate,  Morgan et



al.  (1984) found  that mucostasis,  and ciliastasis occurred at



4.36 and 9.58 ppm, respectively.   At 1.37 ppm an initial increase



in ciliary activity was observed but there was no mucostasis or



ciliastasis, while at 0.23 ppm there was no effect.



     The above results indicate that a  concentration relationship



exists where mucociliary flow would be  impaired at 15  ppm and



less so at 6 and  2 ppm.  This range corresponds to the range



where the steep dose-response in carcinogenic!ty of HCHO was seen



in the Kerns et al. (1983) study.   Recent work by Bogdanffy et



al. (1985)  demonstrated the ability of  HCHO  to bind with proteins



in human and rat  nasal mucus and bovine serum albumin.



Incubation of HCHO in vitro with these  materials indicated  that



binding i3 rapid  and that the main  binding constituent in nasal



mucus is albumin.  Consequently, some fraction of inhaled HCHO



would be expected to be bound and  removed, thus protecting  the



underlying epithelium.



     Whether the  mucous layer has  some  finite capacity to absorb,



retain, bind, and metabolize HCHO  and wash it away to  prevent  it
                               4-50

-------
from reaching the underlying cells, or the response seen is
simply the overt signs of gradual cell toxicity, is unknown.
However, a number of  factors can be considered when discussing
the protective ability of the mucous layer.  First, humans can
detect HCHO at levels below 1 ppm which indicates that, at least
in the olfactory region of the nasal cavity,  HCHO is not
completely removed by the mucous layer.  The mucous layer is
reported to be immobile or flowing extremely slowly in this
region (CUT, 1984).  However, it would seem that if a greatly
reduced removal capacity of the mucous layer in the olfactory
region played a role, this region should have been a target for
effects in the Kerns et al. (1983) study.  This was not the
case.  The significant neoplastic and nonneoplastic effects were
generally seen in the anterior regions of the rat nasal cavity.
     Second, in a study by Casanova-Schmitz et al., 1984), which
measured the difference between metabolic incorporation and
covalent binding of labelled HCHO to macromolecules, it was found
that covalent binding to protein increased in a linear manner
with increases in airborne concentrations (0.3-15 ppm).  However,
the finding is complicated by the fact that labelled
extracellular as well as intracellular protein was measured and
the fact that the overall results of this study have been
questioned.  Consequently, the relative proportions of these two
constituents may not be able to be compared at each dose level.
A discussion of the formation of DNA-HCHO adducts as studied in
this experiment may be found in section 4.5.2.4.
                               4-51

-------
     Finally, no data exist to show that other than a constant



proportion of HCHO reaches the respiratory epithelium at



concentrations below 2.0 ppm, levels that are generally not



acutely toxic to the underlying cells.  At higher concentrations,



above the acute toxicity threshold, it is reasonable to expect



that higher, nonconstant proportions of HCHO reach the underlying



cells because of damage to and eventual destruction of the



mucociliary clearance system.



4.4.3.3.   Conclusion



     In conclusion, it is consistent with some of the data



described above to assume that HCHO's irritant and cytotoxic



properties may have contributed to the nonlinearity of the



malignant tumor response seen in the Kerns et al. (1983) study.



HCHO's demonstrated ability to increase cell turnover could



provide greater opportunity for HCHO to interact with nuclear



material.  As the concentration of HCHO increases, greater cell



proliferation and cell death occur which provide even more



opportunities for HCHO-DNA interactions.  To what degree the



mucous layer protects against HCHO's cytotoxic effects is not



clear, but the experimental data do .suggest that it does play a



role.  Although data show that HCHO reacts with  protein in the



mucous layer/ data have not been developed to show that the ratio



between the airborne concentration and the amount entering tarqet



cells is nonlinear.  Regarding the impact of changes in



respiratory response to sensory irritants, it is likely that this



response is responsible for the different response of rats and
                               4-52

-------
mice in the Kerns et al. (1983) study.  Also, other data
presented by Swenberg et al. (1983) indicate that rats only
inhaled twice as much HCHO at 15 ppm as they did at 5.6 ppm,
which indicates that the dose-response curve may be even steeper
when target tissue dose is plotted rather than concentration.
     It seems likely that many of the factors outlined above have
contributed to the differences seen among species in their
response to HCHO as well as the steep dose-response seen in the
Kerns et al. (1983) study.  However, an examination of the data
described in the sections above (1) does not support the concepts
that the action of the mucous layer presents a barrier to HCHO or
that it causes a nonlinear relationship between air
concentrations and the amount reaching target cells at levels
below overt acute toxicity, (2) that the appearance of and
severity of noncancer lesions can be used to predict the nature
of the  cancer response, and (3) that the appearance of
noncancerous lesions is a necessary prerequisite for cancer
induction.
4.5.   Metabolisa and Pharmacokinetica
4.5.1.    Absorption
     HCHO can enter the body as a result of inhalation,
ingestion, or dermal absorption.  Absorption of HCHO through the
upper respiratory tract in dogs has been estimated to exceed 95%
of the  inhaled dose (Egle, 1972).  Nasal deposition in rats in
excess of 98% has been reported (Dallas et al., 1985).  Studies
bv Heck et al. (1983) indicate that most of the radiolabel from
                               4-53

-------
radiolabelled HCHO inhaled by rats was found  in  tissues  from thg-



anterior portion of the nasal cavity (the concentration  was 10-



100 fold greater than other tissues).  Radiolabel was found in



other tissues, but it is unlikely given HCHO's rapid metabolism



that the radiolabel found was HCHO. In another study by  Heck et



al. (1982a), the quantity of HCHO was measured in rat tissue



before and after inhalation of HCHO or chloromethane.  The



analytical method used cannot distinguish between free and bound



HCHO.  Measured HCHO concentrations were as follows;  0.42 umol/g



for nasal mucosa, 0.097 umol/g for brain, and 0.20 umol/g for



liver.  Inhalation of 6 ppm HCHO for 6 hrs/day for 10 days did



not significantly alter the nasal mucosa, brain, and liver HCHO



concentrations.  A study by Bogdanffy et al.  (1985) demonstrated



that nasal mucus reacts rapidly with HCHO, and suggests  that the



main binding constituent in nasal mucus is albumin.



     Following oral exposure of dogs to HCHO, formate levels in



the blood increased rapidly, indicating rapid uptake and



metabolism (Malorny et al., 1965).  Dermal absorption has been



demonstrated in guinea pigs (Usdin and Arnold, 1979), but does



not appear to be significant in comparison to inhalation or



ingestion.  Studies have also demonstrated the dermal absorption



of [  C] HCHO in rats and monkeys, and rabbits (Ulsamer  et al.



1984).  The chemical form of the radiolabel has  not been



determined, but it has been reported by Ulsamer  et al. (1984)



that data from in vitro diffusion studies using  rabbit skin



indicate that free HCHO cannot be detected enzymatically.
                               4-54

-------
      In  a  study  by  Bartnik  et  al.  (1985),  the  percutaneous
absorption of HCHO  was determined  by applying  [  C] HCHO-
containing cream  (0.1% HCHO) to  the backs  of rats.  Over 70% of
the radiolabel was  found  in the  treated skin,  2.3% in urine, 1.8%
in the carcass,  0.7%  in feces, and 1.3%. in C02 after 48 hours.
Thus  total percutaneous absorption was  6.1% of the applied
dose.  However,  some  fraction  of this number may represent
methanol or formic  acid which  was  present  in the radiolabelled
sample (2 and 3%, respectively).   Similar  results were obtained
by Robbins et al. (1984)  using rabbits  to  which 14C-labelled HCHO
was applied as a solution under  an occluded patch.
Concentrations up to  37 ug HCHO  per patch did not significantly
alter the proportion  absorbed.   When *4C-labelled DMDHEU
containing cloth was  applied to  the backs of rabbits under
various occlusion/perspiration conditions, only insignificant
amounts of the radiolabel penetrated the epidermis.  Even under
the most severe test  condition, only 2.5% of the radiolabel was
transferred from the cloth to  the animal of which 80-90% was
found in the skin directly under the patch.
4.5.2.   Pharmacokinetics
4.5.2.1.    Conversion to  formate
     HCHO that enters the body appears  to  be converted rapidly to
formate and C02 (Malorny et al., 1965; McMartin et al., 1979) or
to combine with tissue constituents.  The conversion of HCHO to
formate occurs following  intravenous (i.v.) infusion,
subcutaneous injection, gastric  intubation, or inhalation.
                               4-55

-------
Studies using i.v. infusion of 0.2M HCHO to dogs have shown



only a small amount of HCHO appears in the plasma during exposure



(Malorny et al., 1965).  This becomes undetectable within  1 hour



after cessation of infusion.  The peak formate concentration



following HCHO infusion was the same as when formate (0.2M)



itself was infused.  The plasma half-life for formate (between 80



and 90 min.) was also similar.  In the same study, HCHO could not



be detected after oral administration of 0.2M HCHO, although



formate increased rapidly in the plasma with a half-life of 81.5



minutes.



     Similar experiments using Cynomolgus monkeys, in which 0.2M



HCHO was infused i.v., showed no accumulation of HCHO in blood



(McMartin et al., 1979).  The blood half-life was estimated to be



1.5 minutes.  Similar half-lives for blood HCHO have been



observed in rats, guinea pigs, rabbits, and cats (Rietbrock,



1969).  Studies by Heck (1982b) have shown that [14C] formate and



[14C]  HCHO have similar distribution patterns in rat blood cells



and plasma following i.v. injection, and follow the same decay



curve.  In a somewhat different experiment, McMartin et al.



(1979) administered C14-labelled methanol by gastric



intubation.  Again, HCHO could not be detected in the blood



although formate levels increased rapidly.  A study in which



humans were exposed to HCHO gas (0.78 mg/m3) for 3 hours also



demonstrated a rapid rise in blood formate levels (Einbrodt et



al., 1976).  Gottschling et al. (1984) studied a group of



veterinary medical students exposed to HCHO.  An examiniation of
                               4-56

-------
pre- and  post-exposure urine samples did not  indicate a formic



acid shift.   In a more recent study by Heck et al.  (1985), HCHO



concentrations  in the blood of  rats and humans were



investigated.  The rats  (8 exposed and 8 controls) were exposed



to approximately 14.4 ppm HCHO  for 2 hrs.  Blood was collected



immediately after exposure and  analyzed by gas chromatography/



mass spectrophotometry.  No significant differences were seen



between exposed and control rats.  Six human  volunteers (4M, 2F)



were exposed  to 1.9 ppm  of HCHO for 40 minutes.  Venous blood was



analyzed  for  HCHO levels before and after exposure.  There was



not a statistically significant effect of exposure on the average



HCHO blood concentrations of the volunteers.  However,



significant differences  were seen in some of  the subjects'



(either decrease or increase) HCHO concentration between blood



taken before  and after exposure.



     The  rapid conversion of. HCHO to formate  occurred in many



tissues in the various species  examined, including human



erythrocytes  (Malorney et al.,  1965), liver and brain; sheep



liver; rat brain, kidney, and muscle, rabbit  brain; and bovine



brain and adrenals (Uotila and  Koivusalo, 1974).  The enzymes



involved  have been studied by Strittmatter and Ball (1975) as



well by Uotila and Koivusalo (1974).  The oxidative process is



initiated by  formation of S-formyl glutathione, which is then



oxidized  by NAD and finally cleaved by thiol  esterase, releasing



formic acid and glutathione.  HCHO also has been reported to be
                               4-57

-------
oxidized to formic acid by a nonspecific aldehydehydrogenase ana
through the tetrahydrofolic acid pathway (Huennekens and Osborn,
1959).
4.5.2.2.   Reaction with Glutathione
     The intracellular level of glutathione  (GSH) affects  the
metabolism and toxicity of HCHO.  In a study by Ku and Billings
(1984), the relationship between HCHO metabolism and toxicity and
GSH concentration in isolated rat hepatocytes was investigated.
When hepatocytes were pretreated with diethyl maleate (DEM) to
deplete GSH, the initial rate of HCHO disappearance was decreased
approximately 50%.  The concentration of HCHO used (5.0 mM) was
not toxic to OEM-treated or untreated cells.  Thus cell viability
was not a factor.  HCHO was also shown to decrease GSH
intracellular concentration in a dose and time-dependent
manner.  DEM treatment followed by HCHO addition caused a  similar
reduction in GSH concentrations even though  DEM pretreatment
resulted in varying GSH concentrations.  In  studies measuring  the
cell toxicity of HCHO, it was found that DEM pretreatment  greatly
decreased cell viability, whereas HCHO treatment alone did  not
after 60 minutes.  When DEM was added to incubations containing
HCHO, toxicity was increased at all incubation times.  Only .at
120 minutes was there substantial toxicity  in the HCHO only
treatment group.  DEM/HCHO treatment increased lipid neroxidation
at HCHO concentrations which decreased cell  viability in other
studies.  DEM alone had no affect on lipid  peroxidation.   To
determine if the enhanced toxicity is due to DEM treatment  and
                               4-58

-------
consequent reductions  in GSH concentrations, L-methionine was
added to DEM/HCHO treated cells.  L-methionine treatment reduced
reduction in GSH concentration and prevented HCHO stiumulation of
lipid peroxidation and loss of cell viability.  Thus, enhanced
toxicity can be traced to the effects of DEM on GSH
concentrations.  As a further check on this hypothesis, the
addition of free radical scavengers, ascorbate, BHT, and
  -tocopherol protected the cells from HCHO induced toxicity in
DEM-pretreated cells.  On the contrary, the addition of
scavengers had no effect on HCHO-induced toxicity in the absence
of DEM treatment, which suggests a non-free-radical mode of
toxicity.
     In studies using isolated, perfused rat lungs and  livers,
Ayres et al. (1985) reported dose-related reductions in GSH
concentrations.  However, the concentrations needed to
significantly reduce GSH levels are many times higher than those
expected in the environment.  Studies by Heck et al. (1980) and
Casanova-Schmitz et al.(1984) indicate that carcinogenic
concentrations of HCHO in the rat (15 ppm) did not reduce
nonprotein sulfhydryl levels in rat nasal tissue or produce
plasma HCHO levels approaching the lowest HCHO concentration
causing GSH depletion in isolated lung/ liver.  Thus, GSH
depletion does not appear to be a critical factor in HCHO-related
toxicity (Ayres et al., 1985).
     The role of GSH depletion on the formation of DMA-protein
cross-links (DPX) has been reported by Casanova-Schmitz and Heck
                               4-59

-------
(1984, 1985).  It was found that when GSH levels were depleted by



phorone/ increases in interfacial (IF) DNA (a measure of DPX) and



the concentration of DPX in isolated DNA were observed.  The



yield of DPX was reported to increase nonlinearly with HCHO



concentration for both normal and GSH depleted rats.  In



addition, DPX yields were greater at low HCHO concentrations in



GSH depleted rats indicating that the metabolism of HCHO at low



concentrations may be more effective (the significance of the



reported nonlinearity in the formation of DPX is discussed in



section 4.5.2.4).  However, a study by Lam et al. (1985) reported



that the concentration of nonprotein sulfhydryls in rat nasal



mucosa was not significantly reduced at 6 or 15 ppm HCHO, which



indicates that HCHO's toxic effects at these levels are not



related to GSH depletion.



4.5.2.3.   Conversion to C02 and other metabolites



     Additional studies (DuVigneaud et al., 1950) have shown that



following subcutaneous administration of 14C-HCHO to rats,



approximately 81% of the radioactivity was found in choline.




Almost 60% of a subcutaneous dose of 14C-formate appeared as




*4C02» with small amounts of radioactivity in choline.  Neely



(1964) administered radiolabelled HCHO intraperitoneally (i.p.)



to rats and found that 82% of the radiolabel was recovered as C02



and 13-14% as urinary methionine, serine, and a cysteine



adduct.  At lower doses, only radiolabelled methionine was



formed.  The author postulated that C02 was derived from serine



(formed from glycine and N5,N10 methylene tetrahydrofolate) by
                               4-60

-------
deamination  to  pyruvate  and  oxidation  in  the  Krebs  cycle.   In  a
study by Mashford and-Jones  (1982),  it  was  found  that  in rats
administered  4  mg/kg of  radiolabelled  HCHO, most  was exhaled
within 48 hrs as C02;  5.5% was  found in the urine.  At a dose  10
times higher  (40 mg/kg),  78% was exhaled  as C02 after  48 hrs,
while 11% was found in the urine.  When HCHO  was  administered  to
rats by inhalation, 40%  of the  radiolabel was  found in tissues,
40% was exhaled, and 20%  appeared in the  urine (Heck,  1982b).  It
was found by  Heck (1983), chat  the greatest amount  of  radiolabel
in the rat nasal mucosa  was  found in RNA, with a  lesser amount in
protein and a small amount in DNA.
     In a study of the disposition of HCHO  in mice, Billings et
al. (1984) found that  70-75% of i.p. injections of  6 mg/kg  or  100
mg/kg of 14C-HCHO was exhaled as C02 within 4 hours, with an
additional 10%  exhaled at the end of 24 hours.  When the rates of
C02 excretion between mice dosed with  100 ug/kg HCHO or 100 mq/kg
formate were examined, it was found  that  the  rate of C02
excretion in mice given  HCHO was slower than  the  formate-dosed
mice.  Since  formate is  an intermediate in  HCHO oxidation,  the
authors speculated that  HCHO might accumulate  in  tissues.
However, subsequent testing did not  bear  this out.  Robbins et
al. (1984),  using rabbits found the  following distribution  of
radioactivity 48 hours after intravenous  injection  of  ^4C-HCHO:
blood 1.58%; skin/muscle/organs 3.26%;  urine  4.14%; and 37.03% in
co2
                               4-61

-------
     The formation of methionine from   C-HCHO and homocysteine

had previously been demonstrated by Berg (1951).  Formation of

methionine would also account for the labelled choline observed

by Duvigneaud et al. (1950) via methylation of phosphatidyl

ethanolamine.  More recent work by Pruett et al. (1980) has

demonstrated the incorporation of *4C-HCHO into the nucleic acid

and protein fractions of WI 38 human diploid fibroblasts.  Most

of the radiolabel was found in RNA with lesser amounts in DNA and

protein.  The purine bases of both DNA and RNA were most heavily

labelled.

     In addition to the serine pathway to CO, postulated above

(Neely, 1964), two other pathways have been identified, and are

diagrammed in Figure 4-4.
    Figure 4-4.  Simplified reaction sequence from drug
    N-demethylation (cytochrome-P-450-dependent monooxygenase
    to HCHO, formate, and CO, production (from Waydhas et al.
    1978).  Reactions are:  la, HCHO dehydrogenase (GSH);
    Ib, aldehyde dehydrogenase; Ic, catalase  (peroxidatic
    mode)? 2a, 10-formyltetrahydrofolate synthetase; 2b,
    10-formyltetrahydrofolate dehydrogenase;  2c, catalase
    (peroxidatic mode).
                               4-62

-------
     Waydhas et al. (1978), McMartin et al.  (1977), and  Palese
and Tephyl (1975) have demonstrated that the catalase reaction
(Figure 4-4) is not of major  importance and  that the primary
pathway to CC^ from formate occurs via the tetrahydrofolic acid
pathway.  This has been demonstrated in rat  liver perfusates
(Waydhas et al., 1978) monkeys (McMartin et  al., 1977), and rats
(Palese and Tephly, 1975).  Since the tetrahydrofolic acid
pathway (Figure 4-5, from Kitchens et al., 1976) can lead to the
transfer of the carbon from formate to a number of other
compounds (including serine), it is not clear that the
10-formyltetrahydrofolate dehydrogenase reaction (Figure 4-4)  is
the only reaction of importance for C02 production in this
pathway.
                               4-63

-------
             Glycln*
               I
            ATP
                       V
               ineslnlc
               acid and
                pur In«*
          ATP T        ^
  S«rln«
                                        Glyclns
                                     NAOPH  HfOf
                                                n5-'°FM
                                                Xl
                                               FM2
ThymidylIc
                                                                     HemecystAln*
                                                                  VIT.  a
                                                                        12
M«m I on I n«
   and
                 tcld
«<4 • N>0«for«yir«rrahy4retelle acid
H4 • N**f«rvrir«fr«nr«ro*olle acid
    4»N',Mt0-«»th«rtylt«fr«ftydro*olle acid
    • N' •fernlalnetctrahydrefelle acid
     • w'.N10 -«n«tnyl«n«T«tranydrofoNc acid
Figure 4-5.   Tetrahydrofolic acid  pathway  and  1-carDon
transfer  for  HCHO raetaoolism.
                                  4-64

-------
 4.5.2.4.   Reactions with Macromolecules
     Besides being converted  rapidly  to C02 and  formate, and
 being incorporated into other chemicals, HCHO can alkylate
 macromo lecules such as amino  acids, proteins, nucleotides, RNA
 and DNA- (LJlsamer et al., 1984; Casanova-Schmi tz  and Heck, 1983,
 1984; Consensus Workshop on Formaldehyde, 1984;  Mizenina et al.,
 1984; Solomon and Varshavsky, 1985; Schouten, 1985; Foekens,
 1985).
     A recent study by Casanova-Schmitz et al. (1984) has
 reported the difference between metabolic incorporatin and
 covalent binding in the labelling of  macromolecules in rat nasal
mucosa and bone marrow by inhaled  [*4C]- and [^Hj HCHO.  Rats
were exposed to labelled HCHO at concentrations  of 0.3, 2, 6,  10,
or 15 ppm for 6 hrs, one day  following a single  pre-exposure to
 the same concentration of unlabelled  HCHO.  The  difference
between metabolic incorporation and covalent binding was
determined by the use of a phenol extraction procedure.  This
procedure allows the separation of macromolecules into phases
after centrifugation (aqueous (AQ), organic, and interfacial (IF)
phases).  DNA can be recovered from both the AQ  and IF phases.
The convalently bound DNA is  recovered from the  IF phase.  In.
 this way, the authors claim that the  relationship between
metabolically labelled DNA and cross-linked DNA  can be
determined.  The principal finding reported by the authors was
 the apparent nonlinearity in  the amount of covalent binding of
HCHO to DNA of the respiratory mucosa.  The amount of HCHO
                               4-65

-------
covalently bound to mucosal DNA at 6 opm was  reported  to be  10.5

times higher that at 2 ppm, whereas covalent  binding to protein

(intra- and extracellular) increased, in a  linear manner with

increases in HCHO concentration.  No covalent binding  was noted

in tissues from the olfactory mucosa or bone  marrow.   The

apparent nonlinear covalent binding of DNA between 2 and 6 ppm

has been used as an input  in quantitative  estimation of risk from

HCHO exposure (Starr and Buck, 1984).

     The Casanova-Schmitz  study has been reviewed by Cohn et al.,

1985,  EPA,  and the Science Advisory Board  (SAB) (1985).  Its

implications for quantitative cancer risk  assessment have also been

addressed.   Cohn et al. came to the conclusion that the data were

interesting but preliminary in nature and  thus not useable as inpta

to quantitative risk assessment.  The SAB  is  composed  of a group of

non-EPA scientists who advise the Administrator of EPA regarding the

scientific adequacy of agency risk assessments, testing and

assessment guidelines,  research proposals, etc.  The Agency  agreed

with the SAB to seek a review of the study by an independent group

of scientists.  The group's report to EPA  (Report No.  TR-835-20,

Expert Review of Pharmacokinetic Data:  Formaldehyde)  is provided in

Appendix 1 and is summarized by the group  as  follows:

    1.    Some doubt still  remains as to the validity of the
         assumptions which form the basis  for distinguishing
         metabolically incorporated and crosslinked (or adducted)
         CH20, i.e., ^H/14C in DNA.

    2.    Experimental methods and controls were adequate with
         respect to monitoring the C^O administration and
         analysis of dual-labeled materials.  However, the
         chloroform/iso-amylalcohol/phenol extraction  for DNA and
         DNA crosslinked to proteins was not  validated in terms


                               4-66

-------
         of  the  identities of materials separated  nor  the overall
         efficiency and consistency of extraction.  The
         occurrence of underlying variability of  incorporation
         due to  kinetic isotope effects on the disposition of
         tritiated CH20 can neither be assessed nor discounted.

     3.   Sufficient documentation is still unavailable to state
         unequivocably that all the crosslinked DNA-protein
         complexes occur in the IF-DNA fraction.

     4.   There remains a need for an effective biochemical
         dosimeter to measure the dose of CF^O delivered to the
         cells of the nasal epithelium.  The data  provided by
         Casanova-Schmitz et al. are not considered a
         sufficiently well-validated measure of this parameter.

     5.   The nonprooortionality of the calculated  concentration
         of bound i^C (CH20)-DNA as a function of  the
         administered dose is documented adequately.   Whether the
         nonproportionality truly reflects crosslink formation or
         is due  to the small sample size, to a constant loss in
         the recovery of IF-DNA, or to artifactual disturbances
         in the  JH/iqC ratio remains to be elucidated.

     6.   The increase in concentration of bound    C with the
         concentration of CH^O is well documented, as  is the
         increase in the difference in the -3H/-1>4C  ratio between
         IF-and AQ-DNA.  The power of separate comparisons for
         the 0.3 and 2 ppm doses is low because of small sample
         size relative to the coefficient of variation.  This
         limits  the potential for inferences about no-response
         levels and low-dose extrapolations.

     7.   The study of Casanova-Schmitz et al. is an important
         first step toward quantitative assessment of  the
         intracellular level of Cf^O in the nasal  mucosa of the
         rat following inhalation exposure.  At its present level
         of validation, however, it does not provide a basis for
         such quantitation.  Furthermore, the selection of an
         acute study model may not be appropriate  to the
         assessment of chronic toxicity.

     In response to the report, the Chemical Industry  Institute

of Toxicology (CUT) submitted detailed comments which strongly

disagree with the expert groups conclusions.  CIIT's comments are

provided in Appendix 1.  As with many emerging areas of

investigation there are bound to be disagreements  among
                               4-67

-------
scientists.  This is one of those cases.  Additional work



underway at CUT using primates may resolve areas of



disagreement.  Until the issues raised concerning the Casanova-



Schmitz study are resolved/ this study will not be used as a



basis for an alternate measure of HCHO exposure.



4.5.2.5.   Endogenous HCHO



     Endogenous HCHO is primarily produced from the degradation



of serine with some contribution from the degradation of other



amino acids.  Oxidative demethylation of N,N-dimethylglycine



(from choline degradation) also contributes significantly to



endogenous HCHO.  HCHO is also produced from a wide range of



xenobiotics (Dahl and Hadley, 1983).  Cytochrome P-450-dependent



N-demethylation of drugs can contribute HCHO.  Other xenobiotics



including dihalomethanes, methanol, dimethylnitrosamine,



hexamethylphosphoramide (HMPA), bis(chloromethyl) ether (BCME),



dibromoethane, and dimethylsulfoxide lead to the production of



HCHO.  HCHO is also formed in vitro in the presence of an amine



acceptor, apparently by nonenzymatic breakdown of



N ,N* -methylene-tetrahydrofolate.  This reaction produces



alkaloids from biogenic amines or drugs in vitro and probably in



vivo.  The role of HCHO in xenobiotic transformation has also



been studied (Kucharczyk et al., 1984).



     Whereas the conversion of HCHO to C02 occurs in a similar



manner in the different species studied, the relative importance



of each reaction differs among species and tissues.  Thus, the



rat is able to convert formate to C02 at more than twice the rate
                               4-68

-------
of monkeys (or humans) and, as a  result, has  lower blood  formate



levels  (McMartin et al./  1977) and does not excrete  formate in



the urine (Neely, 1964).  Man additionally possesses  50%  more



hepatic dehydrogenase than do rats (Goodman and Tephly, 1971).



Den Enge'lse et al. (1975) have shown that mouse (C3Hf/A)  and



hamster (Syrian golden) lungs do  not convert  formate  to CC>2 as



efficiently as liver tissue does.



4.5.3.   Summary



     In summary, free HCHO is not usually found in plasma or



other body tissues in measurable  quantities (this may be  a



function of the analytic  technique and not necessarily the



absence of free HCHO), endogenous HCHO that is produced may be



reasonably presumed to be metabolized rapidly to formate  or to



enter the one-carbon pool.  When  exogenous exposure occurs, HCHO



is likewise rapidly metabolized to formate and excreted,



converted to C02 and/or incorporated into other molecules.  The



same pathways seem to occur in all mammalian  species  examined to



date,  but reaction rates differ among various species and



tissues.  Neither the ratio of metabolic deactivation to  binding



(to tissue or small molecules) nor the effect of route of



exposure on this ratio is known with assurance at this time.



However, Casanova-Schmitz et al.  (1984) have  made an  important



contribution in this area.  Eqle's work (1972) suggests that the



respiratory tract tissues would receive the greatest  dose.



Although effects at other body sites cannot be ruled  out, the



weight of the evidence indicates  that effects at sites distant



from the area of exposure would not be expected.
                               4-69

-------
      The overall metabolism of HCHO  is  summarized  in  Figure  4-6

  !adopted from Kitchens et al., 1976):
?rot«ia« tad Kucltic Acids
   Hucitic Acids
   Labii* a»thyl group*
and on« carbon oatibolin
                                       Urina  44 Sodiua S*lt
     Figures 4-6.  Overall metabolism of HCHO  (from  Kitchens
     et al., 1976).

      As can be seen from Figure 4-6, HCHO is  more chemically

 active than any of its direct metabolites and would,  therefore,

 appear to be the chemical substance of most concern for

 carcinogenicity.  The possibility exists, that  the  actual

 carcinogenic agent may be an amino HCHO-acid  (or other)  adduct

 (EPA, 1981).

 4.6.   Structure-Activity Relationships

      HCHO is structurally similar to other aldehydes  such  as

 acetaldehyde,  malondialdehyde and glycidaldehyde.   These

 aldehydes have been shown to have oncogenic activity  in

 laboratory animals.  For instance, inhalation of acetaldehyde has

 produced tumors of the nose and larynx in hamsters  and tumors of


                                4-70

-------
the nose  in rats, and glycidaldehyde has produced skin  tumors  in
mice in skin painting tests.  Since acetaldehyde is the closest
in structure to HCHO, and  its effects on animals have been
compared  in a previous section, the significant studies related
to its oncogenic potential will be described.
     Acetaldehyde was not mutagenic in the standard Ames test
using Salmonella typhimurium (Commoner, 1976) and Escherichia
coli WP2uvrA (Hemminki et al., 1980).  It had weak mutagenic
activity  in the fruit fly Drosophila melanogaster (Rapoport,
1948).  The potential of acetaldehyde to damage chromosomes has
been indicated by the dose-dependent sister chromatid exchanges
in the Chinese hamster ovary cells (Obe and Ristow, 1977) and
human lymphocyte cells (Ristow and Obe, 1978).
     The carcinogenic effects of the inhalation of acetaldehyde
vapor were studied in hamsters by Feron (1979).  A group of 210
male hamsters, which were further divided into six subgroups of
35 each, were exposed to 1500 ppm acetaldehyde vapor (7 hr/day, 5
days/wk) alone or simultaneously with benzo(a)pyrene (BP) as a
weekly intratracheal injection for 52 weeks.  The weekly
concentrations of BP used were 0.0625, 0.125, 0.25, 0.5, and 1.0
mg/animal.  The maximum dose of BP administered throughout  the
entire experiment was 52 mg/animal.  A group of 210 control
animals were exposed to air alone or simultaneously with the same
concentrations of BP.  At the end of the treatment period,  5
randomly selected animals from each group were killed and
autopsied.  All remaining animals were allowed to recover for  20
weeks and sacrificed by week 72.
                               4-71

-------
     Exposure of hamsters to 1500 ppm acetaldehyde vapor produced



abnormalities in the respiratory tract which were characterized



primarily by reversible hyperplastic/ metaplastic, and



inflammatory changes.  Neoplastic alterations attributable to



acetaldehyde exposure alone were not found.  Intratracheal



instillation of the highest dose of BP (52 mg, 1 mg/wk for 52



weeks) combined with inhalation of acetaldehyde produced twice as



many tracheal tumors (squamous cell carcinoma and squamous



adenocarcinoma) and a shorter latent period as intratracheal



instillation of BP alone.  However, such a synergistic effect of



acetaldehyde was not noticeable at any of the lower BP levels.



No significant differences in the number of tumors in the larynx,



bronchi, bronchioles, or alveoli were found among the different



treatment groups.



     In a separate experiment, groups of 35 male and female



hamsters were treated intratracheally with acetaldehyde for a



period of 52 weeks.  The intratracheal instillations were given



either weekly or fortnightly with acetaldehyde (2% and 4%) alone



or in the presence of either BP (0.25% and 0.5%) or



diethylnitrosamine (DEN, 0.5%), two proven carcinogens.  Interim



sacrifices of 3 animals/sex/group were performed after 13, 26,



and 52 weeks.  All remaining animals were sacrificed after 104



weeks.



     Intratracheal administration of acetaldehyde at both dose



levels caused severe hyperplastic and inflammatory changes in the



bronchioalveolar region of the respiratory tract; however, only
                               4-72

-------
one case of pulmonary adenoma was  found out of  134 animals
treated with acetaldehyde alone.   This is not considered to be an
indication of carcinogenic activity of acetaldehyde.  Despite the
high degree and frequency of peribronchiolar adenomatoid lesions
found following intratracheal instillation of acetaldehyde, the
neoplastic response of the bronchioalveolar tissues was clearly
lower in animals treated with BP plus acetaldehyde than in those
given BP alone.  Thus, acetaldehyde inhibited the effect of BP.
Similarly, the carcinogenic effect of DEN was also not influenced
by the treatment with acetaldehyde.
     In another study, Feron et al. (1982), studied respiratory
tract tumors in male and female hamsters exposed to high
concentrations of acetaldehyde vapor alone or simultaneously with
either benzo(a)pyrene (BP) or diethylnitrosamine (DEN) were
studied.  The animals were exposed 7 hrs/day, 5 days/wk for 52
weeks to an average concentration  of acetaldehyde of 2500 ppm
during the first 9 weeks; 2250 ppm during weeks 10-20; 2000 ppm
during weeks 21-29; 1800 ppm during weeks 30-44; and 1650 ppm
during weeks 45-52.  Animals exposed to air or air plus BP or DEN
served as controls.  Following the 52-week treatment period,
there was a 29-week recovery period after which all hamsters were
killed for autopsy.  All remaining animals were sacrificed after
31 weeks.
     At the end of the exposure period, (i.e., at week 52)
distinct histopathological changes, similar to those of the
previous studies, were found in the nose, trachea, and larynges
of animals exposed to acetaldehyde.  No tumors were found in
hamsters killed immediately at the end of the exposure period.
                               4-73

-------
     Acetaldehyde-exposed animals which were found dead or
sacrificed at week 81 exhibited inflammatory, hyperplastic, and
metaplastic changes in the nose and larynx, suggesting a
persistence of those alterations.  Tumors were encountered in the
nose (adenoma, adenocarcinoma, anaplastic carcinoma) and the
larynx (papilloma, carcinoma in situ, squamous cell carcinoma,
adeno-squamous carcinoma); animals exposed to acetaldehyde plus
BP or DEN also exhibited tumors of the trachea and the lung.   The
neoplastic and nonneoplastic lesions in the larynx were mainly
located either on the true vocal folds or in the most anterior
part of the larynx.  None of the animals exposed to air alone
demonstrated nasal or laryngeal tumors nor atypical laryngeal
hyperplasia and metaplasia.  The incidence of nasal and laryngeaj
tumors in hamsters exposed to acetaldehyde and treated with
either BP or DEN was similar to that found in hamsters exposed to
acetaldehyde alone.  Carcinomas in situ and squamous cell
carcinomas of the larynges were found after combined treatment,
but were not observed after treatment with either BP or DEN
alone.  Based upon these findings, the authors concluded that
"acetaldehyde is an irritant as well as a carcinogen to the nose
and larynx with a weak initiating and a strong 'promoting'
(cocarcinogenic) activity" (sic).
     Finally, in a study by Woutersen et al. (1985) male and
female Wistar rats were exposed to 0, 750, 1500, and 3000/1000
ppm of acetaldehyde for 6 hrs/day, 5 days/week for 27 months.
There were significant nonneoplastic lesions of the olfactory
                               4-74

-------
epithelium at each exposure level.  In contrast, significant



nonneoplastic lesions were seen in the respiratory epithelium



only at the highest dose.  Statistically significant numbers of



adenocarcinomas were observed at each dose level in males and



females.  Squamous cell carcinomas were observed at the two



highest dose levels in males and at the highest dose level in



females.  Most of the tumors originated from the olfactory



epithelium.  Table 4-12 presents summary tumor response of the



nasal cavity for this study.
                               4-75

-------
                                      Table  4-12.
                     Nasal and Larynqeal Cancer  in  Rats Treated  with
                        Acetaldehyde by Inhalation  for 27 Months
                             (Woutersen et al.  1985)
Site and Tumor Type
                                               Incidence a
                                  Males

                           Acetaldehyde (ppm)

                          U     750    1500    3000
                                         Females

                                    Acetaldehyde (ppm)

                                  0     750    1500    3000
Nose

  Papilloma

  Adenoca rc i noma

  Carcinoma in situ

  Squamous cell
  carcinoma
0/49   0/52

0/49  16/50b

0/49   0/49
1/49
  Metastasizing         0/49
  squamous cell carcinoma
1/49

0/49
 0/53    0/49     0/50

30/53b  20/49b    0/50

 0/53    1/49     0/50


10/53b  l4/49b    0/50

 0/53    1/49     0/50
        1/48   0/53    0/53

        6/48c 26/53b  20/53b

        0/48   3/53    5/53


        0/48   5/53   17/53b

        0/48   0/53    0/b3
Larynx

  Carcinoma in situ
0/49   0/49
        0/53
         0/49
0/50
0/48   1/53
0/53
a Incidence is expressed as the number of animals with tumors over the number
  of animals examined.
    |0.0

-------
4.7.   Epideaiologic Studies  Reviewed

4.7.1.   Introduction

     The EPA has reviewed the available cohort and case-control

studies  related to formaldehyde.  Many of these studies have been

released within the past three years.  Only one study is

currently ongoing which relates to evaluating human risks

associated with formaldehyde exposure  a case-control study of

nasal cancers by the Centers for Disease Control.  Only cohort

and case-control designed studies were analyzed for this review

since they yield the best quality of information for judging

causality.  Table 4-13 identifies these studies.  Although these

studies are of optimal designs for evaluative purposes, many

studies suffer from limitations that can potentially influence

their conclusions.   Major drawbacks are: (1) the inference of

formaldehyde exposure levels from industrial hygiene data;

(2) the inability to completely separate the contributions of

HCHO from the contributions of other occupational or personal

exposures; (3) small sample sizes for the cohort studies;

(4) small numbers of observed site-specific deaths: and

(5) insufficient follow-up.

     One outcome of the design limitations is low statistical

power in each study to detect small relative risks for rare for.r.s

of cancer.*  The ability of a well-conducted study to detect -an

increased risk depends upon sample size, years of follow-up,


*The power of a study is the ability to detect true
 association of the exposure and disease.  If a study is
 likely to conclude that the exposure is not associated with
 a disease,  when in fact an association existed, it has a low
 power for detecting that association.


                               4-77

-------
                                                                 Table 4-13
                                                  auniary of Studies Relevant Tb Ranraldehyte
   Type cf Stidy

 1. 3*
 2.

 3.

 4.

 5.  StK

 6.  SW.

 7.
 a
 9.
10.  £MR
11.
12.

13. R-R

14. EM*

15. EM*

16. EM*

17. EM*
Atlrr
        i  (19G2)
tferringtm and Srenrrn
 (1975)
larringtcn and Gates
 (1982)
levineet al. (1981)

Strop et al. (1981)

Wrg (1983)

Taberdav Associates
 (1982)
Adissmet al. (1984a)
      (1983)
Bsrtazzi et al. (1984)
Rlair et al.  (1986,
 1987)
Stayneretal. (1986)

W&lrath and Fkarcni
 (1983)
Walxath and FtciiiaiL
 (1984)
      (1983)
Ii<±>ling et al. (1984)

Stayer et al. (1935)
Study Qxip

Ehthologists


EfettologLsts

F&ttologists

Cntario nerticians (irale)

Aratcnists

QianicaL vgotters

Gianical vodexs

CharnkaL vortets
ChaniaaL waters
                     or
  U32TS
Qarcert. vcateis

N.Y. ertalners and
  fimetal direobccs
O^l i (i »ma
Qiamical voders (rrale)
            pxxicticn
  chankal vcckers
Gannait voders
              Ftefibtmt. Crop

a) U.S. vhite nale age and calendar year-
         ncrtality rates; b)  maters cf the
         Psychiatric Assxiaticn
Ireland, Wales cr Scotland male ag2 and
year iyars ffr- nortality rates
Ireland age-sex and calendar
ncrtality rates
U.S. vhite nale age and calendar
         ncrtality rates
                                                ExprBire
                                                /teent


                                                Ptsait

                                                ftsent
a) ESychiatrists; b) U.S. vhite naLe ag&-
qpecifjc nortality rates
U.S. age-sac and CRlmfer >ear-speci£k:
ncrtality rates
U.S. age-sex and nFQprrfo'" y^r-typr** f^r*
ncrtality rates
Mate ncrtality rates cf Qgland/foaLes
U.S. age-raoe-sex and calendar year
specific ncrtality rates
b&ticnal and Vx^d nale specific ncrtality rates
U.S. ae-raoe-sex and calendar yesc
         ncrtality rates
                                                Pkaant

                                                Ereaant
                                                ftsent
U.S. age-raoe-setc and caleidar
ncrtality rates
U.S. age-race and calenchr
prcporticr£ of dsaths
U.S. age-race and rqif»rir^f jear-spacifjc
prqxxticrB cf deaths
U.S. age-race-eeK and calendar year-
specific prqacrticns cf deaths
U.S. vhite nsLe -vf and calendar
year-specific prqpcrtians of deaths
U.S. age-race and calendar year-specific
prcporticfB of deaths
                                                Eresent

                                                Eresent
                                                tteent

                                                Asant

-------
                                                               Table 4-13 (art.)
4i


VO
Tffieaf Study

18. FM*

19. Gee-Central


20. Case-Central
21. Case-Central

22. Case-Control


23. G»se-Cantral

24. Gse-Gtntrol

25. CaserOntral

26. Case-Control

27.
28. Case-Control
        and Qaiffemen
 (1983)
F^etveather et ai.
 (1982)

Brintan et al. (1984a)
Tblaet al.  (1980)

Ibnterg et  al. (1983)


(artfell et al. (1982)

Osenet al. (1984)

layeset al. (1986)

Rushet al. (1985)

[fertertnet al. (1985)
      et al.
(1986a,b)
Study Qnap

Textile voters

Qiaidcal watkeos
t^bsal ard paranosal
sirus cancEsr casas
  in NCandXA
Isasal ard paramsal sioos
  CBIXET fftgpft in Finland
tfesal ardsincnasal carioar
nwK in Finland, SUeden,
  and Etniaric
isasal and
  canoer cases n
isasal and sincnasal mmer
  casas in Damadc
tfesal and sincrfisaL
  cases in FbLIand
SincnaBal and
  cancer in Qmacticut
FJaspLratoy canaer cases
  fixin a retroBiMctive
  cchxt of rale wooiorters
Sincnasal and ftaryngeal
  canaar in ViesMngbcn
                                                                         Qcckf
                                                                                                             Eata
U.S. age and caLendar yaar-e%ea.fic pnqpccticrB
of vhite fiaiale ctetJe
Che male aifdqee natched &ac ags,
ad >Btal aesvios cate, plant
locaticn and pa/ class
TWo hospital centrals cr cne hospital
control ard cne ffanaaofri ccrtioL
                                                                                                   ftsent

                                                                                                   Bresat:


                                                                                                   Bneeait
natched fix: age, sac, race, state,
eocnonic area of USLB! residence, and
>ear of hrpital adnissicn
Che rcn-respiratEay canoer control
natchscl fiar age and sex
Che rr>lmpr«-a1 rRpnar control
natchsJ &x age-ot-diayicBis,
sex and oxntiy
ffeferot gccup identifiei fron
previxus study (lardell et al. , 1981)
Calm, redbun, pxetate cr treast controls
iratxhed fir age-eex-^ear of cUagTcsis
Living and rbceasad populaticn controls

Ctntrols saiplsd frxjn Connecticut
death certificates
Three controls selecfai fron the ochort
and natched £r age

Controls sarpLed iron pcpulatkn
natchad fix age and sex
                                                                                                   Resent
                                                                                                   Hresent

                                                                                                   Present

                                                                                                   Breeent
                                                                                                   fresent
                                                                                                     Eteaent
aBqx)Sure levels are inferraJ fron industrial hygiene studies of similar voters.
          levels are infiarai fron rurtoer of ^ears erplx^«d in oocupatiai.

-------
magnitude of the increase, background incidence of  the disease,



desired statistical significance, and type of analysis.



     Several newly released studies have strengthened our



knowledge regarding the potential carcinogenicity of HCHO.  These




new studies have contributed stronger evidence and  suggest that



HCHO may be a human carcinogen.  In particular 9 studies  (Acheson



et al., 1984a; Blair et al., 1986, 1987; Hardell et al., 1982;




Hayes et al., 1986; Stayner et al., 1985; and Vaughan et al. ,



1986b) show among different groups statistically significant



associations between site-specific respiratory cancer and




exposure to HCHO-containing products.  Three of these studies



(Blair et al., 1986; Blair et al., 1987, Stayner et al., 1986;



and Vaughan et al., 1986a,b) were specifically designed to detect




moderate elevations in human risk.  In addition,  the Epidemiology



Panel of the Consensus Workshop on Formaldehyde (1984) and the



EPA (1984b)  examined a group of studies and concluded that a



group of professionals (anatomists, pathologists,  embalmers,  and



undertakers) have a significantly increased mortality from



leukemias and brain neoplasms.   These excesses in mortality can




not be attributed to diagnostic bias since these excesses remain



when other professional or like socioeconomic groups are used as




referents.
                               4-80

-------
4.7.2.  Review of Studies Overview and Discussion

     Twenty-eight studies (Table 4-13) of populations that may

have been exposed to HCHO have been reviewed.  Appendix 2

contains a description of each of the studies.  These studies

were of cohort or case-control designs.  Results were expressed

as Standardized Mortality Ratios or Proportionate Mortality

Ratios ** or as odds ratios***.  Eleven studies were of chemical

or industrial workers and seven studies were of medically-related

professions.  For medically-related professions, e.g.,

morticians, embalmers, anatomists, and pathologists, the exposure

was to formalin.  This group has diverse chemical exposures, but

formalin is one exposure which is common.  Ten other case-control

studies examined occupational etiologies of sinonasal cavity and

pharyngeal cancers.  Exposure in these studies was examined

directly by quantitating HCHO levels or indirectly through
**Standardized Mortality Ratios (SMR), from cohort studies, are
measures of the extent to which mortality in the exposed cohort
under study compares to the mortality experience among
unexposed persons.  An SMR divided by 100 is called a risk
ratio.  The SMR analysis uses death rates of a general
population to derive the expected number of deaths.
Proportionate Mortality Ratios (PMR) are measures in which the
cause-specific proportions of mortality among the exposed
(observed deaths) are compared to the expected proportion of
deaths among the unexposed (general population).  In the PMR
study, large excesses of deaths due to one cause can de'flate
the remaining proportions and can, thus, bias comparisons of
the other causes of deaths.
***The odds ratio (OR), from a case-control study, gives the
extent to which exposed individuals are represented among the
affected cases more than among the controls to whom they are
compared.  If the disease under study is rare, the odds ratio
is numerically very close to its associated SMR, but the causal
inference is not as direct.  In addition, an odds ratio
obtained from a case-control study nested within a cohort
design can be used to support conclusions from the cohort
study.


                               4-81

-------
particular occupations where HCHO exposure has been known to



occur.



     The sparsity of individual exposure data made it difficult



to separate formaldehyde from the other occupational or



residential exposures.  Table 4-14 shows that twelve studies have



exposure data for individual members of the study; 6 of these



studies (Acheson et al., 1984a; Blair et al. , 1986; Stayner et



al., 1986; Fayerweather et al., 1982; Partanen et al., 1985; and




Vaughan et al., 1986) have enough information to examine an



exposure-response gradient.  Other studies inferred exposure by



citing previous industrial hygiene data of similar occupational



groups.  This review used exposure estimates identified in EPA



(1984b) of similar occupations as a surrogate for those



epidemiologic studies where exposure levels were not




identified.  It is not known whether the individuals under study



did or did not have formaldehyde exposures at the levels



identified in EPA (1984b).   Table 4-14 presents exposure




estimates for occupations identified in this review.



     Each of the 28 studies has been evaluated with respect to



bias, confounding,  and chance.  Excesses,  both statistically



significant and not statistically significant, in site-specific



mortality have been emphasized in this review.  Deficits were



also noted.  Deficits are hard to interpret except when examining



therapeutic treatments.   Findings that are not statistically



significant are important in light of the small numbers of site-



specific neoplastic deaths  expected or observed in many of the



studies (usually fewer than 5 deaths).  Low statistical power is
                              4-82

-------
                                  Table 4-14
      Formaldehyde Levels to Which Occupational Groups Might Be Exposed
 Occupation
  Average
Formaldehyde
Level (ppm)
  Reference
 Embalmers
 0.3 - 0.9

 0.2 - 0.9

 0.1 - 5.3

 1.37 - 1.70
Levine, 1984

NIOSH, 1980

Kerfoot and Mooney,  ]

EPA, 1984b
Anatomists
 0.07 - 0.14
Stroup, 1984
Pathologists
 0.85a,  3.2*
EPA, 1984b
Resin Manufacturing


Textile Manufacturing

Apparel Manufacturing

Wood Furniture Manufacturing

Particleboard Manufacturing
 2.2  -  3.3
 0.24a,  1.40b

 0.70a,  0.42b

 0.64a,  0.23b

 0.10b,  1.30b

 0.33a,  0.31b
Bertazzi et al., 198!
EPA, 1984b

EPA, 1984b

EPA, 1984b

EPA, 1984b

EPA, 1984b
   Personal sample
b  Area Sample
                                    4-83

-------
 characteristic  of  several  studies.   The power  of  a study  is  the



 ability  to  detect  a  certain  level of risk.   Insufficient  follow-




 up and small  sample  sizes  in the cohort studies compound  to  low



 power through insufficient person-years and  through  cancers  not



 yet having  appeared.   Thus,  elevations  in  specific-site cancers




 in individual cohort studies  which are  not consistently observed



 across all  studies should  not be totally discounted  because  they



 are not  statistically  significant.   Likewise,  the  absence of rare




 cancers, e.g.,  nasal,  in all  cohort  studies  (except  Blair et al.,



 1986) may be  a  reflection of  power.   A  similiar situation may be



 observed in the case-control  studies.   Small numbers of cases for



 any given exposure lowers the detection  power.  Thus,



 associations  with a specific  neoplastic  site may not be



 consistently  observed  across  like exposures.




     The question of the validity of  multiple  comparisons always



 arises in an  examination of many studies and sites.  Twenty-eight



 studies have  been reviewed and to account for multiple



 comparisons by dividing a commonly accepted p-value by the number



 of comparisons yields  a stringent rejection value.  This



 rejection value will not be employed  for this review since its



 use would have the impact of diminishing the statistical power in



the 28 studies to detect a true positive.  As previously



 identified,  many of these studies already suffer from low




statistical  power.



     Tables  4-15 through 4-17 present power calculations for the



reviewed  studies.   Each table summarizes, by study design,



observed and expected numbers of deaths  for neoplasms of the
                              4-84

-------
                                                                            Ta b I e
                                                                                           Studies
      Study
                                           Size
     Matanoskl (1982)
        pathologist*
 1556
       pathologist*
                                          1439
oo
ui
    Levlne et al.  (1934)
       •ortIclans
H77
   Harrington and Shannon 
-------
       Harrington and (takes  (1984)
         •die pathologlsts
                                                                        Table 4-15 (cont.)
                                    2507
      Srroup (1984)
        anatomists
                                   2239
.£»
I
00
en
  (I98J)
che«lcal workers
2067
    Tabersnan Associates (1982)
       formaldehyde
       exposed
       chemical workers
                                  867
                                                buccal cavity and pharynx
                                                lung
                                               colon
                                               brain
                                                lymphopoietic
                                               leukemia
                                               nasal
         cavity and pharynx
   lung
   colon
   brain
   lymphopoietic
   leukemia
  nasal

  brain
  leukernI a

  buccal cavity and pharynx
  lung
 colon
 brain
 lymphopoietic
 leukemia
 nasal

 buccal cavity and pharynx
 lung
 colon
 brain
 lymphopoietic
 leukemia
nasal
NG
9
NG


2
0
12
20
10
18
10
0
II
1
8
NG
3
6
2
0
2
0
NG
3
NG
3
NG
0
NG
22.0
NG

1.2
3.0
I.I
0.,*
6.8
43.0
18.5
3.7
14.4
6.7
0.4
a
1.9
3.8°
NG
11.6
NG
1.6
4.4
0.6
NG
NG
5.2
NG
0.7
2.0
NG
NG

•41 i i
' 1.6
~" -• — _
•331
67 J.O
"»' 5.1
"'* 2.2
'28 1.4
'<» |.6
•271
'25 ,.a
148 2.2
8.0

•579
•212

OS i f.
"3 1.9
IBM A >
100 4. j
'* 2.6
308 7 ?
' • f.

58 2.4
'« 5.8
'« 4.0
-..

—
i.a


Jr
.5
6. 1
2.4
1.5
1.8
2.0
2.5
10.5

---

	
2.0
	
5.0
3.0
9.0

2.7
7.3
4.7
	

-------
                                                                       Table 4-15 (cont. )
oo
     Achason ut a I. ( I984a>
        chemical workers
    7716
       BIP plant
    Berta//! at al. (1985)
       formaldehyde
       exposed
       resin workers
    Blair et al.  a  (1986)
       formaldehyde
      exposed
      manufacturing and production
      workers
   4462
 26561
      Kith  20 years  latency*
  Stayner et al. (1986)
     garment workers
I 1010
    buccal  cavity  and pharynx
    lung
    colon
    brain
    lymphopoietic
    leukemia
   nasal

    lung
   nose

   boccal cavity and pharynx
   lung
   colon
   brain
   lymphopoietic
   leukemia
  nasal

  buccal  cavity and pharynx
  nasopharynx
  lung
  colon
  brain
  lymphopoietic
  leukemia             •
  Hodgkln's disease
 nasal

  lung
 nasopharyngeal

 buccal cavity and pharynx
 buccal cavity
 pharynx
 colon
 brain
 lymphopoletIc
 leukemia
connective tissue
nasal
5
205
NG
5
20
9
0

166
0

NG
5
NG
NG
3
NG
0
18
6
201
42
17
56
19
14
2
148
3
6
4
2
NG
5
18
9
4
0
4.3
196.0
NG
12.5
26.3
11.4
1. 1

MI.O
0.7

NG
3.7
NG
NG

1. 1
NG
NG
19
2
192
48
21
62
24
10
2.2
no
i
3.9
1.2
1.8
NG
7.0
19.8
7.9
I.I
0.6
:if ft >•:.
40 '•« l"l
76 '-6 , 7
79 '-8 2.*0
«•' 5.6
"8 13* • ,'
'•' 1.4
6-' 7.7

1 36 •> a
0 2-8 3.2
	
"* ~ ~ 	
27i 5.0 6.0
	
96 '-6 , ,
•300 ... ''
»i ..' ,;;»
87 4 , .
•* 1.5
81 .<> ,.a
91 -4 ,.4
80 s
* 17
'42 2 0 ->"-,
•" 2.2
91 3-4 4.0
•135
300 4.3 ;;;
155 ?•<> 3.0
•343
113 --- """

71 '; \
'• 5 2.6
91 '•/ 1.9
'14 2.i 24
*. ^
•364
	 i > .. ,.
                                                                                                                                        9.0

-------
                                                                         Table 4-15 (cant.)



    • p < 0.05



    d These nunbars «are obtained using Molina's  tables of Polsson's Exponential Binomial  Unit (Molina,  1942).



      NG, observed or expected nunbar  ot deaths not given In paper.



    c Age-spec I Me mortality rates of  psychiatrists used as the comparison group


    d
      Power MAS not calculated lor sites where statistically significant elevations ware observed,



    * As described In Levlne et al. (1984)                              °



      Because the expected nu»ber of deaths  was large, least detectable relative risks were obtained by the approximation ot Beaunont and Bras low  (1981).


    g
      SMR for the Blair et al. study are for analyses based on white males with time-weighted  average exposure ot >0.1 ppm formaldehyde.



    h White males with cumulative formaldehyde exposure greater than 0 ppn-years.



      Observed and expected numbers ot deaths are tor white male wage workers.
QO
o>

-------
                                                                             Table 4-16

                                                          Con d 111 on a I  Hone r Calculations tor  FMH  Studies'
       Study
                                            il/t
oo
MJ
      Malrath and Fraumenl (1981)
         NY «*balmers
         and funeral
         directors
                     1132
      Malrath and  Frat
        C«l Horn I a
        embalmers
an I  (1984)
                    1050
     Harsh U9bJ)
        resin
        Manufacturing
        workers
                   2490
     lleblIng et al.  (1984)
        formaldehyde
       resin
       workers
                     24
  Cancer
  Site

  buccal cavity and pharyn>
  lung
  colon
  brain
  lymphopoietic
  Ieukemla
  nasal

 buccal  cavity and pharynx
  lung
 colon
 brain
 lymphopoietic
 Ieukemla
 nasal

 buccal  cavity and  pharynx
 lung
 colon
 brain
 lymphopoietic
 leukemia
nasal
                               buccal cavity and pharynx
                               lung
                               colon
                               brain
                               Iymphopoletlc
                               leukemia
                              nasal
                                                                                                            Least detectable
                                                                                                               •Ith power6
                                                                                                                       90*
8
72
29
9
25
12
0
8
41
30
9
19
12
0
0
NG
NG
NG
2
NG
0
2
NG
NG
NG
1
NG
0
7 I
• . i
66.8
20.3
5.8
20.6
a.5.
0.5"
6.1
42.9
16.0
4.7
15.5
6.9
0.6d
0.8
NG
NG
NG
2.3
NG
NG
0.2
NG
NG
NG
0.5
NG
NG

1 13
108
•143°
156
121
140
131
96
•187
•193
123
•175

	
-__
	
86
	
•870
— — —
— _
— — —
217
---

230
130
240
160
210
860
220
140

170
7~2~0~d
530


350
	




860


250
140
280
170
240
1060
260
151

190
880d
660
— 	
--.
400
	 ^




1060


-------
                                                                     Table 4-16 (cont.)
Stayner et al.
garment
•or ker s





Delzell and Grutterman
textl la
•or ker s




256 buccal cavity
lung
colon
brain
lymphatic and
hematopolet Ic
1 eukaml a/a 1 eukaml a
nasal
4462 buccal cavl ty and pharynx
lung
colon
brain
lymphopoietic
leukemia
nasal
3
1 1
NG
1
10

4
0
18
106
115
17
121
45
NG
0.4
12.2
NG
2.1
6.1

2.4
NG
18.0
117.8
115
18.9
64.2
37.5
NG
•750
90
_--
48
163

168
	
100
90
100
90
188
120


180
- — —
380
220

330
-_.
170

120*
170
130
145


200
	
440
250

380

180
130*
130*
180
140
150

<=>  • p<0.005



    4 Conditional on the observed  number ot deaths since distribution ot H  and H might not have a Polssln distribution (Mlettlnen and Nang,  1981),



      These numbers Mere obtained  using Molina's tables ot Polsson's Exponential  Binomial  Limit (Molina. 1942).



    c Power was not calculated tor those sites where statistically significant elevations  were observed.


    d
      As published In Levlne et al.  (1984).



    * Because the expected numbers ot deaths was large, least detectable PMK's were obtained by tha approximation ot  Beaumont and tireslow  (1982).

-------
                                                           Table 4-17

                                         Power Calculations for Case-Control Studiesa'b
                                                                                                  Least Relative Odds to
Study
Fayerweather et al. (1982)
cancer deaths
in chemical
workers

Brinton et al. (1983)

481
481
(1:

160
Size
cases/
controls
1) match)

cases/
Cancer Site
lung, bronchus
and trachea
lymphopoietic
prostate
brain
nasal cavity
Exposure Ratio = P
o
forma Idehyde:
males workers (20%)

textile workers:
Odds
Ratio

0.74
0.72
3.20
0.45

detect
80%

2.0
3.5
4.4
1 1.6

with power0
90%

2.2
4. 1
5.5
16.8

V0
 nasal and paranasal
 sinus cases in NC and VA

 nasal and uasopharyngeal
 cases in Sweden

Olsen et al. (1984)
 nasal cancer
 cases in Denmark
                                 290 controls
                                 (1:2 match)

                                 541 controls
                                 839 cases/
                                 2465 controls
  and sinuses
nasopha ryngea1
nasal cavity
  and sinuses
    Hayes  et  al_.  (1984)
     nasal and nasal
     sinsus cases  in
     the Netherlands
                             144 cases/
                             353 controls
                             (1:2 match)
nasal cavity
  and sinuses
 females (17.4%)        1.8          2.5
manufacture:           *5.8
 males (0.8%)
formaldehyde:
 females (0.1%)
 males (4.2%)
textile dust:
 females (2.5%)
 males (1.9%)
formaldehyde: (Classification A)
 males with no or low
 level wood dust
 exposure (6.2%)        2.8          3.4
 males with high
 level wood dust
 exposure (50%)          1.9          6.9
formaldehyde: (Classification A)
 males,  controlled      *1.9          	
 for high wood dust exposure
                                                                 2. 8
•2.8
2.8
1.3
0.7
15.0
2.8
2.4
18. O
3.2
2.7
                                                                                                                  3. 7
                                                                                                                  8.0

-------
                                                       Tattle 4-17  (cont. )
    Partenen  et al.  (1985)
      nested  respiratory
      cancer  case-control
      study
    Vaughan  et  a I.  (in press)
      sinonasal and
      pharyngeal cases in
      the  U.  S.
55 cases/
169 controls
respiratory
  system
S3 cases/
552 controls
nasal cavity
  and sinuses
yf>
NI
                                 27 cases/
                                 552 controls
                nasopharyngea 1
                                 174 cases/
                                 552 controls
                oro-hypo-
                  pharyngeal
formaldehyde:
 ever exposed  (26.6%)    1.4
 level of exposure
   0. 1 -  1.0 ppm  (16%)   1.5
   > 1.0 ppm  (7.7%)      1.4

occupational formaldehyde:
  cumulative exposure
   5-9 years  (6.3%)    1.1
   10 t years  (10.9%)    0.3
occupational:
resins, glues and
adhesives
  low exposure  (6.5%)    2.0
  high exposure (2.3%) *3.8
domestic:
mobile home residence
   1 + years (12.0%)     1.7
occupational formaldehyde:
 no. of years exposed
  1 - 9 (25.0%)          1.2
  10 * (10.3)            1.6
occupational:
stains,  varnishes,
solvents
  low exposure          0. 9
  high exposure        *4.0
domestic:
mobile home residence
  1 - 9 years  (12.0%)   2.1
  10 + years (3.7%)    *5.6
occupational formaldehyde:
 no.  of years exposed
                                                                     1 - 9 (25.0%)
                                                                     10 + (10.3%)
                                                                  occupa t i ona1:
                                                                  resins, glues,
                                                                  adhesives      e
                                                                     low exposure
                                                                     high exposure
                                                         0.6
                                                         1.2
                                                         1.3
                                                        •3.9
                                                                       2.5

                                                                       2. 7
                                                                       3.4
                                                                       4.0
                                                                       2. 7
                                                                                                        3.2
                                                                                                       2.7
                                                                                                        3.2
                                                                                                        4.5
                                                                                                       3.7
                                                      1.7
                                                      2. 1
                                                                  2. a

                                                                  3. 1
                                                                  3.9
                                                                 4.8
                                                                 3. 3
                                                                                  3.7
                                                                                  3. 3
                                                                                  4.0
                                                                                  5.6
                                                                                  4. 7
                                                 1.9
                                                 2.4

-------
                                                      Table 4-17 (cont.)
                                                                 stains,  varnishes,
                                                                 solvents
                                                                    low exposure6         1.0
                                                                    high exposure6       *3.0         	        	
                                                                 domestic:
                                                                 mobile home residence
                                                                    1-9 years (12.0%)   1.0         2.0        2.2
                                                                    10 + years (3.7%)     0.9         2.9        3.3
   *p<0.05

   a Power calculations for Tola et al.  (1980),  Rxish et al.  (1985) and Hemberg et al.  (1983)  could not be calculated due
     to the unknown exposure ratio (po)  among the controls.

     Power was not calculate:! for studies where statistically significant elevations were observed.

   c Obtained fran the study by Fayerweather et al.  (1982) or was calculated using the method in Rothnan and
f    Boice (1982)  for the studies by Brinton et al.  (1983), Olsen et al. (1984),  Hayes et al.  (1984),  and
£    Hardell et al. (1982).

   d Matching ratio not identified by Hardell et al.  (1982).

   e Prevalence of the exposure among the controls not cited  by Vaughan et al.   (As reported in SAIC,  1986).

-------
 hematopoietic  site cancer as an .example, Table 4-15 shows that




 Levine et al.  (1984) could detect, with 80 percent power, a




 relative risk  of 2.3 or greater and with 90 percent power, a



 relative risk  of 2.6 or greater.



      The'above seven sites were selected for several reasons.




 First, because  the exposure is generally by inhalation and nasal



 tumors were  seen in the chronic rat study (Kerns,  1983),  the




 respiratory  system is a reasonable place to look for effects.




 Nasal tumors, buccal cavity tumors, and pharyngeal tumors were



 included because man,  unlike the rat,  is not an obligatory nose



 breather and inhaled formaldehyde would initially  contact these




 areas.  Last, the Epidemiology Panel,  Consensus Workshop on



 Formaldehyde (1984) and Levine et al.  (1984) report significant



 excesses in brain,  leukemia,  and colon cancer mortality when



 results across  studies were combined.



     Epidemiologists use five criteria for judging whether an



 association  is  causal.  These criteria are:   1) strength of the



association,  2)  consistency across studies,  3) temporally correct



 association  (disease occurs after exposure), 4) specificity of



the association, and 5)  coherence with existing data.   The



 reviewed epidemiologic studies are of  a cohort or  case-control



design,  designs  which examine health consequences of previous



 exposure,  thus permitting point 3 to be' satisfied.



     The Blair et al.  (1986),  Blair et al.  (1987), Vaughan et al.



 (1986a,b), and Stayner et al.  (1986) were designed to detect



moderate increases  in formaldehyde-related risks.   The Blair et




al. (1986) and Vaughan et al.  (1986) studies observed significant
                              4-94

-------
 associations with nasopharyngeal cancer and apparent exposure to



 formaldehyde,  in either the occupational or residential




 environment.  Vaughan et al. (1986)  reported a significant



 association between the incidence of nasopharyngeal  cancer  and



 living 10 or more years in a mobile  home.   This study also




 reported  statistically significant associations between  sinonasal



 cancer and oro-hypopharyngeal cancer and exposure to resins,



 glues,  and adhesives (SAIC,  1986).   Mobile  home residency and



 occupational resins,  glues and adhesives exposure were a priori



 selected  as likely  surrogates for formaldehyde exposure.  No



 statistically  significant associations  were found between cancer



 incidence at any  of these sites  with respect to occupational



 formaldehyde exposure as assessed using an  occupational  linkage



 system.   The risk estimates,  however, for the  highest exposure



 level  and cancers of  the oro-hypopharynx and nasopharynx appeared



 elevated.   These  results  for the  occupational  formaldehyde



 exposure  most  likely  were biased  towards, the null  hypothesis



 since a large  proportion  of  the case  interviews  were  with the



 next-of-kin, respondents  less  likely  to  report  or  remember  all



 jobs the  case had ever held.




     Blair  et  al. (1986,  1987) observed  excesses of  lung and



nasopharyngeal cancer mortality among U.S. workers exposed  to



 formaldehyde in 10 plants.   The highest  risks  were observed for



 lung cancer  among men with a  20-year  latency and  for



nasopharyngeal cancer among  men with  exposure  to  formaldehyde-



containing particulates.  An apparent dose trend was  observed




between nasopharyngeal cancer mortality  and  exposure  to
                               4-95

-------
formaldehde and particulates (Blair et al., 1987); no clear




trends were observed between lung cancer mortality and



formaldehyde level (Blair et al., 1986).  Blair et al. (1986)




argued the data provide little evidence that lung cancer



mortality is associated with formaldehyde exposure at levels



experienced by workers in this study,  although they concluded



that simultaneous exposure to formaldehyde and particulates



appear to be a risk factor for nasopharyngeal cancer.  Blair



et al. (1987) additionally state that further investigation is




needed regarding the dose-dependent association between



nasopharyngeal cancer mortality and exposure to formaldehyde and



particulates.  The significant excesses in total lung cancer



mortality, in analysis either with or without a latency period



equal to or greater than 20 years,  and in nasopharyngeal cancer



mortality among ever-exposed workers are meaningful.  Inhalation



is the primary route of exposure for this cohort.   Second,



misclassification of exposure,  the lack of specificity between



the narrow exposure categories, may account for the lack of a



statistically significant trend between lung cancer mortality and



formaldehyde level.  Blair et al. (1986) relied upon historical



industrial hygiene data,  process changes, and human recall to



reconstruct past exposure to formaldehyde.  The observed wide



variations in historical industrial hygiene data for any given



job and the reliance upon human memory may have contributed to



misclassification.



     Stayner et al. (1986) reported significant mortality



excesses from neoplasms of the buccal cavity, connective tissue,




and tonsils among formaldehyde-exposed garment workers.  The risk






                               4-96

-------
 ratio  for buccal cavity cancer was  significantly  elevated among




 workers with a long duration of employment  (exposure) and follow-



 up  period (latency).  Although it is not presented  in Stayner et



 al.  (1986),  EPA calculations showed a statistically significant



 trend  between buccal cavity cancer mortality and  increasing



 duration of employment.  A significant excess in  deaths from



 cancer of the tonsils (located in the oropharynx) was also




 reported, but there were too few deaths (only 2)  to examine any



 trends with exposure.



     The significant associations between formaldehyde exposure



 and excesses in site-specific buccal cavity and respiratory



 cancers support observations from EPA's previous  review of the



 epidemiological literature.  These other studies  had limited



 ability to detect formaldehyde-related risks due  to lower



power.   Even with this potential limitation, 6 studies (Olsen et



 al., 1984; Hardell et al. , 1982; Hayes et al., 1986; Acheson et



al., 1984a;  Liebling et al., 1984; and Stayner et al., 1985)



 reported significant associations between excess  site-specific



 respiratory or buccal cavity and pharyngeal cancer and exposure



 to formaldehyde.



     The Hayes et al. (1986) and Olsen et al. (1984) studies



report  significant excesses of sinonasal cancer and exposure to



both formaldehyde and wood-dust.  Both studies controlled for



 simultaneous wood-dust exposure, and by doing so, the detection



 limits  exceeded excesses in expected sinonasal neoplastic risk.



 Hardell et al.  (1982) reported a significant excess in si.nonasal



cancer  and employment in particleboard manufacturing.
                               4-97

-------
      The other 3 studies examined mortality among workers




 occupationally exposed to formaldehyde-containing products.



 Acheson et al. (1984a) observed a significant elevation in lung



 cancer among formaldehyde resin workers  in 1 plant in the U.K.




 Acheson et al. (1984a) observed at this  plant a marginally



 significant trend with dose.   Acheson  et al.  (1984a)  concluded



 that the increased lung cancer mortality and positive trend  were




 not  related to formaldehyde  exposure since analyses using local



 cancer rates as the comparison were not  statistically



 significant.   EPA believes that the risks  and trends  from




 analyses  using local  lung cancer rates as  the comparison appeared



 sufficiently  increased for corroborative use.   EPA notes,



 however,  it was not known how  many  of  the  formaldehyde-exposed




 lung cancer deaths  were  included in the  deaths  of  the local



 comparison  group.   This  would  lead  to  a  reduction  in  power since



 the same death  could be  counted  in  both  the  numerator and



 denominator.



     The 2  other  studies  (Stayner et al.,  1985  and  Liebling  et



 al.,  1984)  reported statistically elevated SMR's for  buccal




 cavity cancer among garment workers and  for buccal  cavity  and



pharyngeal  cancers  among  formaldehyde resin workers in  1  plant.



 Portions of the Liebling  et al.  (1984)  and Blair et al.  (1986,




 1987) studies overlapped  as did  portions of  the  two Stayner  et



 al. (1985;  1986)  studies.  The  nonoverlapping portions  and



 improved design of  the more recent  studies (i.e.,  Blair  et al.,



 1986; Blair et  al., 1987; Stayner et al.,  1986)  reinforce  the



conclusions of the  earlier studies.
                               4-98

-------
     The  studies  of  embalmers,  anatomists  and  pathologists




 reported  deficits in mortality  from site-specific  respiratory



 cancers.  Although individual characteristics  are  not known, this



 observation may be a reflection of decreased smoking habits among



 these professional groups  in comparison to the general



 population.  Since expected deaths are based on general



 population site-specific mortality, the number of  expected deaths



 may be biased upwards with the resultant SMR being lower.  The



 lack of lung cancer  excesses in these studies may  additionally



 reflect the lower statistical power to detect moderate increases



 in site-specific  respiratory cancer mortality.



     Site-specific excesses in  lymphopoietic,  leukemia, colon, .



 and brain neoplasms have been observed in  five studies



 (Harrington and Shannon, 1975; Harrington and Oakes, 1984;



 Stroup,  1984; Walrath and  Fraumeni, 1983; '.Valrath  and Fraumeni,



 1984),  but these excesses  were not statistically significant



 across all studies.  This  lack of consistency may  reflect lack of



a causal relationship or may reflect limited power to observe



 excesses at specific sites because of small sample sizes,



 insufficient follow-up, different exposure levels, and different



 routes of exposure in the  individual studies.  The Epidemiology



 Panel of Consensus Workshop on Formaldehyde (1984) summarized the




observed and expected numbers of site-specific cancers  from both



 SMR and PMR studies and noted statistically significant  excesses



 in mortality from brain cancer and leukemia among  embalmers,




pathologists, and anatomists.   Levine and co-workers (1984) 'jse.i
                               4-99

-------
 this  same method and, additionally, noted a statistically




 significant excess in mortality from colon cancer.



      The same conclusions were reached through the use of another



 approach by summarizing all SMR and all PMR site-specific




 findings according to Fisher's combined probabilities method



 (Sokal and Rolf, 1969).  Fisher's combined probabilities can be



 used  on different sets of data that test the same scientific



 hypothesis and where for one reason or another a joint



 statistical analysis is not optimal.  This methodology does not



 assume all studies are equal.  Again,  Fisher's combined



 probabilities may not be an ideal test.  Its use on discrete or



 count data tends to bias the results toward non-significance



 (Gastwirth,  1983).  A detailed description of the procedures and



 analyses are presented in EPA, 1984b.   Table 4-18 presents the



 summarized results.  Thus, where site-specific mortality has been



 reported,  it can be concluded from SMR studies that brain cancer



 mortality is significantly elevated (p<0.05) among pathologists,



anatomists,  and embalmers, and from PMR studies that leukemia and



brain cancer mortalities are significantly elevated (p<0.05) for



 these professions.   Likewise, from PMR studies, colon and



 lymphatic and hematopoietic cancer mortalities are significantly



elevated (p<0.05) for manufacturing workers.



     To further examine power, the human data were compared to



estimates of the upper bound risk that were calculated based on



 the malignant tumors in Kerns (1983).   This comparison assumes



 the excess risk calculated from the animal low-dose extrapolation



 is the excess above a risk of one for the study population
                              4-100

-------
Cancer Site
                         Table 4-18

Fisher's Conbined Probability(p)  for SMR and for PMR Studies

Study Design               Study  Population            Fisher's pa
Buccal cavity SMR
and pharynx
PMR
Lung SMR
PMR
Colon SMR
PMR
Brain SMR
PMR
Lymphatic and SMR
hematopoietic
PMR
Leukemia SMR
PMR
Embalmers, Anatomists,
Manufacturing Workers
Embalmers, Anatomists,
Manufacturing Workers
Embalmers, Anatomists,
Manufacturing Workers
Embalmers, Anatomists,
Manufacturing Workers
Embalmers, Anatomists,
Manufacturing Workers
Embalmers, Anatomists,
Manufacturing Workers
Embalmers, Anatomists,
Manufacturing Vorkers
Embalmers, Anatomists,
Manufacturing Workers
Embalmers, Anatomists,
Manufacturing Workers
Embalmers, Anatomists,
Manufacturing Workers
Embalmers, Anatomists,
Manufacturing Workers
EiTibaLTiers, Anatomists,
Manufacturing Workers
Pa tho legists
Patho legists
Patho legists
Patho legists
Pathologists
Patho loists
Pathologists
Pathologi sts
Pathologists
Pathologists
Pathologists
Pathologists
0.64
0.40
0.36
0.10
0.99
0.35
0.54
0.83
<0.35
0.22
<0.01
0.48
<0.01
0.95
0.02
0.75
0.08
0.56
0.17
<0.01
0.17
0.26
0.04
0.10
Probability of -2     Z__  L-i Pj     distributed' as a chi-square with 2k  degrees  of

freedom (Sokal and Rolf,  1969).   Stall values indicate a statistically significant
elevation over 100.
                                   4-101

-------
relative to the U.S. population (Margosches and Springer,




1983).  Hence, human site-specific neoplastic relative risks are



calculated by adding the percentage increase in site-specific



tumors to a relative risk of one.



     Two major assumptions are made to carry out this



prediction.  First, the number of human cancer site-specific



deaths approximates lifetime incidence.  Second, site-to-site



concordance between animals and humans does not necessarily hold,



and only one site is examined at a time.



     Table 4-19 presents the upper bounds on predicted human



relative risk for seven neoplastic sites.  Based on Table 4-19,



we would expect to see a relative risk of around 1.26 for buccal



cavity and pharyngeal neoplasms for funeral service workers




(morticians and embalmers).  It must be noted that the predicted



relative risks vary greatly with the mortality.  The rarer the



cause of mortality the higher the predicted relative risk will



be.  Comparing the occupation-associated predicted human relative



risks with the least detectable risks identified in Table 4-15 to



4-17,  we see that very few of the SMR and PMR studies had 90%, or



even 80%,  power to detect this upper bound predicted human nasal



sinus and cavity risk.   Most of case-control studies had 30%



power to detect such excess nasal cavity and sinus risks, if



average exposure to formaldehyde for the cases was around



1.3 ppm.   Note,  the reviewed studies had over 90% power to deter",



a predicted upper bound on nasal cavity and sinus relative risk



(RR=101.0) that was based on animals bearing either nasal cavity



and sinus squamous cell carcinomas or polypoid adenomas if
                              4-102

-------
                                                  4-19
Cancer Site
ELneral Service Nbnufectiring
Vtrtem ^pjarel Resin Flznitxre article Bard
(1.70Hn)b (0.64pon)b (1.40ppn)b (1.30ppm)b (0.10ppn)b (0.33 con)
Rraai cavity 1.26c
and pharynx
ling
Gblm
frain
r\jirt'TY"T 1 '11 f& If
Ta.Jtema
ISbsal cavity
and sirus
1.02
1.05
1.24
1.05
1.13
6.45
a This procedure is describee
on an asanpticn that eases
is the acess above a risk
to an inexposed or g=neral
tVt^ h (+ art hi
EfcpoFticns
b Eeranal ex:
1.23=
1.02
1.04
1.22
1.05
1.12
5.83
lb/^fetc
B ri* c
of one |
1 1 1 ulaf'i
nan relative risk = 1
*TT 'tilths C^lOl'^^^* fri
ri^M'-r-jbgd in EE
insure esturates
A, 198fc
fixm EE
(5.65)d
(1.38)
(1.90)
(5.44)
(2.04)
(3.41)
1.53=
1.04
1.10
1.51
1.12
1.28
(101) 12.45
• ili ii i i ii 1 1 f
pares arc S
Rio list-art fr
br ahuraa e
en.
+ P(d)UO^
1.44= 1.03= l.llc
1.04 1.00 1.01
1.09 1.01 1.02
1.42 1.03 1.11
1.10 1.01 1.03
1.23 1.01 1.06
10.65 1.60 2.42
Textile
(0.70 ppn)
1.26c
1.02
1.05
1.24
1.06
1.13
6.50
fcringsr (1983). ft is based
cxi anirral kw-dcse extrapolaticn
ygoBed prpilfrt-.im relative
5-stage nodal
an I960 ncrtality data.
•
^ 1964D. -



c l£per bond predicted huran relative ri^s Vnffrl en a P(d)UCL
  P(d)  is estinatad fron the nnber of aninals bearing  aqiBnaJs'c

d Lfper boxid predicted hjtan relative ri*s basad en P(d)UCL>  s^taqe nccel,
  P(d)  is estinatal fixm the trtal rinber cf aninals baaring aqLarDSceQ"carcinaias or
  polypoid adenaras.
                                                4-103

-------
 exposure was around 0.64 ppm or greater.  None of the studies




 could detect the predicted relative risks that were based on




 animals bearing only squamous cell carcinomas for brain,  or for



 leukemia,  or lymphopoietic,  or colon,  or lung neoplasia for the



 populations studied.








 4.7.3  Conclusion




      The EPA has examined 28 studies which related to



 formaldehyde.   Three of  these studies  (Vaughan et al.,  1986a,b;




 Blair et al.,  1986,  1987;  and Stayner  et al.,  1986)  were  designed




 to detect  moderate  elevations in human cancer  risks; the



 remaining  25 studies had  detection limits that exceeded



 corresponding  expected excesses in site-specific  neoplastic




 risks.   Results  from 9 studies  (Vaughan  et al.,  1986a,b;  Blair  et



 al.,  1986,  1987;  Stayner  et  al., 1986; Olsen et  al., 1984;



 Hardell  et  al.,  1982; Hayes  et  al.,  1986;  Acheson et al.,  1984a;




 Liebling et  al.,  1984; and Stayner  et  al.,  1984)  suggest  that



 lung, nasopharyngeal> sinonasal, and oro-hypo-pharyngeal  cancers



are associated with  formaldehyde exposure.



      In  each of  the  above 9  studies, the  populations were  also



undoubtedly  exposed  to other  agents and  these  exposures may have



contributed  to the observed  increase in  cancer risk.  Five



studies, however, addressed confounding.'   Vaughan  et al.



 (1986a,b) controlled  for sinokirv-j and alcohol consumption  in their



analyses.  Hayes et al.  (1986) and Olsen  et al .  (1984)  controlled




for wood-dust exposure;  the detection  limits in both studies



exceeded corresponding expected excesses  in sinonasal neoplastic
                              4-104

-------
 risk.   Stayner et al.  (1986) measured possible confounders such



 as phenol or particulate dusts in their study and thought the



 contribution of the confounders to the observed excesses in



 buccal  cavity or pharyngeal mortality were minimal to none.



 Mote, Stayner et al. could not measure the impact of smoking on



 their observed excesses in mortality.  Blair et al. (1986), on



 the other hand, stated that the lack of a consistent elevation



 for tobacco-related causes of deaths suggested that their



 cohort's smoking habits did not differ substantially from those



 of the  general population.  Regarding diagnostic bias accounting



 for the observed brain cancer excesses,  the brain cancer excesses



 remained when other like socioeconomic groups were used as the



 comparison.  Socioeconomic status may be a confounder in the



observed associations with upper respiratory cancers, but no data



currently exist for evaluation.  As identified earlier, smoking,



 sometimes associated with socio-economic status, either has been



 taken into account in analyses or was thought to be appreciably



 similar within the individual study comparison groups.



     Based on the above human evidence,  formaldehyde can be



placed in the "limited evidence of carcinogenicity" category.



This category is defined as "indicates that a causal



interpretation is credible, but that alternative explanations,



such as chance, bias, or confounding, could not adequately be



addressed" (EPA,  1986).



     Formaldehyde should not be placed in the categories



 "inadequate evidence" or "sufficient evidence of



carcinogenicity."  "Inadequate evidence" is defined as
                              4-105

-------
 "indicating that one or two conditions prevailed:   (a) there were-



 few pertinent data, or (b) the available studies, while showing



 evidence of an association, did not exclude chance, bias, or



 confounding."  Placemen't into the "inadequate evidence" category



 would imply that the studies contained insufficient data to



 consider adjusting for alternative interpretations.  The



 aforegoing discussion shows this is not the case.   "Sufficient



 evidence of carcinogenicity" is defined as "indicates that there



 is a causal relationship between the agent and human cancer."  A



 variety of plausible important exposures could have confounded



 these results, but no adjustment could be made for  them.  In



 addition,  the association between mobile home residence and



 nasopharyngeal cancer was a first report; future epidemiological



 studies would be needed to confirm a causal association between



the formaldehyde exposure in a mobile home and the  incidence of



nasopharyngeal cancer.



     On this basis, EPA has concluded that the epidemiological



evidence is "limited".
                              4-106

-------
4.8.   Weight-of-Evidence



4.8.1.   Assessment of Human Evidence



     EPA examined 28 epidemiologic studies relevant to HCHO.




Three of these studies, two cohort (Blair et al., 1986; 1987



Stayner et a'l. , 1986) and one case-control (Vaughan et al.,



(1986a,b), were well conducted and specifically designed to



detect small  to moderate increases in HCHO-associated human



risks.  Each of these three studies observed statistically



significant associations between respiratory site-specific




cancers and exposure to HCHO or HCHO-containing products.  In



each of the above three studies, the populations .studied were



also undoubtedly exposed to other chemicals and these exposures



may have contributed to the observed increases in cancer risk.



Only the study by Vaughan et al. (1986a,b) controlled for smoking



and alcohol consumption.



     The Blair et al. (1986; 1987) cohort study observed



significant excesses in lung and nasopharyngeal cancers among



U.S. workers occupationally exposed to HCHO at 10 industrial



sites.  Blair et al. (1987) conclude that formaldehyde and



particulates appear to be a risk factor for nasopharynyeal



cancer.  Blair et al. (1986),  however,  argued that the lung



cancer excesses provided little evidence of an association with



HCHO exposure since the lung cancer risk did not increase



consistently with either increasing intensity or cumulative HCHO



exposure.   EPA, after reviewing these data, has concluded that



the significant excesses in total lung cancer mortality, in
                              4-107

-------
analyses either with or without a latency period equal to or




greater than 20 years, and together with nasopharyngeal cancer



mortality among HCHO-exposed workers are meaningful despite the




lack of significant trends with exposure.



     The Stayner et al. (1986) cohort study reported



statistically significant excesses in mortality from buccal



cavity tumors among HCHO-exposed garment workers.  The SMR was



highest among workers with a long duration of employment



(exposure) and follow-up period (latency).



     Results from the case-control study by Vaughan et al.



(1986a,b) showed a significant association between nasopharyngeal



cancer and having lived 10 or more years in a "mobile home".



Persons for whom this association was drawn had lived in mobile



homes that were built in the 1950s to 1970s.  This study also



reported significant associations between .sinonasal cancer and



orohypopharyngeal cancer and exposure to resins, glues, and



adhesives (SAIC, 1986).  No significant trends were found in



cancer incidence at any of these sites with respect to



occupational HCHO exposure; however, the risk estimates for the



highest exposure level and cancers of the orohypo-and naso-



pharynx appeared elevated.  However, this population, like the



two previously discussed,  was also undoubtedly exposed to other



chemicals which may have contributed to the observed increases in



cancer risk.




     EPA reviewed 25 other epidemiologic studies.  These studies



had limited ability (lower power) to detect small to moderate
                              4-108

-------
increases in HCHO-related risks due to  (1) small sample sizes;




(2) small numbers of observed site-specific deaths; and (3)



insufficient follow-up.  Even with these potential limitations,



six of the 25 studies  (Acheson et al.,  1984a; Hardell et al.,



1982; Hayes et al., 1985; Liebling et al., 1984; Olsen et al.,



1984; Stayner et al.,  1985) reported significant associations



between excess site-specific respiratory (lung, buccal cavity,



and pharyngeal) cancers and exposure to HCHO.



     The Olsen et al.  (1984), Hayes et  al. (1986), and Hardell



et al. (1982) studies  reported significant excesses of sinonasal



cancer in individuals  who were exposed  to both HCHO and wood-



dust, or who were employed in particleboard manufacturing where



HCHO is a component of the resins used  to make particleboard.



Only the Hayes et al.  (1986) and Olsen et al. (1984) studies



controlled for wood-dust exposure; the  detection limits in both



studies,  however, exceeded corresponding expected excesses in'the



incidence of sinonasal tumors and, therefore, no significant



excesses were likely to have been observed.



     The Acheson et al. (1984a) study conducted in the United



Kingdom supports the results of Blair-et al.  in that, when



compared to mortality  rates of the general population,



significant excesses in mortality from  lung cancer were observed



in one of six HCHO resin producing plants in England.  A trend of



borderline significance with dose was observed for this one



plant.  Acheson et al.  concluded that the increases  in mortality



from lung cancer were  not related to HCHO exposure since the
                              4-109

-------
elevation and trend were not statistically significant when




compared with local lung cancer rates.  EPA believes that the



risks and trends from analyses using local lung cancer rates as




the comparison risks appeared sufficiently increased for



corroborative use.



     The remaining two studies reported significant excesses of



buccal cavity cancer among garment workers in 3 plants (Stayner



et al., 1985) and excesses of buccal cavity and pharyngeal cancer



among HCHO resin workers in 1 plant (Liebling et al., 1984).



Portions of the Liebling et al. (1984) and Blair et al. (1986,



1987) studies overlapped as did portions of the two Stayner



et al. (1985; 1986) studies.  However, the non-overlapping



portions and improved design of the more recent studies (i.e.,



Blair et al. 1986, 1987; Stayner et al. 1986) reinforce the



conclusions of the earlier studies.



     Analyses of the remaining 19 epidemioLogic studies have



indicated the possibility that observed leukemia and neoplasms of



the brain and colon may be associated with HCHO exposure.  The



biological support for such postulates, however, has not yet been



demonstrated.



     Based on a review of these studies, EPA has concluded that




under EPA's Guidelines for Carcinogenic Risk Assessment there is



"limited" evidence to indicate that HCHO may be a carcinogen in



humans.  Nine studies reported statistically significant



associations between site-specific respiratory neoplasms and



exposure to HCHO or HCHO-containing products.  This is of
                              4-110

-------
interest since inhalation is the primary route of exposure in



humans.  Although the common exposure in all of these studies was



HCHO, the epidemiologic evidence is categorized as "limited"



primarily due to possible exposures to other agents which may



have confounded the findings of excess cancers.



4.8.2.   Assessment of Animal Studies



     The principal evidence indicating that HCHO is able to



elicit a carcinogenic response in animals are the studies by CUT



(Kerns et al., 1983), Albert et al. (1982) and Tobe et al.



(1985).  In the CUT study,  statistically significant numbers of



squamous cell carcinomas of the nasal cavity of Fischer 344 male



and female rats were seen.  The CUT study was a well conducted,



multidose inhalation study.   In addition, while not statistically



significant, a small number of squamous cell carcinomas were seen



in male mice.  Because this type of nasal lesion is rare in mice,



these data must be considered biologically significant.  Benign



tumors (i.e., polypoid adenomas) were seen in male rats in the



CUT study at all dose levels and in female rats exposed to 2 ppm



of HCHO.   Notably, the dose-response curve for the benign tumors



in this study did not mirror the carcinoma response; the tumor



incidence was highest at 2.0 ppm and decreased at higher doses.



     Tobe et al.  also observed a statistically significant



increase in the numbers of squamous cell- carcinomas in the same



strain of male rats as was used in the CUT study.  Albert et al.



reported a statistically significant elevation of the same



malignant tumor type in male racs of a different strain.  In both
                              4-111

-------
the Tobe et al. and Albert et al. studies benign squamous cell




papillomas were seen.  This observation was in contrast to the



CUT study in which polypoid adenomas were the only benign tumors




observed.  Hamsters have been tested in long-term inhalation



studies  (Dalbey, 1982) but no increased incidence of tumors was



seen in HCHO-treated animals.  However, deficiencies in the study



design and poor survival limit the interpretation of the results



from these studies.



     Additional support is provided by studies by Dalbey (1982)



in which HCHO increased the production of tumors caused by a



known animal carcinogen; Meuller et al. (1978) in which a



solution of formalin produced lesions in the oral mucosa of



rabbits which showed histological features of carcinoma in situ;



and studies by Watanabe et al.  (1954, 1955) in which injections



of formalin and hexamethyenetetramine produced injection site



sarcomas and one adenoma.



     HCHO is mutagenic in numerous test systems, and it is able



to transform a number of cell lines.  In addition,  HCHO has been



shown to be able to form adducts with DNA in both in vivo and in



vitro tests (Consensus Workshop on Formaldehyde, 1984).  Its



ability to interfere with DNA repair mechanisms has also been



demonstrated.   However, evidence demonstrating HCHO's mutagenic



potential in in vivo tests is lacking (IRMC Report on Systemic



Effects, 1984b).  The literature reports conflicting data



concerning chromosomal effects in humans.  However, the weight of



these data seems to indicate little potential for these effects
                              4-112

-------
in the workplace, but this judgement must be tempered by the




limitations of the studies.



     Although HCHO's acute effects do not demonstrate its




carcinogenicity, they do help explain differences in species



response, and the severity of the carcinogenic response in the



animal studies.  HCHO's acute effects may be factor in the



promotion of its carcinogenic potential at concentrations greater



than 1 ppm in rats and possibly in humans.



     Another factor that bears on the possible carcinogenicity of



HCHO, is the different responses seen in laboratory animals to



HCHO.  HCHO has been studied in rats, mice,  hamsters, and monkeys



by inhalation.  In rats a highly statistically significant



response was obtained in two strains.  In mice only males of one



strain showed a marginal response, while hamsters and monkeys



showed no neoplastic response.  However, the studies of



respiratory response to sensory irritants indicate that when dose



received is adjusted for reductions in respiratory rate, rats and



mice appear to respond similarly.  The cancer test data on



hamsters are negative, but this finding is tempered by poor



survival, limited pathology,  and other factors.  The study using



monkeys (Rusch et al.) indicates that, at least for nonneoplastic



lesions (squamous metaplasia), rats and monkeys respond



similarly.



     HCHO is not the only aldehyde that is carcinogenic in



animals.  Acetaldehyde,  the closest aldehyde to HCHO in



structure, is carcinogenic in hamsters and rats, causing cancers
                              4-113

-------
in the nose and trachea of the former, and nasal cancers in the




latter (by inhalation).   In addition, other aldehydes such as



glycidaldehyde and malondialdehyde have been shown to be



carcinogenic.



     Finally, HCHO's  rapid metabolism and pharmacokinetic data,



the protective action of the mucous layer, and respiratory



response to sensory irritants have been discussed in the HCHO



literature as factors that may bear on judgements of the



mganitude of the potential human cancer risk posed by HCHO and



will be discussed in  sections 7 and 9.



     In conclusion, based upon a review of the above data,  EPA



has concluded that there is "sufficient" evidence of



carcinogenicity of HCHO in animals by the inhalation route.  This



finding is based on the induction by HCHO of an increased



incidence of a rare type of malignant tumor (i.e., nasal



squamous-cell carcinoma) in both sexes of rats, in multiple



inhalation experiments,  and in multiple species (i.e., rats and



mice).   In these long-term laboratory studies,  tumors were not



observed beyond the initial site of nasal contact nor have other



mammalian in vivo tests shown conclusive effects at distant



sites.



4.8.3.    Categorization of Overall Evidence



     In conducting risk assessments of suspect carcinogens, EPA



generally evaluates the overall weight-of-evidence including both



primary and secondary evidence of carcinogenicity.  As specified



in EPA's Guidelines for Cancer Risk Assessment (EPA, 1986),
                              4-114

-------
primary evidence derives from long-term animal studies, and




epidemiological data insofar as this is available.  Secondary, or



supplemental, evidence includes structure-activity relationships,




the results of short-term tests, pharmacokinetic studies,



comparative metabolism studies,  and other toxicological responses



which may be relevant.



     In the process of categorizing HCHO,  two lines of evidence



were assessed, one of which is an assessment of studies of humans



and the other is the assessment of evidence from studies in



animals.  The results from each assessment are then combined to



characterize the overall evidence of carcinogenicity.   The EPA



Guidelines also suggest that quantitative risk numbers be coupled



with EPA classifiations of qualitative weight of evidence.



     Consequently,  based on the determination that there is



sufficient evidence that HCHO is an animal carcinogen and the



determination that there is limited human evidence, HCHO can be



classified under the draft guidelines as a Group Bl-Probable



Human Carcinogen.
                              4-115

-------
              5.    HAZARD OF NONCARCINOGENIC EFFECTS

5.1.   HCHO-Related Effects of the Eyes and Respiratory System*

     Irritation of the eyes and mucous membranes is the principal

effect of Low concentrations of HCHO observed in humans.  Human

responses'to airborne HCHO at various concentrations are

summarized in Table 5-1.  Table 5-1 shows a wide range in HCHO

concentrations reported to cause specific health and sensory

effects.  At concentrations below 0.05 ppm none of the effects

listed have been reported.
                            Table 5-1.
             REPORTED HEALTH EFFECTS OF FORMALDEHYDE
                    AT VARIOUS CONCENTRATIONS

                                        Approximate HCHO
Health Effects Reported                Concentration, ppm*

  None reported                              0-0.05

  Odor threshold                          3.05-1.0

  Eye irritation                          0.01-2.0**

  Upper airway irritation                 0.10-25

  Lower airway and pulmonary                 5-30
      effects

  Pulmonary edema, inflammation,            50-100
      pneumonia

  Death                                    100+
 *Range of thresholds for effect listed.
**The low concentration (0.01) was observed in the presence of
  other pollutants that may have been acting synergisticaily.
*Unless otherwise cited, from NTRC (1981


                               5-1

-------
     Most persons can perceive the odor of HCHO at about 1 ppm,



but some persons can detect it as low as 0.05 ppm.  Eye



irritation has been reported at concentrations as low as 0.05



ppm.  At concentrations at or above 1 ppm, nose,  throat, and



bronchial irritation have been noted.  Such irritation was nearly



uniformly reported by persons when the concentration reached 5



ppm.  HCHO concentrations exceeding 50 ppm cause severe pulmonary



reactions, including pneumonia, bronchial inflammation, pulmonary



edema,  and sometimes result in death.



     Table 5-1 shows the variability and overlap of thresholds



for responses among subjects. Tolerance to olfactory, ocular, or



upper respiratory tract irritation occurs in some persons.



Factors such as smoking habits, socioeconomic status, preexisting



disease,  and interactions with other poliuiants and aerosols are



expected to modify these responses.



5.1.1.    Eye



     A common complaint of persons exposed to HCHO vapor is eye



irritation.   Some persons can detect HCHO at 0.01 ppm, but it



produces a more definable sensation of eye irritation at 0.05-0.5



ppm.  Marked irritation with watering of the eyes occurs at a



concentration of 20 ppm in air.  Permanent eye damage from HCHO




vapor at low concentration is thought not to occur bec'ause people



close their eyes to avoid discomfort.  Increased blink rates are



noted at concentrations of 0.3-0.5 ppm in persons studied in




chambers.   Blink rate,  although used as an objective measure of



eye irritation,  appears variable for any given subject.  In smog-
                               5-2

-------
chamber testa human subjects  tested could readily detect and



react to HCHO at as low as 0.01 ppm.  The irritant effects of



HCHO seem to be accentuated when it is mixed with other gases.



     Accidental splash exposures of human eyes to aqueous



solutions'of HCHO have resulted in a wide variety of injuries,



depending on concentration and treatment.  These range from



discomfort and minor, transient injury to delayed,  but permanent,



corneal opacity and loss of vision.



     In summary, human eyes and adnexal are very sensitive to



HCHO, detecting atmospheric concentrations of 0.01 ppm in some



cases (when mixed with other pollutants) and producing a



sensation of irritation at 0.05-0.5 ppm.  Tolerance to eye



irritation is reported to occur.   Lacrimation is produced at



higher levels,  but damage is prevented by riosing the eyes in



response to discomfort.  Aqueous solutions of HCHO accidentally



splashed into the eyes must be immediately flushed with water to



prevent serious injury, such as lid and conjunctival edema,



corneal opacity, and loss of vision.
                               5-3

-------
 5.1.2.   Olfactory System



     The odor threshold of HCHO is usually around  1 ppm, but may




 be as low as 0.05 ppm for a small percent of the population.



 General olfactory fatigue with associated increases in olfactory



 thresholds for rosemary, thymol, camphor, and tar has been



 reported among plywood and particleboard workers and is thought



 to be associated with HCHO exposure.



 5.1.3.   Upper Airway Irritation (Nose and Throat)



     Symptoms of upper airway irritation include the feeling of a



 dry or sore throat,  tingling sensation of the nose, and are



 usually associated with lacrimation and pain in the eyes.



 Irritation occurs over a wide range of concentrations, usually



beginning at approximately 0.1 ppm, but is reported more



 frequently at 1-11 ppm (see Table 5-1).  "olerance to eye and



upper airway irritation may occur after 1-2 hours of exposure.



However,  even if tolerance develops,  the irritation symptoms can



return after a 1- to 2-hour interruption of exposure.



     Finally, examinations of the nose and throat  reveal chronic



changes that are more severe in persons occupationally exposed to



higher concentrations HCHO.  Exposure to HCHO can  cause



alterations in the nasal defense mechanisms that include a



decrease in mucociliary clearance and a loss of olfactory



sensit ivity.



5.1.4.    Lower Airway and Pulmonary Effects



     Lower airway irritation which is characterized by cough,



chest tightness,  and wheezing is reported often in people exposed



to HCHO at 5-30 ppm.
                               5-4

-------
     In a study of workers exposed to phenolic resin fumes by



Schoenberg and Mitchell (1975), there was evidence of chronic



airway obstruction in workers exposed for more than five years.



This was measured by lower FEV 1.0/FVC and MEF 50%/FVC ratios.



However, as opposed to the high percentage of workers reporting



acute respiratory symptoms, only small decreases in pulmonary



function during the workday and workweek were found.   In a



similar study, it was found that workers exposed to a phenol-HCHO



type resin,  hexamethylenetetramine-resorcinal, experienced



significant acute lung effects (lung function measured before and



after shifts) as measured by decrements in tests measuring "small



airways" effects.  However, there was no difference in baseline



lung function tests in the exposed and control populations



(Gamble et al., 1976).   Finally,  workers exposed to HCHO from the



manufacture of fiberglass batts and the f-:
-------
trailers, morticians,  and residents of UFFI homes,

respectively.  However,  Main and Hogan did find significantly

increased symptoms of eye and throat irritation and headache and

fatigue among the exposed group.  The residents of UFFI homes

experienced a high frequency of eye irritation and moderate rates

of nasal congestion and  tearing when exposed to 1.0 ppm HCHO for

90 minutes in a chamber  (Day et al.,  1984).   No significant

increase in respiratory  disease was found in the morticians

studied by Levine et al.

     In reviewing a number of morbidity studies,  including the

Schoenberg et al. (1975)  and Gamble et al.  (1976) studies,  the

Epidemiology Panel of the Consensus Workshop (1984) concluded

that:

     No important reductions in forced vital capacity were
     observed.   Reductions in forced expiratory volume in
     one second and forced expiratory volu.-.e (expressed as a
     percentage of forced vital capacity) vhen observed were
     small.   These were  not detected when exposure to
     formaldehyde was  solely as a vapor.   There was either a
     weak or absent association of reduced pulmonary
     function tests with  exposure in the  few studies- where
     this factor was analyzed.   Workshift (acute) changes in
     pulmonary function  tests (PFT) have  been assessed only
     when other dust'was  present and/or the formaldehyde
     itself was a particuiate or incorporated in
     particles.  Acute PFT reductions 'were not consistently
     present, were small  and showed no regular association
     with exposure.   Although some symptoms were present,
     the changes in PFT  were clinically insignificant, and
     there is no convincing evidence formaldehyde exposure
     results in restriction or obstruction at the doses
     studied.  There is  some suggestion that the symptoms
     are reversible and  of minor import.   However,  because
     of the demonstated  irritant potential of formaldehyde,
     selection bias may  be occurring in the exposed
     populations so that these studies are likely to
     underestimate adverse effects of formaldehyde exposure.
                               5-6

-------
      Studies  cited  that  were  not  available  to  the  Panel  do  not




materially affect their  findings.



      Pulmonary  edema and pneumonitis  could  result  from very high



HCHO  concentrations, 50-100 ppm.   It  is not  known  what



concentrations/durations are  lethal to humans, but concentrations



exceeding 100 ppm would  probably be extremely hazardous  to most



and might be  fatal  in sensitive persons.(NRC,  1981).



5.1.5.   Asthma



      In addition to its  iirect  irritant effects on the



respiratory system,  HCHO has been  shown to' cause bronchial



asthma-like symptoms in humans  (Hendrick et  al., 1982; Surge  et



al.,~  1985; and Nordman et al.,  1985).  Although asthmatic attacks



may in some cases be due specifically to HCHO sensitization or



allergy,  the evidence for this  is  less than  certain (Consensus




Workshop, 1984).  HCHO seems to act more  :ommonly  as  a direct



airway irritant in persons -who have bronchial asthma  from other



causes (Surge et al . , 1985 and  N'ordman et al . ,  1985).  However,



the HCHO concentrations required to elicit such attacks  are



relatively high, higher than would be expected  in  most



nonoccupational environments.   For example,  no



bronchoconstriction was observed in seven mild asthmatics who



were exposed to 1 ppm HCHO for  10  minutes at rest  and to 1 or  3



ppm during mild exercise (Sheppard et al.,  1984).   In a  study of




21 asthmatics living in UFFI homes, no consistent  bronchial



effects were produced from three hour exposures to:   Placebo,



0.54 ppm HCHO, UFFI particles 0.5/rnl, and HCHO  free UFFI off-
                               5-7

-------
 gases  (Lees et al. , 1985).  Witek et al. (1985) reports no



 effects in healthy and asthmatic individuals exposed to 2.0 ppm



 HCHO with and without mild exercise, and in a group of laboratory



 workers routinely exposed to HCHO.



     In a study of 230 persons who had been exposed to HCHO and



 suffered asthma-like symptoms, 218 did not respond when



 challenged with 2.0 ppm HCHO, including 71 subjects with



 demonstrated bronchial hyperactivity (histamine or methachoiine



 challenge test).  The 12 individuals that did respond were



 diagnosed as "true HCHO asthmatics" and all had been exposed



 occupationally (Nordman et al., 1985).   Finally, in a study of 15



 workers occupationally exposed to HCHO who were exposed to



 approximately 4.0 ppm HCHO under controlled conditions, six



 workers developed immediate asthmatic reaciions, which were most



 likely due to its irritation properties, while three workers



 developed what was diagnosed as HCHO-causei hypersensitivity



 (Surge et al.,  1985).



     Persons with bronchial asthma respond to numerous agents,



 such as exogenous irritants and allergens,  respiratory



 infections,  cold air,  smoke,  dust,  and stress.  The asthmatic



person seems to represent an extreme on the scale of respiratory



 sensitivity to inhaled irritants.  A paper by Brooks et al.



 (1985) reports two cases in which asthma-like symptoms may have



 been caused by a single exposure to high levels of an irritating



 agent.  Symptoms persisted for at least four years and were



 accompanied by early inflammatory responses in the lung.  Mo
                               5-8

-------
documented preexisting  respiratory  illness was  found.  The



authors have termed the  illness observed reactive airways




dysfunction syndrome  (RADS).   Because many occupations have the



potential for episodic, high level  HCHO exposure, RADS should be



considered as a possibility.



     Diagnosis of  immune sensitization has been based upon



knowledge that individuals were exposed to HCHO before the onset



of symptoms, reported complaints and symptoms, and spirometric



pattern on obstructive changes in respiratory function upon



bronchial provocation by inhalation challenge with HCHO.



Although the production of specific Immunoglobulin Type E  (IgE)



antibody has been  demonstrated to other chemicals (e.g.,



trimellitic anhydride, and nhthalic anhydride), IgE antibody has



not been shown to'  be produced  in response -3 HCHO exposure.



However, a study by Patterson et al. (1986; has demonstrated the



presence of IgE antibodies against  HCHO-hunan serum albumin



conjugates and human serum albumin  (HSA).   The authors believe



the immunologic response is HCHO related because of a similar



pattern in dogs immunized with HCHO or HCHO-dog albumin and the



fact that anti-HSA antibodies have  not been identified in



patients reactive to other hapten-HSA compounds.  Respiratory



sensitization with HCHO has not been demonstrated with animals



(Lee et al.,  1984).  In some human  studies in which patients



complained of respiratory illness,  they did not respond



positively to bronchial challenge testing with HCHO gas, but it



does appear from the work of Hendrick et al. (1982), Surge et  al
                               5-9

-------
 (1985), and Nordman et al. (1985) that HCHO can induce



 hypersensitivity by the inhalation route.  However, the data



 indicate that this may be a rare event.  In addition,  no data are



 available describing induction concentrations, but it appears



 that challenge concentrations as low as 1.0 ppm can elicit a



 response (Nordman et al., 1985).



 5.1.6.   Summary



     A number of lower airway.and pulmonary effects may occur



 from HCHO exposure.  Thresholds have not been established for the



 irritant effects of inhaled HCHO.  However, within the range of



 0.1 to 3 ppm, most people experience irritation of the eyes,



 nose, and throat (Consensus Workshop, 1984).   In most healthy



persons exposed to HCHO,  concentrations greater than 5 ppm will



 cause cough and possibly a feeling of ches- tightness.  In some



susceptible persons,  concentrations below  5 ppm can cause these



 symptoms,  including wheezing.  In persons with bronchial asthma,



the irritation caused by HCHO can precipitate an acute asthmatic



attack, sometimes at concentrations below 5 ppm.  Although



conclusive evidence is not available, it appears'that HCHO is



capable of inducing respiratory tract allergy, but data are



 lacking on induction concentrations.  In concentrations greater



than 50 ppm, severe lower respiratory tract effects can occur,



with involvement not oniy of the airways but also of aiveoiar



tissue.  Acute injury of this type includes pneumonia and



pulmonary edema.  Finally, a dose-response analysis of the ha.^an



data appears in section 8.
                               5-10

-------
5.2.   Irritation/Sensitization—Dermal and Systemic



     In reviewing any analysis of respiratory effects, it is



important to remember that irritation and sensitization are two



distinct physiologic responses.  Irritation is a purely local,



immediate response resulting from a chemical reaction between



HCHO and the epithelial lining.  The irritant response will



resolve with cessation of exposure.   It is scientifically



accepted that there is a threshold for the irritant response.



     A chemical sensitization response is a far more complicated



physiologic effect.   Some chemical sensitization responses are



mediated by the immunologic system,  for others antibodies have



not yet been identified and the mechanism is as yet unknown.  The



sensitization response may have one or more components, immediate



and/or delayed.  The key distinction between sensitization and



irritation,  is the absence of a clear threshold in the former.



Once an individual is sensitized,  he/she v^il respond to low



effect-triggering exposures.   There is debate in the scientific



community as to whether or not a threshold exists for the initial



chemical sensitizing event(s),  but the data are not available to



resolve the issue.



     It is established that HCHO is a primary skin sensitizing



agent producing allergic contact dermatitis.  It is also probably



a cause of immunoiogic contact urticaria (Consensus Workshop,



1984).




     HCHO induces allergic contact dermatitis by a delayed type



(Type IV)  hypersensitivity mechanism.  Besides contact with HCHO
                               5-11

-------
itself, allergic contact dermatitis can be caused by contact with



disinfectants and tissue preservatives containing HCHO,  HCHO



releasers (resins in clothing, and paper products),  and with



preservatives used for cosmetics, detergents,  polishes,  etc.



     Table 5-2 illustrates some induction concentrations which



induce sensitivity and the range of challenge  concentrations



which elicit the allergic reaction.  The threshold for induction



has not been clearly defined,  but it has been  estimated as less



than 5 percent formalin in water.  The appropriate threshold for



elicitation of allergic contact dermatitis in  sensitized subjects



ranges from 30 ppm for patch testing to 60 ppm for actual product



concentrations of HCHO (formalin).  However,  because of the



limited data base these estimates should be used with caution



(Consensus Workshop,  1984).   Data (induction and challenge



concentrations) regarding the ability of HIHO-resin treated



textiles to cause allergic contact dermatitis  in garment workers



for instance are lacking.
                               5-12

-------
                            Table 5-2.
          DELAYED TYPE HYPERSENSITIVITY (HUMAN SKIN)  DUE
                  TO LOW LEVELS OF FORMALDEHYDE*

 Induction                 Challenge          Results (No.
 Concentration           Concentration       Reacting Humans)

   370 ppm               3,700 ppm           0/45
 3,700 ppm               3,700 ppm           4/48  (4.5%)
 11,000 ppm               3,700 ppm           5/58  (5.7%)
 18,500 ppm               3,700 ppm           4/52  (7.7%)
 Unknown                     30 ppm           4/8   (50%)
 (clinical)                  60 ppm           5/8   (63%)
                           100 ppm           6/8   (75%)
                        10,000 ppm           8/8   (100%)
 Unknown                     32 ppm           0/14
                            55 ppm           2/14  (14%)
                           144 ppm           7/14  (50%)


 *IRMC 1984a
     The CIR Expert Panel (1984) stated that "the formulation and

manufacture of a cosmetic product should be such as to ensure use

at the minimal effective concentration of -ormaldehyde, not to

exceed 0.2 percent measured as free formal .iehyde. "

     HCHO skin irritation is non-immunologic? how its mechanism

may differ from other forms of dermal irritation is not known.

     Induction of contact urticaria by HCHO has been reported and

is presumably a Type 1 allergy (Consensus Workshop, 1984).

However,  proof that the immunological reactions are due to an

allergic response must await the demonstration of specific immune

reactions such as the production of IgE or IgG antibody specific

for HCHO (IRMC Subgroup on Sensitization, 1984a).  Nonimmunoiogic

contact urticaria which requires multiple applications at the

same site has been reported (Consensus Workshop, 1984).
                               5-13

-------
     Sensitivity caused by the release of HCHO into the blood

from blood dialysis treatment has been reported.  Frequent

eosinophilia (increase in eosinophil leukocytes) and some severe

hypersensitivety and asthma-like reactions have been associated

with this occurrence.  Antibodies reacting with HCHO conjugated

red blood cells is evidence of Type II auto allergy.  The asthma-

like reactions are suggestion of Type I allergy (Consensus

Workshop, 1984).  However, commenting on this the IRMC Subgroup

stated that:

     The hemodialysis patient population should not be
     considered a source of IgE antibody since:  (1)
     formaldehyde levels present during dialysis have been
     markedly reduced; (2) these reactions were due to
     systemic exposure and primarily induced an antigenic
     change in red blood cell surface markers; (3) only one
     possible case has been reported of (anaphylactic)
     sensitization by this route; this may resemble some
     reactions caused by endotoxins present in dialysis
     equipment.   In this case patients were exposed to
     allergens other than formaldehyde (personal
     communication from Ronaid M. Easterl_r.g, M.D.).

     However,  a study by Patterson et al.  (1986) has demonstrated

the presence of IgG,  IgM,  IgA, and IgE antibodies against HCHO

human serum albumin (HSA), but no correlations could be drawn

between the antibodies against HCHO-HSA and symptoms or

complication in patients using dialysis equipment sterlized with

HCHO.

5.3.   Cellular Changes

     Inhalation exposure to HCHO causes a number of cellular

effects depending on the concentration and duration of exposure.

     In the Kerns et al. (1983) study, rats exposed to 2.0 oprr.

HCHO experienced rhinitis, epithelial dyspiasia, and squamous


                               5-14

-------
metaplasia after 12 months of exposure.  The frequency of



squamous metaplasia increased to nearly 100 percent at the end of



the exposure period at 24 months.  Considerable regression was



noted at 27 months (see Figure 4-1).  In a more recent study by



Tobe et al. (1985), slight increases in rhinitis and squamous



metaplasia were observed in F-344 rats exposed to 0.3 ppm for 28



months and those found dead.   However,  the frequency of squamous



metaplasia falls within the 15 percent background rate for this



type of lesion as seen in the Kerns et al.  (1983) study.



     A study by Rusch et al.  (1983), which measured similar



endpoints in monkeys,  rats, and hamsters,  reported a NOEL for



squamous metaplasia of 1.0 ppm.   Table 5-3 clearly shows that a



threshold for this response exists at about 1 ppm (rats in the



Kern study experienced squamous metaplasia at 2.0 ppm).  A



similar threshold level is suggested for -rrikeys as Table 5-4




indicates.   Although,  the authors did not attribute the one case



of squamous metaplasia to HCHO exposure,  it is possible that HCHO



is causing effects, other than squamous metaplasia,  at or beiow



1.0 ppn due to the increased incidence of nasal discharge in



monkeys at 0.2 and 1.0 ppm as illustrated in Table 5-5.  Such a



response may be due to damaged cilia of the respiratory



epithelium.  Data submitted by Woutersen et al.  (1984b) on a



subchronic (13-week)  inhalation toxicity study with HCHO in fats



(10 rats per sex at each dose) showed no squamous metaplasia in



the controls,  3 of 20 at 1 ppm,  20 of 20 at 10 ppm, and 20 of 20



at 20 ppm.
                               5-15

-------
                            Table 5-3.
             Significant Findings in Nasal Turbinates
                             in Rats*
Group

I (combined
  (controls)
II
III
IV
Level (ppm)
   0
   0.20
   1.00**
   3.00
    Squamous
Meta/Hyperplasia
     5/77
     1/38
     3/36
    23/37
 Basai Ceil
 Hyperplasia
    4/77
    0/38
    0/36
   25/37
 *Adapted from Rusch et al. (1983)
**NOEL
    Group

    I
    II
    III
    IV
    V
                           Table. 5-4.
             Significant Findings in Nasal Turbinates
                           in Monkeys*
     Level [ppm]

        0
        0.2
        1.00**
        0
        3.00
       Squamous Meta/Hyperplasia

                  0/6
                  0/6
                  1/6
                  0/6
                  6/6
 *Adapted from Rusch et al. (1983)
**NOEL
                            Table  5-5.
              Total Incidence By Groups of Monkeys*
Grou
(ppm]

Hoarse

Congestion

Nasal discharge
                 II
         III
IV
V
(0)
0
0
9
(0.2)
0
0
30
(1.0)
0
0
45
(0)
0
0
5
(3.0)
32
36
62
*Adapted from Rusch et al. (1983).  Out of a total of 156
observations per group.
                               5-16

-------
     The effect of HCHO on nasal mucociliary function in the rat



has been studied by Morgan et al. (1986) (see Section



4.4.3.2.).  Male Fischer 344 rats were exposed for 6 hours per



day for 1, 2, 4, 9 or 14 days,  to 0.5, 2, 6 or 15 ppm HCHO.



There was a clear dose-dependent affect on mucociliary



activity.  At 15 ppm there was significant inhibition of



mucociliary activity which progressed from anterior to posterior



regions of nasal tissue.  Only slight effects were noted in



animals exposed to 2 or 6 ppm.   At 0.5 ppm no effects were



observed.



     The affects of HCHO on the human nasal system has been



studied by a number of authors.  Anderson and Moihave (1983)



reported decreases in nasal mucus flow rates at air



concentrations as low as 0.38 ppm.  In a study of five employees



of a sporting goods store in which pressed wood panels were used •



in the basement, Solomons and Cochrane (1934) report finding



nasal turbinate swelling in all five employees that persistent at



least four months beyond the point measures were taken to reduce



exposure to the point that no irritation symptoms remained.



Unfortunately, actual HCHO concentrations were not measured.



However, the lack of eye irritation may indicate that HCHO



concentration had been reduced to below about 1.0 ppm or nay



indicate tolerance to HCHO.   Initial concentrations nay have been.



much higher (>3 ppm) because the employees could not stay in the



basement for more than a few minutes due to intolerable eye and



upper respiratory tract irritation,  choking, and marked
                               5-17

-------
dyspnea.  Lacroix et al.  (1985) report on the clinical assessment



of  76 children who had been exposed to UFFI.  Among the many



symptoms observed were abnormal nasal mucosa and nasal



secretions.  Finally, in a study of workers processing



particleboard by Edling et al. (1985), it was found that the



group exposed (20 men) had a significantly higher nasal mucosa



histological score (points were assigned to eight factors



describing histological characteristics,  e.g. loss of cilia,



keratosis, etc.) than a referent group of 25 men.  HCHO exposure



levels were in the range of 0.1-1.1 ppm.   Average exposure time



for the men was seven years.  Five of the exposed group (25%) had



swollen or dry changes, or both,  of the nasal mucosa.  This was



characterized histologically as loss of cilia and goblet cells,



squamous metaplasia,  and,  in some instances, mild dysplasia.



     In summary, it is clear that observable cellular changes



begin to occur above 1 ppm HCHO in animals,  with the extent and



severity dependent on concentration and duration of exposure.



Based on data developed in rats and monkeys the NOEL for squamous



metaplasia and rhinitis can be placed at 1.0 ppm.  The human data



indicate that  mucocillary clearance system effects may be



occurring in humans at concentrations as low as 0.1 ppm, but data



in this regard are sparse.  Consideration of the animal data



indicates that the rat model is a reasonable predictor of human



effects, even though a rat is obliged to breathe through its



nose, whereas a human is not.
                               5-18

-------
     The practical consequence of the cellular changes noted is a



disturbance of the mucociliary clearance mechanism.  Since this



system  is an important defense mechanism in the removal of



particulate matter, including microbes,  impairment of this



defense mechanism may increase the susceptability of persons to



infections and other respiratory diseases (Proctor, 1982; Comroe,



1974; Widdicombe, 1977).  Reports suggesting that inhibition of



the clearance system may predispose certain children to



respiratory infections were reviewed by the Consensus Workshop



(1984).  Their conclusion was that better designed studies are



needed to characterize this effect.   In a study by Tuthill (1984)



of respiratory disease in children and woodstove use, it was



found that the strongest relationship of all study variables was



that of HCHO exposure.  Excess acute respiratory illness was



significantly related to HCHO exposure.   However, HCHO



concentration was estimated using parameters such as remodeling,



UFFI in walls,  and mobile homes.   Thus the results of this study



must be tempered by this and certain design limitations.



5.4.   Central Nervous System Effects



     Reports in the literature link HCHO with a number of



behavioral and physiologic effects such as thirst, dizziness and



apathy, inability to concentrate, sleep disturbances, etc.



Central nervous system (CNS) responses to HCHO have been tested



in a variety of ways,  including determination of optical



chronaxy,  electroencephalographicaliy, and by measuring the



sensitivity of the dark-adapted eye to light.  Responses are
                               5-19

-------
reported to begin in some persons at 0.05 ppm and are maximal in



individuals at about 1.5 ppm.  HCHO at less than 0.05 ppm



probably has little or no objective adverse effect (NRC,  1981).



However, in general, how HCHO affects the CNS is not clearly



defined (Consensus Workshop, 1984).



5.4.1.   Neurochemicai Changes




     Studies using radiolabeled HCHO have shown radioactivity in



the brains of rats after inhalation exposures.   However,  the



chemical identity of the radioactive material has not been



determined.  It is unlikely to be HCHO because of its rapid



metabolism.  Some kind of condensation product or labeled amino



acid from one-carbon metabolism may be present.



     HCHO has been shown to affect the firing rate of



nasopalatine and ethmoidal nerves of the trigeminal nasal sensory



system.  Besides being able to effect changes in the respiratory



rate of animals, HCHO also appears to be able to depress



trigeminal nerve response to other irritants, although the data



in this regard are not conclusive because of the testing



protocol.



     HCHO (at high concentrations) has been reported to cause



cerebral acid proteinase activity in rats in one study and



decrease in cerebral R>JA concentration, together with decreases



in the succinate dehydrogenase and acid proteinase activities, in



another (Consensus Workshop, 1984).   In a study by Boja et ai.



(1985) in which rats were exposed to 5.0 ppm HCHO, for 3 hours on.



2 consecutive days,  levels of 5-hydroxyindoleacetic acid,
                               5-20

-------
3,4-dihydroxyphenylacetic acid, and dopamine were increased in



the hypothalamus.  The toxicological significance of these



neurochemical changes is unciear.



     Whether HCHO is capable of causing morphological changes in



the CNS is unciear.  In two studies reviewed by the Consensus



Workshop (1984), conflicting results were seen.  In one study,



structural and cytochemical changes were seen in the cerebral



amygdaloid complex of rats exposed to 1 to 3 mg/m^ of HCHO for 3



months.  In contrast, monkeys injected intravenously over several



hours with HCHO for a total dose of 0.9 g/kg showed no



histoiogically detectable effects in the CNS.



5.4.2.   Human Studies



     Several reports are available which link chronic HCHO



exposure to a number of psychological/behavioral problems



including depression, irritability, memory loss and decreased



attention capacity, and sleep disturbances.  Unfortunately, these



studies for the most part have involved field surveys using



subjective self-report symptom inventories.  Control data are



often inadequate or completely absent.  This is a significant



problem when dealing with HCHO, which in addition to any direct



toxic effects possibly associated with it, produces distinct



olfactory cues which may stimulate a spectrum of secondary



psychological reactions (e.g., expectancies, irritations,



anxieties,  fears, etc.).  These reactions may in turn exacerbate,



mask, or interfere with the more direct neurologic, biochemical,



and physiological responses to HCHO (Consensus Workshop, 1984).
                               5-21

-------
     Nine studies of human populations were reviewed by the



Consensus Workshop (1984), but most had serious methodologic



problems.  For instance in studies by Dally et al.,  Sardinas et



al., Garry et al., and Woodbury and Zenz,  health complaints such



as headaches and difficulty in sleeping were linked to HCHO



exposure.  However, these studies do not include control



populations and suffered from selection bias.



     Thun and Aitman have pointed out some of the difficulties  in



prevalence surveys of symptoms in residents from UFFI homes,



including olfactory cues,  respondent and recall biases, and the



objective outcomes measured.   Mo significant difference was found



in the occurrence of headaches or insomnia in residents of homes



with UFFI, compared to neighborhood controls.



     In contrast, a study by Olson and Dossing found a



significantly greater prevalence of nose and throat irritation,



unnatural tiredness,  and headaches in exposed subjects than in



controls.  While this study overcomes many of the design problems



previously discussed, responses still may have been based by an



awareness of the subjects of the study goals and hypotheses.



     Attempts have been made to evaluate reported symptoms using



formal tests of neuropsychological function.  A study by Schenker



et al.  found that persons living in UFFI homes who had 'complained



of memory impairment had negative results on formal tests of



memory function,  although positive findings were seen  for many



regarding attention span.   In addition, a study by Anderson found



no effect on performance'tests of 16 healthy volunteers exposed
                               5-22

-------
 to HCHO under controlled laboratory conditions (Consensus



 Workshop).  More recent studies by Kilburn et al. (1985a, 1985b)



 of histology technicians showed disturbances of memory, mood,



 equilibrium and sleep that occurred simultaneously with headache



 and indigestion in 76 women technicians, while male technicians



 were not appreciably different than a male comparison group.



 When 25 technicians were evaluated using neurobehavioral tests



 (block design, digit symbol,  and embedded figure),  a few deficits



 were seen compared to expected results (IRMC Subgroup on Systemic



 Effects, 1984b).



     Commenting on the human data the Workshop Panel stated that



 the information "suggests that formaldehyde may affect the



 psychological functioning of the individual in three ways:  (1)



 directly,  as a result of the immediate tox.c properties of the



 substance on the peripheral and central nervous systems; (2)



 indirectly,  as a result of the individual's monitoring and



 awareness of the aforementioned changes and his/her



 interpretation and reaction to such changes, which,  in turn,



 feeds back into the central nervous system; and (3)  as a result



 of the individual's psychological reaction and concomitant CMS



 response to the olfactory properties of the substance.  In



practice,  these processes are interdependent,  yet this simple



 analysis of a complex series of responses underlines the need to



 control for 'expectancy' effects in formaldehyde research to



 permit a differentiation of the direct effects of formaldehyde on



psychological functions from it secondary effects. "
                               5-23

-------
5.4.3.   Conclusion

     Based on the body of data available on the effects of HCHO

on the nervous system, the Workshop Panel concluded that:

          The effects of formaldehyde .and/or its metabolites
     on the biochemistry of the nervous system have not been
     clearly defined.  Various possibilities exist whereby
     such effects might be mediated.

          Some evidence exists that exposure to fomic acid
     (the principal metabolite of formaldehyde) in vapor
     form at high concentrations exercises nervous system
     toxicity in intact rats.

          The irritant effects of formaldehyde may be
     reflected in altered function of sensory nerves such as
     the trigeminal nasal sensory system.  The presence of
     morphological changes in the CMS has been observed in
     one study and not in another.

          The difficulties inherent in any study of
     psychological/behavioral effects of formaldehyde have
     not yet been overcome in the course of conducting field
     surveys.

          Epidemiologic studies evaluating neuro-
     psychological symptoms potentially d'ja to occupational
     or environmental exposure to formaldehyde have failed
     to overcome the problems commonly associated with such
     studies.  However, some studies merit further
     investigation.

5.5.   Developmental and Reproductive Effects

5.5.1.    Animal Studies

     A number of studies have been reported which measured the

potential for teratogenic or reproductive effects of HCHO.

     Ulsamer et al. (1984) reviewed four inhalation studies.  No

teratogenic effects were reported.  However, other effects in

dams and fetuses were reported such as, increased duration of

gestation and body weight of offspring, microscopic changes in

the liver,  kidneys, and other organs of fetuses from exposed
                               5-24

-------
dams, and decreased Levels of nucleic in the testes of exposed

males.

    • A dermal study by Overman (1985), reported that applications

of  formalin to the backs of pregnant hamsters for 2 hours per day

on  day 8, 9, 10 or 11 of gestation increased resorptions but did

not cause birth defects.  The author speculated that the

increased incidence of resorptions may have been stress related

because of evidence that rats and mice subject to stress

experience increased resorptions, but no teratogenic effects in

the survivors (see Kimmel et al., 1976).

     A study by Marks et al. (1980) was reviewed by the Consensus

Workshop (1984) which concluded that it was the only adequate

s-tudy (at that time) of possible teratogenic effects of HCHO in

mammals.

     The Workshop review is as follows:

          Marks and colleagues intubated pregnant mice on
     days 6 through 15 of gestation with 0, 74, 148 or 185
     mg/kg/day.  At the highest dose, 22 of the 34 pregnant
     mice died.  At that dose, there was an increased
     incidence of resorptions, but that increase was not
     statistically significant.  At no dose did the
     incidence of resorptions differ between the treated and
     control groups.  There were also no treatment-related
     differences in the mean number of implantations,
     stunted fetuses,  live fetuses per litter, or average
     fetal body weight per litter.  At a dose which killed
     more than 50 percent of the dams, no adverse
     reproductive outcomes were observed except for the
     increase in the incidence of resorptions that was not
     statistically significant.

     To measure the teratogenic potential of HCHO generated  in

vivo,  a number of investigators exposed animals to hexamethylene-

tetramine by feeding or by drinking water.  Studies by Delia
                               5-25

-------
 Porta et al., Hurni and Ohder, and Natvig et al. were variously



 reviewed by the CIR Expert Panel (1984), Ulsamer et al. (1984),



 MRC  (1981), and the Consensus Workshop (1984).   No malformations



 were noted in any of the studies.



     Glycerol formal (GF), a possible slow HCHO-releasing agent,



 has been reported to be teratogenic in the rat.  However,  Asby et



 al.  (1986) studied the hydrolysis of GF and its effects in a



 mouse bone marrow micronucleus assay, which is known to be



 sensitive to certain slow HCHO-releasing agents.  No hydrolysis



 was observed and the micronucleus assay was negative.



 Consequently, the teratogenic activity of GF is unlikely to be



 due to HCHO (Asby et al., 1986).



     The Consensus Workshop (1984)  reviewed studies of



 reproductive effects.   In one study, prolonged diestrus, but no



 impairment of reproductive function was reported.  Ovarian



 involution and endomentrial atrophy were observed in another



 study,  but only in female mice exposed to 40 ppm HCHO (a



concentration which killed 80 percent of the animals).  Other



 studies were reviewed but were found to be of little value



because of methodologic problems.



 5.5.2.    Human Data



     No data have been found linking HCHO to teratogenic effects



 in humans.
                               5-26

-------
     Review of reports of reproductive effects by the Consensus



Workshop (1984) and the IRMC Systemic Effects Subgroup (1984b)



did not lead to firm conclusions regarding HCHO's potential to



cause reproductive effects for a number of reasons.   In a study



by Shumilina, workers exposed to urea-HCHO resins were reported



to have a threefold increase in menstrual disorders  and produced



more babies weighing between 2500 and 3000 g than the controls.



The IRMC Systemic Effects Subgroup concluded that because of a



lack of information on the worker environment and the



socioeconomic conditions of the study and control groups, plus



the fact that other conditions such as stress and personal and



nutritional habits are associated with the effects reported, the



role of HCHO in the development of the reported disorders is



uncertain.   In a better designed study,  reviewed by the IRMC



Subgroup and the Workshop, Olson and Doss-r.g studied a group of



female workers in a mobile home day care center who were exposed



to 0.43 mg/m3 of HCHO.  They reported increased incidence of eye



irritation, headache,  and use of analgesics in the group.  In



addition,  30 percent of the exposed group had a history of



menstrual irregularity.  The Consensus Workshop (1984) felt that



these two studies point to the need for further research, but do




not show a causal relationship between exposure to HCHO and



menstrual disorders.



     In two other reports reviewed by the IRMC (1984b), an



increased incidence of miscarriages, changes in menstrual cycies,



and an increase in ovarian cysts were reported in one study of
                               5-27

-------
 female hiatotechnicians and a high incidence of sexual



 dysfunction among male workers making fiber-reinforced plastic



 was  reported  in another.  In both instances, the workers were



 exposed to chemicals other than HCHO, especially the male



 workers.  Consequently, it is uncertain whether the effects



 reported are due to HCHO itself, to another chemical agent, or to



 the  interaction of numerous chemicals.



     The Consensus Workshop (1984) reviewed three studies related



 to the potential of HCHO to cause germ-cell mutations.  A study



 by Fonlignie-Houbrechts reported increased pre- and post-



 implantation  losses in the first week of mating, following



 exposure of male mice to 50 mg/kg of HCHO by injection, and an



 increase in preimplantation loss in the third week.  No evidence



 of increased dominant lethal effects were seen in a study by



 Epstein et al. where mice were exposed at loses of up  to 40



mg/kg,  IP.   Finally,  Cassidy reported increased sperm



 abnormalities in rats exposed to a 200 mg/kg, but not  in rats



given 100 mg/kg orally.  "Thus the data are not consistent and do



 not adequately test the possibility that formaldehyde  causes



germ-cell mutations"  (Consensus Workshop, 1984).  However, these



data may not be inconsistent given different routes of



 exposure.  More work in this area may be needed.



 5.5.3.    Conclusion



     Ulsamer et al. (1984),  the Workshop, and the IRMC Subgroup



 concluded the following regarding the potential of HCHO to cause



 teratogenic or reproductive effects.
                               5-28

-------
Ulsam«r at al.:

     Th« currently available data do not show that the
embryo La unusually sensitive to formaldehyde nor is
there any information to show that formaldehyde is
teratogenic in rodents when administered orally or
applied dermally in nontoxic amounts to the dams.
Also, the in vitro data do not provide any evidence to
support the conclusion that formaldehyde causes terata
at exposure concentrations that are not toxic to the
adult.

     Inhalation of formaldehyde has caused fetotoxic
effects but not teratogenic effects.   Further studies
of formaldehyde exposure by inhalation are needed to
elucidate the meaning of these changes.  Limited
evidence suggests that formaldehyde may affect the
menstrual cycle and perhaps reproduction in women
repeatedly exposed.  Additional work is needed to
validate these findings.

IRMC Subgroup:

     Reproductive function depends upon a sensitive and
integrated feedback system between the nervous system
and the reproductive organs.   Thus, many chemicals that
affect the nervous system have the potential to affect
reproduction.   It is possible that formaldehyde, by
affecting the nervous system induces indirect changes
in reproductive behavior and reproduction.  Although
mechanisms for such have not been delineated, several
recent reports that show an increase in the incidences
of brain tumors  in humans exposed to formaldehyde
provide indirect evidence of the potential of
formaldehyde to significantly affect the CNS.
                          5-29

-------
     Consensus Panel:

          In summary, the panel could find no evidence
     clearly demonstrating that formaldehyde caused adverse
     reproductive outcomes.  What it found was a paucity of
     information from which to make inferences and data that
     suggested hypotheses to be tested in future studies.
     This panel feels that formaldehyde poses little,  if
     any, 'risk as a potential human teratogen.  This
     judgment is based on the irritation potential of
     formaldehyde at extremely low ambient concentrations
     (0.05 ppm), existing data from in vivo mammalian
     studies, and toxicokinetic and metabolism data
     indicating an extremely short half-life (not detected
     to 1.5 min) of the parent compound,  and relatively
     short half-life (80 to 90 min) of the only known
     metabolite (formate) in the blood,  regardless of the
     route of exposure.

5.6.   Effects on Visceral Organs

     The potential effects of HCHO on visceral organs has

received relatively little attention.  One recent review article

by Beall and Ulsamer (1984) summarizes the association between

exposure to HCHO and effects on the liver.  Based on the

literature reviewed, it appears that HCHO causes hyperemia or

inflammation in liver and kidney in rats.  Microscopically, HCHO

also causes cloudy swelling, cytoplasmic vacuolization, and

necrosis in the liver,  and hyperemia, edema, and necrosis  in the

kidney.  Macroscopic changes in the liver have also been produced

by HCHO.  When exposure is repeated over a period of weeks,

changes include a mottled appearance and a decrease in liver

weight.  Following a single high exposure, liver size may

increase.  Effects on viscera could result from indirect

mechanisms or be secondary to other effects near the site  of

first contact.   Under some circumstances, GSH detoxification

mechanisms may be involved (IRMC, 1984b).


                               5-30

-------
     Transient'effects on  the hematopoietic  system occurred  in



rats and nice after  6 months of  exposure  to  HCHO by inhalation.



These  effects were reflected by  statistically  significant



decreases  in  (1) reticulocytes in  female  mice  exposed to 2.1, 5.6



or  14.3 ppm;  (2) mean corpuscular  hemoglobin in male and female




rats exposed to 14.3 of HCHO; and  (3) mean corpuscular hemoglobin



concentration in male rats exposed to 2.1, 5.6 or 143. ppm of



HCHO.  Male and female rats had  significant  (p<0.05) increases in



mean corpuscular hemoglobin, mean  corpuscular hemoglobin



concentration, and myeloid to erythroid ratios after 13 weeks of



exposure by inhalation to  12.7 ppm of HCHO.  This could indicate



myeloid hyperplasia or erythroid hypoplasia.  Thus, it is



possible effects on  visceral organs could be partially caused .



through changes in the hematopoietic system  as well as through



other mechanisms (IRMC, 1984b).



     Gibson (1984),  in reply to  Beall and Ulsamer (1994), notes



the absence of any hepatic changes attributed to HCHO in the



Kerns et al. (1983)  (CUT study) study.  Also, other than effects



in the respiratory systems of rats and mice, HCHO has not been



shown to cause toxic effects at  other sites.   In the Tobe et al.



(1985) study,  where rats were exposed to  15  ppm EiCHO for 28



months, no changes other than in the respiratory system could be



attributed to HCHO exposure.  A  decrease in  liver weight was



noted, but this was assumed to be  caused by  a decrease in food



intake, not by a direct toxic effect.
                               5-31

-------
     Addressing the issue of systemic effects, the Consensus
Workshop (1984) stated that "There is no convincing evidence in
experimental animals that inhalation exposure causes significant
primary toxicologic effects in organs other than the upper
respiratory tract."
                             5-32

-------
                     6.   EXPOSURE ASSESSMENT
6.1.    Introduction
     The sources of HCHO can be grouped  into  two major
cateqories:  commercial production and indirect production.  The
chemical is not  imported in any appreciable quantities.
     Commercially, HCHO is produced from the  catalytic oxidation
of methanol, using either silver oxide or a mixed-metal oxide as
the catalyst.  Processes accounting for the indirect production
of HCHO include  the photochemical oxidation of airborne
hydrocarbons released  from incomolete combustion processes, the
production of HCHO during incomplete combustion of hydrocarbons
in fossil fuels and refuse, and certain natural processes.
     The 1984 commercial production of HCHO amounted to about 6
billion pounds.  The major derivatives are urea-HCHO resins,
phenol-HCHO resins, acetal resins, and bu.anediol.  The urea- a-.;
phenol-HCHO resins account for about 53 percent of HCHO
production.  Adhesives and plastics are the major end uses.
     The "consumption" of HCHO can be broken down into three
major categories:  nonconsumptive uses, pseudo-consumptive uses,
and consumptive uses.  In nonconsumptive uses, the chemical
identity of the HCHO does not change.  In pseudo-consumptive
uses,  the chemical identity of HCHO does change, but it is not
irreversibly altered.  Under appropriate conditions, some or all
of the original HCHO may be regenerated.  Consumptive uses, on
the other hand, are those uses in which HCHO  serves as a
feedstock for the preparation of other chemicals.  The
                               6-1

-------
derivatives  are  irreversibly  fomed and  usually contain only



residual levels  of unreacted  HCHO.  Under extreme conditions,



such as very high temperatures or highly acidic conditions, some



of the derivatives may deqrade and release HCHO.



     HCHO's  major nonconsumptive uses are (1) disinfectant, (2)



preservative, (3) deodorant,  and (4) textile and paper uses.



     The major pseudo-consumptive uses are (1) urea-HCHO resins



which are used in fiberboard, particleboard,  plywood, laminates,



urea-HCHO foams, molding compounds, and paper, textiles, and



protective coatings; (2) urea-HCHO concentrates which are used to



produce time-release fertilizers, and (3) hexamethylenetetramine



which is used as a special anhydrous form of HCHO to cure resins



and to treat textiles and rubber.



     The major consumptive uses are (1)  melamine-HCHO resins



which are used for molding compounds, fiberboard, particleboard,



plywood, laminates,  paper and textiles,   (2) phenol-HCHO resins



which are used in fiberboard, particleboard,  plywood moldina



compounds,  and insulation; (3) nentaerythritol which is used to



oroduce alkyd resins, (4) 1,4-butanediol which is used to produce



tetrahydrofuran/ (5) acetal resins which are used in the



manufacture of engineering plastics, and (6)  trimethyloloropane



which is used in the production of urethanes.



6.2.    Estiaates of Current Human Exposure



     To obtain estimates of human exposure to HCHO, the Agency



commissioned a contractor study (Versar, 1982).  This studv



integrated the existing monitoring data, engineering or modeling
                               6-2

-------
estimates, use data, population estimates, and assessment of the



likelihood of exposure from HCHO-related activities into an




exposure assessment detailing those activities having a high HCHO



exposure potential.  EPA updated some portions of this assessment



to reflect new data received in response to the FEDERAL REGISTER



notice of November 18, L983 and other data gathered by EPA.  The



combined data were used as the basis  for the Hay 1985 draft risk



assessment.



     Subsequent to the draft risk assessment, the Agency



commissioned additional contractor studies to assess garment



worker (PEI, 1985) and residential (Versar, 1986a,b,c) exposure



to HCHO in more depth.  The exposure estimates from these reports



were used as the primary basis for this risk assessment.  The



conclusions of these contractor reports are summarized in this




document; more detailed information regarding exposure can be



obtained by referring to the contractor reports.



6.3.   Populations at Risk



     The two populations at.risk examined here are certain home



residents and garment workers.



6.3.1.   Home Residents




     Based on a projection of manufactured housing starts by



Schweer (1987), it is estimated that 7,800,000 persons may occupy



new manufactured homes during the next ten years.  This figure




assumes 295,000 starts per year and 2.64 persons per home.



     Similarly, an estimated 214,000 new conventional homes



containing significant quantities of pressed wood products as



construction materials will be started each year for the next ten
                               6-3

-------
years with an occupancy rate of 2.95 persons for a total of

6,310,000 persons.

6.3.2.   Garment Workers

     The number of potentially exposed garment workers is

estimated to be 777,000 (Versar,  1982) out of 1,100,000 workers

employed in the U.S. apparel industry (Ward, 1984).  This figure

may drop in the future due to increased foreign competition and

the introduction of labor saving equipment.

6.3.3.   Summary

     Table 6-1 presents population estimates for the two housing

segments.  Assuming that the number of potentially exposed

garment workers remains steady at 777,000, then a total of almost

15,000,000 persons over the next ten years may have the potential

to be exposed to elevated levels of HCHO.



                            Table 6-1.
                       POPULATIONS AT RISK

                                       Population
   Category                      	Estimates	
                                 per yr        10 yrs

Manufactured homes               779,000     7,790,000


Conventional homes               631,000     6,310,000

* Schweer (1987)
                               6-4

-------
6.4.   Sources of HCHO  in  Population Categories  of  Concern
     The principal  sources of  HCHO  in  the  two  population
categories of concern are  HCHO-based resins, principally  urea-
HCHO (UF) resins.   In homes, these  resins  are  used  to  bond  the
wood plys used to make  plywood and  to  bind the wood particle and
fibers used to make particleboard and  medium density
fiberboard.  For garments, HCHO-based  resins are used  to  impart
permanent press finishes to the garments.
6.4.1.    Homes Containing  Pressed-Wood Products
6.4.1.1.   Pressed-wood product descriptions
     Pressed-wood products are used in flooring, interior walls
and doors, cabinetry, and  furniture.   The  three  principal types
of products containing  UF-resin are particleboard, medium-density
fiberboard (MDF), and hardwood plywood.
     Particleboard  is composition board comprised of 6  to 10
percent resin (by weight), and small wood  particles.   UF  resin is
used in the majority of particleboard  (about 90  percent of  total
production capacity).   The 1983 production of  particleboard was
over 3  billion square feet, of which 70 percent  was used  in
furniture, fixtures, cabinets, and similar products.   The
remaining 30 percent was used  for construction,  including deckina
in manufactured home manufacture and flooring  underlayment  in
conventional housing.
     Recent data indicate  that particleboard is  used in home
construction at a rate  of  0.16 square  feet (ft2) (~ 0.5 m2) ner  1
cubic foot (ft^)  of indoor air volume  in mobile  homes.  The

                               6-5

-------
loading rate (ft2/ft3) in conventional homes  is  lower on average,
approximately 0.05 ft2/ft3  (~ 0.17 m2/m3)  (see Table 6-2).
However/ loading rates in conventional homes  may vary
considerably from homes that contain only  particleboard as a
cabinet material to homes whose floors are constructed with
particleboard underlayment.
     MDF is also a composition board.  It  is  comprised of wood
fibers and 8 to 14 percent  UF resin solids by weight.
Approximately 95 percent of MDF production (over 600 million
square feet in 1983) was used to manufacture  furniture, doors,
fixtures,  and cabinetry.  No data are available on the precise
extent of  MDF's use in either mobile or conventional homes.
     Unlike the two composition boards discussed above, hardwood
plywood is a laminated product; the resin  is  used as a glue to
hold thin  layers of wood and veneers toqether.  Of the nearly 4.3
billion sguare feet consumed in 1983, 55 percent was used for
indoor paneling, 30 percent for furniture  and cabinets, and 15
percent for doors and laminated flooring.
                               6-6

-------
  Table 6-2 .   Use of Pressed-wood Products
                                                in
                                             Construction
 Cateoorv
Mew Hoses (U.S.)«'b

Percent units containing
  Hardwood plywood paneling
  Particleboard underlayment
Average loading rates,6
  Hardwood plywood paneling
  P«rticltbo*rd und«r Uyntnt
  Partidrtotrd shelving
  P«rticl«too*rd kitchtn c«t)intts
  ToUl p«rticl«too*nj
     Homts
 Pvrctnt  units  containing
   P«rtidflOO*rd

 Avtragt  loading  rates  (nr^/m3)
   ToUl  particlcboard

 Existing Hants (U.S.)*

 Percent  units  containing   .
   Hardwood  plywood paneling
   Particleooard

 Average  loading  rate  (nrVm3)
   HardMod  plywood paneling
   Particleooard
                           SFO
 7.6
30. 5
                                     0.066
                                     0.118
                                     0.010
                                     0.039
                                     0.167
                            100
                           35.5
                           90.3
                           0.096
                           0.058
                                        of
                                                TH
                                     9.3
                                     9.2
         O.OS9
         0.092
         0.016
         0.052
         0.160
         100
                           0.145    0.100
                                                          8.5    most
                                                          1.7    most
                                              0.049
                                              0.033
                                              0.020
                                              0.059
                                              0.112
                                                                  1.0
                                                                  O.S
                                                        100      100
                   0.079    0.479
                            most
                            most
                            1.0
                            0.5
   Qita reflect  only interior uses of UF pressed wood products.
   Loading rates are for  those  hones containing these products.

.•Source:   NPA (1964)  and H?m  (1984) for conventional homes - Based on
  interpretation of  the results of a survey of 900 home builders (103
  responses)  regarding the extent of use of particleboard and harduaod
  plywood paneling in  new nones containing these products (NAHB 1984).
 Source:
  hones.
Meyer and Hermanns (1984a),  NAH8 (1984). MHI  (1984)  for mobile
 (Footnotes continued on next  page)
                                   6-7

-------
               Table  6-2.   Footnotts (continued)
**? of product surf act  arta/m* of  indoor air volunt.

<%ourct:   InttrArt  (1983)  - bastd on in-hont survtys  it 9 SFO,  1  TN.  1
 And 1 W.   Total  loiding  includts undtrUywtflt. stw1«in9 and
  SFO loadings rangtd from 0.028 to 0.491
'Source:   Scnuttt (1981)  - Bas«d on in-hoi» survtys at 31  SFO.   Avtragt
 loadings bastd on tan»s  containing thts* products.

f    SFO • Singlt family  dMtlling
     TH • TOHnhOUM
     IV • *j1tifamily dMtlling
     PW . No&ilt
                                   6-8

-------
 6.4.1.2.    HCHO  release  from  pressed-wood  products
      Each of  the pressed-wood  products  described  above  contain  UF
 resins which  release HCHO over  time.  The  release  is attributable
 to  two basic  sources (Podall,  1984):
     1. •  Free  (unreacted) HCHO  present  as  a  result of incomplete
         crosslinking during  resin cure.
     2.   Decompos.it ion of unstable UF resin  or resin-wood
         chemical species as  a  result of their intrinsic
         instability and/or due  to hydrolysis.
 Free HCHO, which is present in  cured resin, at low  levels  (<1
 percent)  is the  most significant source of HCHO release from
 pressed-wood  products in the  initial period  after  they  are
 manufactured  (Podall, 1984).  The specific time period  in whicti
 free HCHO dominates releases  is  not known.
     The  second  source, decomposition and  hydrolysis, pertains  to
 the  large proportion of HCHO-bearing species like  methylene
 ureas, urea methylene ethers, and cellulose-crosslinked species
 that may release HCHO for a much longer period of  time  (Podall,
 1984).  These species differ  in  their susceptibility to
 hydrolytic attack and decomposition, and their relative rates and
durations of release can only be hypothesized at  this time.
     Release of  HCHO from UF-resin containing pressed-wood
products  is complex/ with numerous interrelated aspects.  The
pressed-wood product manufacturing process,  and other factors,
affect the amount of each HCHO-releasing species  present  in the
 finished  product.  The resin  formulation has a direct effect on
                               6-9

-------
release; resins with a  low HCHO:urea  ratio  have, when  cured, a
lower level of free HCHO but may be less stable and more
susceptible to hydrolysis (Myers,  1984).  Other additives  to the
resin, such as acid catalysts, change the resin chemistry  and
influence the release profiles.  The  conditions under  which the
resin is cured affect bond strength,  determining to some extent
the stability of the resin components.  The character  of the wood
itself also affects HCHO release;  the more acidic the  wood, the
greater the tendency for acid hydrolysis and HCHO release
(Podall, 1984).
     Under normal use conditions,  the release of HCHO  decreases
with time,  as discussed previously.   Emission reductions linked
to product aging relate to a decrease over  time in both the HCHO
present in the board as a residual from manufacturing  and  the
latent HCHO present in  the board in hydrolytically labile  resin
and wood components.  The emission rate decay curve for a  board
is apparently exponential with time;  the residual HCHO is  emitted
at relatively high rates followed  by  a slow release of latent
HCHO.   Althouoh  the short-term emission rate behavior  of boards
has been reported in numerous studies, little quantitative
information is available on the long-term emission rates,
particularly for newer  products made  with low HCHO-urea ratio
resins or treated with  scavengers.
6.4.1.3.   Other Sources of HCHO
     Indoor HCHO concentrations may be attributable to sources
other  than pressed-wood products containing UF resin.  The other
sources can be characterized as follows:
                               6-10

-------
    o    Urea-HCHO foam insulation (UFFI) (existing homes only)

    o    Products with phenol HCHO resins (PF)
              softwood plywood
              hardboard
              wafarboard
              oriented strand board
              fibrous glass insulation
              fibrous glass ceiling tiles

    o    Consumer products that may contain HCHO resins
              upholstry fabric
              drapery fabric
              other textiles

    o    Combustion products
              unvented kerosene and gas appliances
              smoke from tobacco products
              combustion of wood or coal in fireplaces

    o    Ou td oo r a i r
              ventilation system air exchange

     Compared to pressed-wood products, with the exception of

UFFI,  the other sources are usually minor contributors to HCHO

concentrations in conventional and manufactured homes.

     The Consumer Product Safety Commission (CPSC) in 1982

prohibited the installation of UFFI in residential buildings and

schools.  Although it was later overturned by a Federal court,

the CPSC ban on UFFI caused the virtual elimination of the UFFI

industry (Formaldehyde Institute, 1984).  There is considerable

debate among the regulatory agencies'and the UFFI industry as to

the extent of long-term HCHO emissions from UFFI presently in

place (Hawthorne et al., 1983).  UFFI is not discussed in detail

in this section; refer to Versar (1986c) for further information

and references.

     Though no residential sources of HCHO have been as well-

studied as urea-HCHO foam insulation and pressed-wood products

made from UF resins, there are fairly complete data on the
                               6-11

-------
importance of pressed-wood products with PF resins, on  fabrics


treated with UF resins for permanent press, on fueled appliances,


and on cigarette smoke as sources of residential  levels.


     Common applications of PF resin pressed-wood products


include roof and wall sheathing, subflooring, and siding.  Small


amounts are used for shelving, cabinets, indoor paneling, and


fixtures (APA, 1934).  Pnenol-HCHO resins are inherently nore


stable than are UF resins, and pressed-wood products nad-e of ?F


resin emit HCHO at much lower rites than do products made with UF


resins.  The small amount of HCHO that  is emitted from  the panel


products is the result of residual HCHO that remains in the resin


(APA,  1984).


     There are several published studies on HCHO  emissions from


PF pressed-wood panel products.  Myers and Nagaoka  (1981) found


that HCHO levels in chamber tests rarely exceeded 0.1 ppm in the


presence of PF particleboard at 25°C.  Matthews et  al.  (1983,


reports X-XV) tested PF hardboard and softwood plywood  and


obtained similar results.  Myers (1983) measured higher levels


(0.3 ppm)  initially in tests of waferboard and particleboard made


with PF resins, but levels declined rapidly.  The American


Plywood Association (APA,. 1984) has submitted data  (reviewed by


Versar, 19S6c) indicating that PF-resin pressed wood products
                                                        >

emit little HCHO.


     Other generic product lines containing PF that are used in


construction applications are fibrous glass insulation  and
                               6-12

-------
ceiling  tiles.   In  1983,  as  a  result of  a  study on  HCHO  release



from consumer products  (Pickrell et al.,  1982), CPSC decided to



further  evaluate HCHO emissions  from fibrous glass  insulation and



ceilinq  .tiles.  These products,  when compared  with  other products



tested, 'were among  the  highest group of  emitters  tested  by



Pickrell et al.  (1982).   Concern about.these test results arose



because  of the high  loading  rates of these products in homes.



Under normal use conditions  (in  attics), insulation would be



subjected to temperatures much higher  than normal room



temperatures, thereby increasing potential HCHO emissions.



     Further evaluation by Matthews et al. (1983) and Matthews



and Westley (1983)  (under contract to CPSC) indicated that a



predicted increase of no  more  than 0.022 ppm in indoor HCHO level



would result from use of  new ceiling tile = or  new insulation.  As



the products age, the HCHO emission rates  and  resulting  indoor



concentrations would be expected to decline significantly.



     Available data  on  treated fabrics (Pickrell  et al., 1982,



1984) indicate that, with emission rates only  as  high as 115



ug/m2/hr, these can  be  relatively important sources in homes only



with large surface areas  of  furnishings  like draperies (at least



when new).  The data on combustion appliances  show  that  HCHO



release  is a function of  whether the appliance is tuned  and



functioning properly.   Gas stoves may  emit less than 2 to nearly



30 mg HCHO per hour  of  use;  gas  heaters  can emit  less than 5 to



over 60 mg/hr, depending  on  the  efficiency of  burning; and new



kerosene heaters emit up  to  of 3.9 mg/hr of HCHO  (Traynor et al.,
                               6-13

-------
1982; airman et al. , 1983; Fortmann et al., 1984; Traynor et al. ,



1983; Caceres et al, 1983).



     The emissions data on sidestrean cigarette  snoke range  from




20 ug per cigarette (Bardana, 1984) to nearly I.5 mg/cigarette



(reported by Matthews et al., 1984).  Several studies, however,



concur on an emission rate of 1.0 to 1.2 mg/cigarette.  The



importance of this source  is obviously related to use patterns.



Studies where numerous persons chain-smoked in a poorly



ventilated room (Timm and Smith, 1979) did indeed show that HCHO



levels were elevated after a short period of time, but other



studies (Traynor and :;itschke, 1984) in the homes of smokers



indicated that,  at a smoking rate of 10 cigarettes per day, HCHO




levels were not elevated over controls with similar loading rates



of other sources.



6.4.2.   Garment Manufacture




     The principal source of HCHO in the garment manufacturing



workplace,  is the release of HCHO from fabric treated with resins



that impart durable or permanent press properties.  The textiles




normally treated are blends of cotton, acetate,  and rayon.  These



fabrics account for 60-80 percent of the textile produced



annually.



     The resin of choice is dimethyldihydroxyethylene urea



(DMDHEU) and its alkylated derivatives.   It is estimated that



approximately 90 percent of the durable press resin market is



accounted for by DMDHEU.  Other resins used are urea-HCHO,



melamine HCHO,  and carbamate resins, plus a HCHO/sulfur dioxide



vapor phase process.
                               6-14

-------
     HCHO is released from treated fabric in three phases.  In



Phase I, any HCHO loosely held by Van der Waal forces is released



as the  fabric is dried.  Release of HCHO by this mechanism is




usually complete by the time garment workers receive the



fabric.  Surface desorption occurs during Phase II.  This



represents the release of HCHO which is not covalently bound to



the fabric, and can last up to 240 hours.  The material is



normally stored during this phase, and increased ventilation can



increase the rate at which HCHO is desorbed.  Phase III, in which



hemiacetal hydrolysis is the mechanism of release, is thought to



be the phasa of HCHO release which results in worker exposure at



the manufacturing site.  Release of HCHO by the hydrolysis



mechanism is independent of air changes, but dependent on



humidity and temperature (Ward, 1984)



6.5.   HCHO Levels in Homes and Garment Manufacturing Sites



6.5.1.   HCHO Levels in Homes



     Table 6-3 briefly summarizes the residential HCHO monitoring



studies reviewed by Versar (1986a, c).  .However, because of the



changing nature of pressed-wood products with UF resins and the



constant evolution and improvement in monitoring techniques, this



residential monitoring data base is not the most appropriate for



describing current HCHO exposure in homes.  Many data sets are



based on investigation of homes from which complaints of HCHO



symptoms have been filed; these data sets may not be



representative of average exposure because of bias toward high



concentrations.  Homes studied before 1980 were built with
                                6-15

-------
                                               Table  6-3.  Sumtary of Residential Formaldehyde Monitoring
  Study/sailing dite(s)
  (reference)	
Nujfcerof hows
                          (ppn)  or
Nu*er of samples    range of neans
                                                                                             Ran«e (pp.)
                                                         Coments
  COMVENIIOMAl HOMES
  Flaming A Associates
   New York Study
   (Iraynor A Nitschke  1964)
   Univ. Washington (1982-1963)
   (Breysse 1964)

  IBL (1979-present)
   (Ginun et al.  1963)
                                        30
                                        59
                                        24 (EE)
                                        16 (W)
        113
                      0.040
               0.007-0.IS)
                <0.I to > 1.0
                                       <0.005  to 0.214
                                       <0.005  to 0.079
                                                                              Non-complaint hows.
                                                                              Prinarily complaint hones.  Only 4 of II)
                                                                              •easuranents >0.5 ppn.

                                                                              Includes energy-efficient (It) and older.
                                                                              weatherized (W) non-complaint hones around
                                                                              the U.S.
o\
Geonet (1978)
 (Hoschandreas et al. 1978)
                                          17
       -714
a\
  Canadian UFFI/ICC  (1981)
    (UFFI/ICC 1981)
   ORNl/CPSC 40 lennessee hone
    Study (1982)
    (Hawthorne et al.  1984)

   Private Washington  labs  (1983)
    (Breysse 1984)

   UK study  (-1980-1982)
    (Everett 1983)
                                       378
                                        29
                                        25 specified
                                           conventional

                                        SO
         76
0.02 to 0.16     0.25
                <0.05 to >0.5
                                                                              Includes conventional, "experimental",  dm
                                                                              apart«ent hones around U.S.  Non conpldini
                                                                              hones.  Assuming 601 of total aldehydes i->
                                                                              fonMldehyde.

                                                                              Study of Uff I and non-UFf I hones; wean  is
                                                                              for non-UFFI hones.  (Mean M/UFFI =  0 OV1
                                                                              ppn for 1.897 hones).

                                                                              Study of UFFI and non 4JTFI homes; nedn  is
                                                                              for non-UFFI hones.  (Mean w/UFf 1 =  0 .Oil
                                                                              ppn for II hones).
                                                                              None exceeded 1.0 ppn.   45 of 76
                                                                              0.05 and 0.09 ppn.
                                    Study was of UFFI and non-UTf I hones,  mt-jo
                                    is  for non-UFFI hones.  (Mean w/UFfl , U on
                                    PP»)

-------
                                                             Table  6-3.  (continued)
Study/sampling date(s) _*_•
(reference)
Dutch study (19/1-1980)
(Van der Ual 1982)


Houston, lexas study (1980)
(Stock and ftendei 1985)





a\
.i Sacrawnto. California (1982)
-J (Uagner 1982)

San Francisco, California (1984)
(Sexton et al. 19856)

Iowa study (1980)
(Schutte et al. 1982)
SAI California survey (1984)
(SA1 1984)
— • 	 • 	 _
ber of hones lumber of sables
— — — __ 	
36


5 _
38 conventional 38
1 energy-efficient 1
conventional
19 aparUnents 19
II condoniniuns ||
3 energy-efficient 3
condoniniiMs

12 i;


SI 5)


31 3/2

6 _
64
	 . 	
Mean (pp») or
range of Means
--



—
0.04
0.0?

0.08
0.09
0.18


0.106


0.038


0.063

0.084
0.050
	 	 	
Range (pp»)
_
0.032 to 1.444
(range of
•axiauns)
0.048 to 0.602
<0.008 to 0.14
0.04 to 0. II

0.02 to 0.21
<0.008 to 0.29
0. IS to 0.20


0.0/8 to 0. 163


0.013 to 0.085


0.013 to 0.34

0.046 to 0. 153
0.018 to 0. 120
Coments
	 	 	 	
Prior to control i^loMUtion. largely
conplaint hones.

After panel coating.
Non-conplaint hones; no UFFI.







All hones less than 5 yrs old. All hcnis
«ith air exhange rates less than 0.5 per
hour.
Only 2 hones less than 6 yrs old.
39 h«es «ore than 10 yrs old.
Non-canplatnt hones.
Non-conplaint hones.

New. non -coqplaint hones.
Older, non conplaint hones.
Indiana Board of Health
 study (19f9-1983)
 (Konopinski  1983)
120
120
0.09
                                                                                           NO to 1.35
Study of UFfI and non4TF I homes; mean is
for non-UTFl nones;  includes some conpUmt
notes.  (Mean M/UTFI  -  0.05 pan for 119
hones).

-------
                                                             Table  G-3.   (continued)
Study/sanpling date(s)
(reference)	
                                        Mean (pp») or
Muter of hows     Muter of samples    range of Means
                                                            (pp»)
                                                                      Cowents
Godish (1983)
Conn (1961)

Swiss hows (1963)
 (Kuhn and Uanner 1984)

Netherlands study (1961-1982)
 (Cornet 1983 - Holland study)

Swedish horns (1975-19/7)
 (Sundin 1978)

Danish hows (1913)
 (Andersen et al. 19)5)

MOBILE HOMES

Geowt (19/8)
 (Itoschandreas et al. 19/8)

Univ. Washington (1982-1983)
 (Breysse 1984)

NHI  (1984)
 (Owners 1984)

Clayton (1900  I9UI)
 (Sinyh et al. I9fl2a)
 29
103

 46


 52


319


 23
430
259
                      84
822
                       15
              0.05
              0.021
              0.048 to 0.055
              0.58
              1.44
              0.21
              0.34
              0.62
           (adjusted)
                                                          0.03 to 0.0)       Study of UfFI and non-UFFI hows; mean i-,
                                                                             for non-UFFI hows containing no
                                                                             particleboard flooring,  cabinetry or
                                                                             paneling.  (Mean M/UFF1  = 0.01 ppm for ?B
                                                                             hows).
                              ~0.I  to O.I         Highest level prior  to occupancy
                                                          —                 Hows without particleboard, as measured l>y
                                                                             the chromotropic acid Method.

                                                          O.I to 2.0         Few details available.
                                                          0.07 to 1.8)        HOWS known to have particleboard
                                                                             construction Materials.
                                                          0.01 to 0.46        Assuming 601 of total aldehydes  is
                                                                             forMaldehyde.  Non-ccMplaint hows

                                                          <0.l to >I.O        37 of 822 wasurewnts >I.O pp.   c«plai..i
                                                                             hows.

                                                          0.24 to 0.46        3-Month old how built specifically (or  i,-.i
                                                          0.02 to 2.9         Mon complaint,  occupied and noiioccupied
                                                          (adjusted)          Concentration by how age evaded

-------
                                                              Table  6-3.   (continued)
Study/sailing date(s)
(reference)	
ftartwr of hows
                                                                         Mean  (ppm) or
                                                          r of samples    range of means      Range (pp.)
                                                                                                   Coments
Wisconsin (I960)
 (Anderson et al.  1983)

Minnesota (1960-1961)
 (Stone et al. I960

lennessee (1962-1963)
 (Hodges 1964)
Kentucky (19/9-1960)
 (Conyers 1964)

lexas study (1962-1963)
 (Univ. lexas 1963)
SA1 California survey (1964)
 (SAI 1964)

California State survey (1964)
 (Sexton et al. I985a. I985t»)
      131


      109
                                        55
                                       103
                                       121
                                                             920
      663
                                                            663
0.36


0.61


0.30

0.23


0.43


0.18



0.114


0.091
0.02 to 2.26        Mon-complaint.  occupied h«es.
                    Concentration by hoje age evaluated
                                                                                                                       ho"e «9» <* yrs.  Complaint hones
                                                           0.02 to 1.43        Complaint hones; no age data.

                                                           0.02 to 1.92        Complaint homes, see Idble 21  for data by
                                                                              how age.

                                                           0.01 to 1.99        Complaint hows, see Idble 28 for data by
                                                                              home age.

                                                           0.04 to 0.35        Non-co^>laint homes.   Excludes results (run
                                                                              one county (El Paso)  where evaporative
                                                                              coolers Mere in use.
                                                          0.068 to 0.144      Passive LBL sampler; one Meek;  non

-------
with products made of high HCHOrurea  ratio resins that are no



longer on the market; they cannot be  considered as baseline



exposures for that reason.  The most  appropriate data for



describing current exposures in mobile and conventional homes



are, therefore, those generated by random sampling of



noncomplaint homes after 1980, preferably after 1982 (when



manufacturers began using resins with mole ratios of 1.5 (F:U) or



less).  These restrictions on the "appropriate" data base still



leave a considerable volume of monitoring data on levels in



homes.  Table 6-4 summarizes the noncomplaint  (random) data on



HCHO levels in conventional and mobile homes.



6.5.2.   Manufactured Homes



     HUD has recently promulgated changes in its Manufactured



Home Construction and Safety Standards (24 CFR 3280).  The



changes, published in the FEDERAL REGISTER of  August 9, 1984  (47



FR 31996), set product emission standards for  particleboard (0.3



ppm) and plywood (0.2 ppm).  HUD believes that if the product



standards are met and no other major  emitters of HCHO are present



(e.g., medium density fiberboard), ambient levels will not exceed



0.4 ppm (EPA estimate of 0.15 ppm as  a 10 year average) under



certain temperature, humidity, and ventilation rate conditions.



The HUD regulations, however, were designed to reduce acute



reactions to HCHO and are not based on HCHO's  potential



carcinogenicity in humans.
                               6-20

-------
Table 6-4.   Sunwary of"«esidential Monitoring Data from Randomly-Sampled Hunts
Nurb«r
of harms
Convention*)
30
40
17
29
31
6
120
29
103
78
SI
Mobile
2
259
137
121
3
663
«ea/> (pom)

0.040
—
o.os
0.060
0.063
0.064
0.09
0.05
0.027
0.07
0.038

0.21
0.62
0.3S
0.18
0.114
0.091
Range (pom)

0.007 - 0.151

-------
     EPA estimates a ten-year average ambient HCHO level of O.LO
ppm for new manufactured homes.  EPA has used this estimate and
the estimated 10-year average for new homes  that  just meets the
HUD target level of 0.4 ppm  (0.15 ppm) in the quantitative cancer
risk assessment.  Another study has reported average levels of
0.54 ppm for manufactured homes less than three years old and
0.19 ppm for homes older than three years (State  of Wisconsin,
1983).   The Exposure Panel of the Workshop (1984) reported
studies that showed average  ambient levels of 0.38 ppm for
manufactured homes not subject to complaints about HCHO odor by
residents, and averages of 0.38 ppm to 0.90  ppm for complaint
homes.   Thus,  an unrealistic worst case exposure  estimate was not
used to estimate human risk.  Also, only 10  years of exposure
were assumed for manufactured homes.  Specific exposure data
follow.
     The average HCHO level  in mobile homes  appears to have
declined in recent years due to the use of lower-emittina Dressed
wood products in mobile home construction and to  the natural
decay of HCHO emissions from products in existing mobile hones.
Average levels in the existing stock of mobile homes are now
around 0.2 to 0.5 ppm/ with  mean levels in individual homes
(including complaint homes)  ranging from less than 0.1^ to over
1.0 ppm.
     This apparent decline is shown graphically in Firjure 6-1.
The Conyers (1984) study of  complaint mobile homes, initiated in
1980, showed mean HCHO levels of 0.85 ppm in new  homes.  An
                               6-22

-------
    I
         00 -
         08 -
          0 1 -
         0 • -
O>
KJ
    5     05
    s
    5
          03-
          02 -
          01 -
060
040
Oil
02*
OM
0 Ik
0 12
0 10
OM
OO6
006
IMO

!•'•

!•'•
10'k
!•»«
                                                                                      1112
                                                                                      till
 ItUtNO

-  -    IMOtl DAIAIClAVION/WISCOMSIMDAIASt I   PHtUICItOI

   0   iMOai OAIA ICOMVtHS IM4I

   A    IM2 OAIA IHOOtitS IM4I

   •   IM3MOAIA IUMIV ItXAS IM4I

   *    IM4OAIA  IMHI IM4I

   «)   IM4 OAIA ISCNIOM*I«I IMb   VCAH INMTHICMSIUOV WAS INIIIAUU
                                                                                                                                 L-J
          •      •
                 —f	1	1	1	1	1	r	1	1	1	1	\	1        r~
             1069    1970    1971    1972     1973    1074     I97&     I97C     1977    1970     1079   1000     1001     1902    1903

                                                                        VtAHOt MANUFACTURE
                                 I i'jUK.   C-l .  LEVELS IN MOBILE HOMES t OH Ht SPONGING TO VEAH OF MANUFACTURE
                                                          ~T~
                                                          I9U4

-------
 exponential  function describing  the  relationship between HCHO



 level and home age  (r2=0.35)  for the combined Singh  (1982) and




 Anderson  (1933) data (i.e.  the Clayton/Wisconsin data  set) (1200



 data points) predicts an average level of 0.5 ppm in new 1970 to



 1980 vintage mobile homes  (noncomplaint).  Results of  studies



 begun in more recent years  (University of Texas, 1984; MHE, 1984;



 Sexton  et al., 1985; Groan  et al., 1985) indicate that initial



 HCHO levels in new homes on average  fall within the range of 0.2



 to 0.3  ppm.



     Using the exponential  function describing the Clayton/



 Wisconsin data to estimate decay of HCHO emissions over time, 10




 year average concentrations can be estimated.  For initial



 concentrations in new homes of 0.5 ppm (i.e., Clayton/Wisconsin



 data set), 0.4 ppm  (i.e., the HUD target level), and 0.25 ppm




 (i.e.,   midpoint of range of recent study of new home levels), the



 10-year average concentration estimates are 0.19 ppm, 0.15 ppm,



 and 0.10 ppm, respectively.



     The fraction of homes with elevated levels of HCHO also



 appears to have declined in recent years.  Figure 6-2 shows that



 the majority of homes less than 215 days old in the Clayton/



 Wisconsin data set had HCHO concentrations above 0.4 ppm.  More



 recent  studies indicate that this fraction is decreasing.  The



 California survey of 663 mobile homes (Sexton et al. , 1985)




 reported levels exceeding 0.4 ppm only in two and three-year old



homes.   The Texas study (University of Texas, 1984) reported that
                               6-24

-------
                        too -
                         CO -
o,     FREQUENCY
I         OF
^    EXCEE DANCE
in
                         20 -
1ECENO

  A PfftCENI  •' 1.0

  • rfMCENI  > 04

  • PfftCEMI  > 0.2
                             MEDIAN
                                 2/S  SSO  S2S  1100  13/5 I65O  I92S 2200 2476 275O  3025  3300  3S75
                                                                  HOME AGE. DAYS
                     .,:IM i  (,- „' .   FIUOUENCYOF f OMMAI OtHYDE LEVELS. BY HOME AGE. EXCEEDING
                                    1 0. 04. AND 0 ? .MM., IN Cl AY ION AND WISCONSIN DAI A COMOINf D

-------
 the  highest mean  in any group of homes was 0.35 ppm  (ten hones in



 one  county less than one year old);  it is likely that one or more



 of these had levels above 0.4 pom, but not approaching  1.0 ppm.



     Levels -neasured at any one temperature and humidity can,



 however,- be misleading.  Table 6-S which illustrates  the effect



 of temperature and humidity changes on a 0.4 ppm reading at 25°C



 and  50 percent relative humidity (the HUD target) shows that



 under more extreme conditions (30°C/70 percent RH), the predicted



 level could rise  to 0.92 ppm.  Because changes in temperature and



 humidity occur over the course of a day and with seasonal weather



 fluctuations, homes without constant climate control  would



 therefore be affected.



     These data illustrate clearly that HCHO levels  in  homes are



 the functions of multiple variables; neither age nor  temperature



and humidity, nor any other variables can account for all



variations in residential levels (Versar, 1986b).



     As the foregoing illustrates, HCHO levels in new



manufactured homes were tending toward 0.4 ppm and in some cases



above,  until about 1979.  After that date, mean HCHO  levels in



new manufactured homes began to fall or level off slightly below



0.4 ppm.  Even so, peak levels above 0.4 ppm can be expected at



times du« to adverse temperature and humidity conditions.  The



freguency for such peaks is not known with confidence,  but based



on the  data available (see Tables 6-6 and 6-7, and Figure 6-1)



they could be expected to occur in a substantial fraction of new



manufactured homes.
                               6-26

-------
Table 6-5.   Potential Effects of rawperature and Relative Munidity
                Changes on Formaldehyde Air Conctnt rat ions (pa«>*
Relative htnidity
re*p<
S9f
68f
77»r
86-F
rrature
ciro
(20«C)
(25»C)
(30^)
301
0.08
0.1S
0.24
0.40
401
o.n
0.19
0.32
O.S3
SOI
0.14
0.24
0.40
0.66
601
0.17
0.29
0.48
0.79
701
0.19
0.33
O.S6
0.92
 *CilcuIat«d using equations in Myers,  1984Mfticn were developed
  primrily froi data on reUtiweiy new pressed Mood products  and new
  hovs.  ASSIMH a te^erature coefficient of 8.930 and a nuridtty
  coefficient of 0.0195.  Assumes a base fomaldeftyde aeasurement of
  0.40 pp* at 2S*C and SO percent relative hundity.
                                6-27

-------
                            Table 6-6.
         FREQUENCY OF OBSERVATIONS FOUND IN CONCENTRATION
          INTERVALS BY CLAYTON ENVIRONMENTAL CONSULTANTS
Concentration
Interval (ppn)
0.
•
•
•
•
•
•
•
•
•
1.
2.
0 -
11 -
21 -
31 -
41 -
51 -
61 -
71 -
81 -
91 -
1 -
1 -
Number
.10
.20
.30
.40
.50
.60
.70
.80
.90
1.00
2.00
3.00
of homes
Percent of
<0.5yrs >0.5
3.
7.
6.
7.
5.
6.
5.
5.
6.
12.
24.
7.
6
9
5
2
3
5
8
8
5
2
5
9
139
a.
4.
36.
16.
0.
12.
16.
4.
0.
4.
0.
0.
2
Sanpled Homesa
-1 yr All
0
0
0
0
0
0
0
0
0
0
0
0
5
8.
19.
14.
9.
5.
4.
4.
3.
3.
7.
14.
4.
Homes
1
7
3
3
0
6
6
9
9
7
7
2
259
a 259 "noncomplaint" mobile homes up to eight years old were
  sampled in 1980-1981.  Three measurements were typically taken
  in each single-wide home and four measurements were taken in
  each double-wide home.  The data in the Table reflect the
  average concentration measured in each home.

Source:  Versar (1986a) statistical analysis of data supplied by
         Singh et al.  (1982).
                               6-28

-------
                            Table  6-7.
         FREQUENCY OF  OBSERVATIONS FOUND IN CONCENTRATION
            INTERVALS BY WISCONSIN DIVISION OF HEALTH
Concentration
Interval (ppm)
0.
•
•
•
•
•
•
•
•
•
1.
2.
0 -
11 -
21 -
31 -
41 -
51 -
61 -
71 -
81 -
91 -
1 -
1 -
Number
.10
. 20
.30
.40
. 50
.60
.70
.80
.90
1.00
2.00
3.00
of observations
JL°-
2
29
0
10
10
13
10
7
2
2
10
0

Perc
5 yrs
.63
.0
.0
. 5
. 5
.2
. 5
.9
.6
.6
.5
.0
38
rent of
>0.5
3.
13.
21.
14.
11.
12.
8.
5 .
3.
0.
5.
0.
21
Observations'1
-1 yr All
8
6
1
6
3
2
9
6
3
0
2
5
3
14.
20.
18.
14.
9.
8.
5.
3.
2.
0.
3.
0.
Ho ne s
1
4
4
0
2
0
2
6
2
7
3
3
976
a 137 "noncomplaint" mobile homes up to nine years old were
  sampled in 1980-1981.  Each home was sampled at least six
  times at monthly intervals.  The data in the table reflect
  the results of 976 measurements.

Source:  Versar (1986a) statistical analysis of data supplied by
         Wisconsin Division of Health (1984).
                               6-29

-------
6.5.3.   Conventional Homes



     The average HCHO levels reported in several monitoring




studies of conventional homes range from less than 0.03 to 0.09



ppm  (see Table 6-4).  Newer homes and energy efficient homes with



low air exchange rates tend to have higher HCHO levels (often



exceeding 0.1 ppm) than older hoines (Versar, 1986c) .   Results of



recent studies indicate that initial HCHO levels in new



cofiventional homes generally fall within the range of 0.05 to 0.2



ppm; few measurements exceeded 0.3 ppm (Stock and Mendez,  1985?



Hawthorne et al., 1984; SAI, 1984; Wagner,  1982).  Computer



modeling to estimate initial HCHO levels in conventional homes



built using significant amounts of pressed wood (i.e., either



underlayment,  paneling or both) yields values ranging from 0.1 to



0.2 ppm (Versar,  1986 ).  Using the exponential decay function




described in Section 6.5.2, the 10 year average concentration for



a home with an initial concentration of 0.15 ppm (i.e.,



approximate midpoint of range of new home levels) is estimated to



be 0.07 ppm.  Summaries of some of the major HCHO monitoring



studies are presented below.



     The Lawrence Berkeley Laboratory (LBL) has summarized HCHO




concentrations in 40 residential indoor environments since 1979



(Girman et al., 1983).  They have found that HCHO concentrations



in homes designed to be energy-efficient are somewhat higher than



concentrations in conventional homes.   The maximum reported value



is. 0.214 ppm in an energy-efficient home in Mission Viejo,



California.  Data are not sufficient to allow calculation of mean




levels.

-------
     As part of  the development of an  indoor air pollution model
based on outdoor pollution and air exchange rates/ Moschandreas
et al. (1978) studied the patterns of  indoor aldehyde levels
monitored in 17  houses in the U.S.  These data can be useful if
we assume HCHO constitutes 60 percent of total aldehydes, based
on LBL data (Girman et al., 1983).  The 17 houses had an average
aldehyde concentration of 0.09 ppm.  Applying the 60 percent
factor, the average HCHO concentration for the houses would be
0.05 ppm.  The highest mean for any one home was 0.26 ppm; the
range for that home was 0.2 to 0.45 ppm.  Another home with a
mean of 0.20 ppm reported a range of 0.07 to 0.5 ppm.  For no
other conventional home did levels exceed 0.4 ppm.
     A University of Iowa Study (Schutte et al. , 1981), oerfomed
for the Formaldehyde Institute, monitored 31 conventional,
detached homes not containing urea-HCHO foam insulation (UFFI)
for HCHO concentrations in the indoor air.  Samples were
evaluated in relation to outdoor HCHO concentrations, age of the
home, and other environmental factors monitored at each of the
sampled homes.  The average indoor concentration found in the
homes was 0.063 ppm (standard deviation = 0.064) with a ranrje of
0.013 to 0.34 ppm.  In only 5 of the 31 homes were average
concentrations higher than or egual to 0.1 ppm.
     The 1981 Canadian study (UFFI/ICC,. 1981) also studied nor-
UFFI homes.   Table 6-8 summarizes these data, showing that levels
in none of the 378 homes exceeded 0.2 ppm.
                               6-31

-------
    Table 6-8.   Comparison of Non-UFFI Canadian Homes
                  by Average HCHO Concentration
Av0r40fc
'OHM I uQnyQV
concentration (DOB)
«.OI
.01-. 025
.025-. 040
.040-. 055
.055-. 070
.070-. 085
.085-. 10
.1-.15
.15-. 20
Totals
MJMMr of
48
111
97
67
30
15
—
9
1
378
fltrcenugt
12.7
29.4
25.7
17.7
7.9
4.0
—
2.4
0.3
100.1
CkJRjIjtivt
percentage
12.7
42.1
67.8
85. S
93.4
97.4
-
99.8
100.)

Source:  (ffl/lCC (1981).
                          6-32

-------
     A report by Virgil J.  Konopinski  (1983) of the  Indiana State
Board of Health summarizes  the results of a series of
investigations conducted  from 1979 through  1983 to determine HCHO
levels .in conventional homes in  Indiana.  The mean HCHO level in
the  120 homes without UFFI  was 0.09 ppm  (0.05 for homes with
UFFI).  That mean could be  skewed by the maximum concentration of
1.35 ppm reported in one  home.   Neither  the age of the homes nor
the age of the UFFI installations was  reported.
     From April to mid-December  1982,  Oak Ridge National
Laboratory (ORNL) with the  U.S.  Consumer Product Safety
Commission (CPSC) studied indoor air quality in 40 east Tenessee
homes.  The objective of  the study was to increase the data base
of HCHO monitoring in a variety  of American homes and further
examine the effect of housing types, inhabitant lifestyles, and
environmental factors on  indoor  pollutant levels.
     Homes to be sampled  were selected based on a stratification
to ensure representative  home age, insulation types, and heatinq
sources.   All were voluntarily enrolled.  Twice a month, four
samplers at each location monitored HCHO levels in three rooms
and outside the house.  Samplers were  exposed to the air for
24-hour periods.  No modifications to  the residents' life  styles
were requested during these measurements.
     Table 6-9 summarizes these  data by  home age and season
(indicative of temperature  and humidity).   HCHO measurements in
the 40-home east Tennessee  study led to  the following major
conclusions:
                               6-33

-------
   Table 6-9 .   o»t/c«C »an Forbid**, concentration, (pp.,
                   " "  "      « of Agt and Season ((
                               poo Detection Limit)
*9» of house
—^—— — — — , .
all
0-5 years
5-15 yMn
older
0-5 years


5-15 years


older


all


Season
-
all
all
all
all
spring
siamer
fall
spring
suwer
fall
spring
staler
fall
spring
SMer
fall
i*
^~^^^™™™^^— •»•
0.062
0.084
0.042
0.032
0.087
0.111
0.047
0.043
0.049
0.034
0.036
0.029
0.026
0.062
0.083
0.040
s«
0.07?
0.091
0.042
0.042
0.093
0.102
0.055
0.040
0.048
0.03S
0.051
0.037
0.023
0.076
0.091
0.047
•
5903
3210
1211
1482
1210
1069
931
626
326
259
757
341
384
2593
1736
1574
n
— ^~~~a^_i
40
18
11
11












NOU:
      > • *Mn concentrations.
      s • standard aviation.
      • • ntflfctr of Mtsurvwtts.

      IneludM nom Kith and without UFFI.
        Hawthorn* tt al.  (1984)
                           6-34

-------
     (1)  The average HCHO levels exceeded 100 ppb (0.1 ppm) in 25
         percent of the homes.

     (2)  HCHO levels were found to be positively related to
         temperature in homes.  Houses with UFFI were freauently
         found to exhibit a temperature-dependent relationship
         with measured HCHO levels.

     (3)- HCHO levels generally decreased with increasing age of
         the house.  This is consistent with decreased emission
         from materials due to aging.

     (4)  HCHO levels were found to fluctuate significantly both
         during the day and seasonally.

     Studies by Breysse (1984) evaluated conventional, non-UFFI

homes.  The University of Washington studied 59 such homes;

private laboratories in the state studied an additional 25.  The

freouency distribution for measured levels are presented in Table

6-10.  A total of 6 of the 189 samples (3.1 percent) were over.

0.5 ppm and 56 samples (26.5 percent) were over 0.1 ppm.

     Traynor and Nitschke (1984) monitored indoor air pollutants

in 30 homes with and without suspected combustion (and other)

sources.  The average HCHO level observed in all the test homes

was 40 ppb; a high value of 151 ppb was found in one of the

tested residences categorized as containing new furnishings and

new paneling as a suspected pollution source.
                               6-35

-------
        Table  6-10.   frequency Distribution of Fonw)d>nydt l»v«ls
                     in UitAington Conventional  Non-lFFI HONK
Fomaldtnydt
concentration
(p.)
> 1.0
> O.S - 0.99
> 0.1 - 0.49
< 0.1
TOTAL OBSERVATIONS

Nufeer of Sarnies
S9 U. ttsn 2S Private
tae* l*t> hoMS
2 0
2 2
41 9
«8 6S
113 7ft
1-189

Frequency
(percent)
1.0
2.1
2ft. S
70.4


Source:  SrtysM (1984)
                                    6-36

-------
     The results can be summarized as follows:

    o    The  4 homes with no  identified source had a ranqe of
         means of 0.007 to 0.034 ppm.

    o    The  3 homes with new furnishings had a range of means of
         0.015 to 0.061 ppm.

    o  .  The  4 homes with cigarette smokers had a range of means
         of 0.032 to 0.060 ppm.

    o    The  18 homes with gas, coal, and wood fueled
         appliances/heaters had a range of means of 0.012 to
         0.056 ppm.

    o    The  12 homes with a combination of sources reported a
         range of means from 0.013 to 0.064.

Variations in home levels could not be attributed to combustion

sources.

     Stock and Mendez (1985) measured HCHO concentrations inside

78 homes  in the Houston, Texas area during the summer of 1980.

No mobile homes,  UFFI homes, or complaint homes were samoled.

Indoor concentrations ranged from less than 0.008 ppm to 0.29 ppm

with an average value of 0.07 ppm for detectable concentrations

(Number of samples,  N»75).  Three energy efficient condominiums

had, as a housing category, the highest mean level (0.18 ppm).

Condominiums  (N*ll), apartments (N»19), and energy-efficient

houses (N»7) represented the mid-range with mean levels of 0.09,

0.08,  and 0.07 ppm,  respectively; the mean of 38 conventional

houses was 0.04 ppm.

     Wagner (1982) measured HCHO levels in 12 California homes

that fall into a  prescribed "worst-case" category of buildinq and

occupancy characteristics (i.e., low infiltration and ventilation

rates, new construction, presence of gas stoves).  Weekly averaqe
                               6-37

-------
concentrations ranged from 0.078 to 0.163 ppm with a mean of



0.106 ppm.




     Sexton et al.  (1985) measured HCHO levels in 5 1 home



dwellings.-  Weekly average concentrations ranged from 0.013 to



0.085 ppm with a geometric mean of 0.035 ppm and an arithmetic




mean of 0.038 ppm.   Seventy-six percent of the homes were more



than 10 years old and only two were less than six years old.



     A downward tend in HCHO levels in conventional homes is seen



in Figure 6-3.  The relative proportion of low HCHO levels in



homes that have been monitored has increased over the past six



years,  and the proportion of high levels have decreased.  These



data are limited and caution in interpretation is recommended



(Versar, 1986a).



6.5.4.    Garment Worker Exposure



     HCHO levels in apparel manufacturing facilities were



generally below 3 ppm prior to 1980 (see Table 6-11).  OSHA had



established a 3 ppm TWA (time-weighed average) in 1967.  However,



OSHA is presently considering establishing a new level (see 50 FR



50412;  December 10, 1985).  The ACGIH (American Conference of



Government. Industrial Hygienists) recommended level is 1 ppm




TWA.  In recent years,  HCHO levels observed were generally below



1 ppm (see Table 6-12).   The data in Tables 6-11 and 6-12 must be



viewed with caution because in 1983, the National Institute for




Occupational Safety and Health (NIOSH) discovered that the



commercially prepared inpregnated charcoal tubes which had been



used in previous personal monitoring studies were unstable.
                               6-38

-------
          100
cr\
     LJ
     2
      D
      O
                                                                                                              MOSCHANOHEAS*!*!




                                                                                                              SIUCK ANUMCNUtZ I.I9UOOAIAI



                                                                                                              SCHUIIE «l4l. (ISaOOAIAt



                                                                                                              HAWIHURNt »t* II9A2UAIAI



                                                                                                              IHAVNUH ANONIISCHKL IliMiJ 1984 UAI A|
                       oui
                                                             OOiOl
                                                                                                      0203
                                                                                                                      0104
                                                                                                                                          04
                                                             I OHMAI IJMIVIll I UNI I NltfAIION (HHMI
                                 '"l'"i-r,-!.    | ,-tMiiii.nl y  IJisli -iliuliim  ,;  U-vcIs  in  Conwenl ional  llui..es

-------
     Table 6-11.   PRE-1980 MONITORING DATA FOR GARMENT MANUFACTURING AND
                              CLOSELY  RELATED INDUSTRIES
i«mr,/fM.m, tm
TflUlUilMU*

farvtut M««'*CtM't








t*»"«»ft titt" ovttf* ct*ttM
(l.f. • «'»»» lft«9t. ClOtH*
»«f •••VAtMtt tlO'tt. fU.)

»4.f«C tm/tf».tW-t
•»'
Witr""-"*1**
M^MllWmui.1^
^^••^•flt frvtl
»t^t^.t »r,fl
»,^,-,M ,r»»t
*t*M*»M If tl
•S
••?
«
MS
M
•S
^^,1^^**
0.1 - 1.4 (1171)'
1 • 11 (INS)'
0.1 • 2.7 (T\a«4rM. IMC)
«0.l . 1.4 (TM. 1171)'
0.15 • O.M (TWA. 1N4)'
O.I • 2.7 (TW*-«rt«. 1M«)
fl.OOC-fl.M4 (TWA>ftf1<«4l .
117})
2.000 • 1.140 (T»gu»»f »»«•).
117!)
<9f (Cri». 1171)
2. no (c«n.
• •• fttrtDt^ MMH9I14JM •Mll44)lf.
4 MM IMCI'ttO <• «•• HfOtXt.
' S««lt tyft «4M NMtflM.
J Nr«|M«l *r •*«» «| iMctf«t4.
  ••t MtKtM.
                                                                                   IS
                                          6-40

-------
Table 6-12.
RECENT MONITORING DATA FOR FORMALDEHYDE IN THE GARMENT
          MANUFACTURING INDUSTRY
SIC
C.**
mi
tin
1111







llrt


CM,
NMcN*l«r MMir4 f»tkiMit.
CMtUl MMlrltt. Olr»ln«j.
M*. ft
•TTM Skirl U.
MMtrlck MMlt« Wilt. l«.
•brrttkwrt. Ml
f»M»llM Skirl Mf. U..
llMkAllAd Skirl to.
AMrlcnt. CA
C. t. MtlkMM, to.
C. r. totktMy to.
lUftlaa Skirt to.k
t*rtm Skirl C«.
•1 !«•(*. U

•rrev Skirl U.
lr« Co«M, Nl« C.
••lltrtft |M« (•
AH*M«. t*
IN t». Iw
ftkrlc ly9*/lrr*lBCn|
•S*
•S
**lyt«Un. p*lipttlir-c*ll««.
kltMt. H|lo« kltMt; ONOMlU*
•S
•S
^ysar^..ls.
•S; f«ra»ltekr*-k«tf|<«-fc»»«< re* In
•Si f«f««l4ckydr-k«it4 r«»l»
yrMnrt4
•Si UravltftkfM-kttctf rttU
•Si OMOMU. ftttvttt, fit-
•S; f*r**l4*ky4r-k«»(4 rttln
ft t- 1*1*4. »r(-c«l
•S
•t
•t
"~:r
0.010-0. 10* |IM*-l«rta^l.vIM4)
1.0 |itr««a. IMll
1.0 (tcrrc*. IMll
1.0 ItcrcM. IMll
0.14-0. II llM*-«rt*. IMI)
0.11-0.44 (Cr«k. IMll
0.00-0.11 inu «r«». IMI)
O.II-O.tl |IIM-«ro. IMll
0.11 I»f4». IMll
IMir
0.00-0.10 IIM-*'**. IMll
O.IO-O.M |IMI-«rt*. IMI)
O.t4 (r*«k. IMll
•O.OM-3.SI (llM-f«r»WMl.lMl)
O.IS-0.41 |IUA.|r««. IMll
1.01-1. II |HM-krctlkl«« l*M.
• o^AAl
0.01-1.0) |IIU.«rc*. IMO)
0.1-1.0 |(r«k. IMO)
O.OM-0.194 rnM-Hri«Ml. IMI)
0.00-O.U (lH«-«rtt. IMll
O.IS-O.MinM-Hr»*««l. IMI)
O.II-O.M IIIM.«rct. IMI)
• .M *.U jllU.r... IMll
o.ii |»ta. IMII
0.440 |t«lllM-*rc«. IMll
0. IM^IMA-pa««l. IMO)
0.110 ('««». IMO)
J 000 (Urt(*. IMO)
0.000 Ikrrcn. *»U «n»"0«i«)
.r^:,.
i
i
i
i
i
U
i
14
10
£•
M
10
14
M
M
11
1
1*
10
10
Ml
II
10
11
U
M
1
1
1
1
1
t-.Hi
Ml 1*4
•t
•S
1
1
1
1
4
4
S
4
1.4
S
s
4
1.4
S
s
4
4
4
V
4
S
4
1.4
i
S
•S
M
•S
•t
•S

-------
                Table  6-12.   (continued)
en

NJ
JIN



»W


2142


21S1





?MI


IMS
                                  Mil f CM U.
                                   CM». M
MtMM. K


l«fl*r C«.
                                          IMMlrlct
                                       M».. M
terfctr felt !•».
••tic*. M

I to**It. lie.
• itMrct. M
                              Mttllfc l«i I«C.
                                    . CA
                                    »'|. C*.
                              •IralagM*. M
                                       rt»U.
ftferlC


M





M


M



M


•S
                                                               •.«-•.
                                                               •.M |IIM..r««. IN!)
                                                      t !•-• I! |IM-*«rt«Ml. .
                                                      • !•••.41 IIM «rr*. |MO|
                                                      • It I.II jtc.k. IMOI

                                                      It.OOO |Scrc*«. IMI)
                                                                                    •.000 (fcrtt*. |«00)
                                                      • •M-O.IM (IM
. IMI)


. IMI)
                                                      • 00 IHM.HM*Ml. IMII
                                                      1.000 ikrre.. |Ml|
                                                                                         N
                                                                                         1
                                                                                                                       10
                                                                                                                       II
       SIC
                                                          In
                                                                    *•
                              <«H IM.
                          NMlflt4 » I CM in.
                          f I CM 110
                          CIA IMri SJS *•»
                          •>Mftr »r**4 l«4lt«l«r lukt*
                          » I C*K M4.
                       ••! »»t(l'lt4 U Ikt rt>*r«MC.
                                   r«tln.
                                  c*n
                                                                                                                   for  IS
  IMl
  I* Ifct
                                          »r*«IHU«
                         U ill c«4t 1111.
                         t«*»lrt. Ik* >H«
                                                                           «**!(*
                                                                                                 «rr*
                                                                                                                     Ik*
                                                                             I.M
                                                                               M
                              4
                              1.4
                              S

                              •S


                              n
                                                                                                          •i
                                                                                                          •s
                                                                                                          •$
                                                                                                                   •s
                                                                                                                   n
                                                                                                                                 kr**lhln« I^K.
                       Ikli «••»*•, can *li« k» cUttl«U« U SIC <•*» lilt. 1111. «•< lilt.

-------
Table 6-13.  NFOSH Monitoring Data—Ranges
            by Department
(i SAMPLES)
CUTTING
(12)
(29)
COLLAR
(33)
(27)
PARTS
(30)
(46)
ASSEMBLY
r (7)>
(66)
PACKAGING
(45)
(20)
ADMINISTRATION
(30)
(26)

tf fl I
* ° 1
1 h 1
1 ° 1
1 fl 1
1 ° 1
1 0 I
1 ° 1
4 m 1
« 9 <• |
^ ft . - -. 	 „..!


1 o 1
1 ° 1
0 0.1 0.2 0.3 0.4 0.$ 0.
8 HOUR ttfA FORMALDEHYDE CoNceNtRAtloN LEVEL

-------
Thus,  the nonitoring data above may  be suspect since  the  loss of
HCHO  from the tubes was not consistent.  Consequently, the HCHO
levels  recorded most likely represent lower  levels  than actual
conditions.  The NIOSH method at that time was also used  by OSHA.
      NIOSH subsequently developed a  stable medium for collecting
the HCHO and did two in-depth industrial hyqiene studies.  The
surveys were done at two large manufacturing sites producing
men's dress shirts.  HCHO exposure levels were determined for 54
of 72 job titles in two different plants.  The number of
individuals within each job title whose exposure levels were
sampled was based on the trotal number of employees  in that
category and reflect a 95 percent confidence level that the
highest and lowest exposed individuals were  included  in the
sampling.  A summary of the data are presented in Tables  6-13 and
6-14.  These tables show that all levels of  exposure  were less
than  0.51 ppm TWA.  Also, as Table 6-13 illustrates,  the  combined
range of data was very narrow (0.01-0.39 ppm) for 5 of the 6
departments in the two plants.  The  range of mean concentrations
of all departments (0.13-0.20 ppm) is very narrow and compares
well within the overall combined mean exposure level  of 0.17 onn,
which was used for the quantitative  cancer risk assessment.   In
addition, the average exposure levels used in EPA's section 4(f)
determination (EPA, 1984), 0.23 ppm  (area) and 0.64 ppm
(personal) (Versar, 1982), were also used for this cancer risk
assessment.
                               6-43

-------
                                             Table 6-14,
U1
                             FORNU.DEHYOE. CONCENTRATION LEVELS (PPM)
                                      GARMENT MANUFACTURING

ADMINISTRATION
CUTTING
f f*l • A *K
COLLAR
PARTS
ASSEMBLY
P Art/ A/» • u<»
•ACK AGING

•r o«rri_t^
S6
11
60
76
1*9
65
(137)
— Wm__ lEtf1"-
0.01
<0.01
0.02
<0.01
*0.01
*0.01
«0.01
- 0.51
- 0.39
- 0.39
- 0.35
- 0.35
- 0.27
- 0.51)
o,n
V. ±J
0.1*1
0.16
0.20
0.1?
0,14
(0.17)

-------
     All of the determinations made  in the NIOSH studies were at
one point in time and may not reflect the variation of exposure
over a longer period.  Factors that  could affect variation  in
HCHO levels in these plants include  variation in ambient
temperature, humidity, type of fabric or resin system, and  volume
of stored materials or completed work.
     The exposure range across departments, within plants,  as
well as between plants, appears to be narrow.  Both these plants
were large manufacturing sites, producing similar products.  Both
plants had central ventilation/cooling systems.  This type  of
plant may potentially represent only 10 percent of the total
number of manufacturing sites (though up to 25-30 percent of the
workforce may work in such plants) (Ward, 1984).
6.6.   Summary
     The data presented above indicate that HCHO levels in  new
manufactured homes are generally below 0.5 ppm, with 10-year
averages for new HUD Standard homes  of 0.15 ppm or less.
However,  some fraction of new homes  experience peak levels  that
could exceed 1.0 ppm for periods of  time.  It would be expected
that as temperature/humidity exceed  75°F/50% RH, HCHO levels
would rise as Table 6-3 illustrates.  Thus, depending on heating
and cooling preferences, HCHO levels in new homes may
substantially exceed the reported mean for new homes.
     The situation is similar for conventional homes, although
reported mean levels are lower, 0.03 to 0.09 ppm.  However,
because conventional housing is much more heterogeneous, peak
                               6-46

-------
levels in some new homes may substantially exceed reported



means.  Although temperature and humidity conditions play a large



role, construction techniques which tend to limit air exchanges,



such as in energy efficient homes, and building product mixes are



also of. major importance.  The ten-year average HCHO



concentration for a new home built with significant amounts of



pressed wood is estimated to be 0.07 ppm.



     Reported HCHO levels during garment manufacture are below



1.0 ppm and in some plants below 0.5 ppm, and the NIOSH data



indicate rather tight ranges (none exceeding 0.51 ppm).  However,



much of the reported monitoring data must be approached with



caution due to the technical fault discussed earlier.  Building



design, ventilation, and temperature/humidity changes may be



responsible for daily or seasonal variations.
                               6-47

-------
                  7.    ESTIMATES OP CANCER  RISKS
     In principal, data from studies of humans are preferred for
making numerical risk estimates.  However,  as is often the case,
the available epidemiologic data on HCHO were not suitable for
low dose quantitative cancer risk estimation, mainly because of a
lack of adequate exposure information in the studies.
Accordingly, results from studies in animals were used to
estimate low-dose human cancer risk.  This is done by fitting
mathematical models to the observed animal data.  In addition,
even though the epidemiologic studies were not suitable for
quantifying a dose-response curve, those studies with observed
statistically elevated cancer risks provided some support for the
animal-based predicted upper bound risk.  This comparison, while
yielding valuable information to the assessment, should be viewed
with caution since exposure levels in these epidemiologic studies
were subject to some variation.
7.1.   Risk Estimates Baaed on Squamoua Ceil Carcinoma Data
     Data from three different studies were considered for their
appropriateness to this risk assessment, studies by Kerns et al.
(1983) (the CUT study>, Albert et al.  (1982) (the NYU study),
and Toba *t al. (1985).  Dose-response modeling was applied to
the CUT data for Fischer 344 rats using squamous cell carcinomas
of the nasal turbinates as an endpoint.  See Table 7-1 for the
statistical significance of the response in the CUT and Tobe
studies.  The NYU study provides corroborating evidence of a
similar response in another strain of rats (Sprague-Dawley).
                               7-1

-------
                                             ""'able 7^1
                    Carcinoma tumor incidence in Fischer  344  rats  and male  B6C3R1  mice
                                        Fisher Exact Test Results
I
10
             Species
             Fischer  344
             Rats of  the
             CUT Study
             (•ales and
              females
              combined)
             of the CUT
             Study (Hales)
                     Dose (ppm)
                               Control
0/156 (0)
                 2.0
                                                  5.6
                               0/159 (0)
                            2/153 (.01)


                              pf-0.24
                                                14.3
94/140 (.67)


   pf<0.01

B6C3F1 Mice
Control
0/109 (0)
2.0
0/100 (0)
5.6
0/106 (0)
14.3
2/106 (.02)
                                                pf«0.24
Fischer 344
Rats of the
Tobe ftudv
Control

0/32 (0)
                                               0.3
                                             0/32 (0)
                                 2.0
                               0/32 (0)
                                                                  15.0
 14/32 (.44)

   pf<0.01
               '- Numbers in parentheses are proportions responding.             "   ~~~
               - Fisher Exact Test p-value.  Small values indicate that the response in
                 dosed animals may be significantly different from the response in the
                 control animals.  This p-value should be compared to 0.017 for
                 significance at the 0.05 level.  This is a multiple comparison, which uses
                 a critical value of o/k for k (in this case k = 3) comparisons with the same
                 control group.

-------
                                             Table 7-1

                        Neoplastic polypoid adenoma  incidence  in  Fischer  344  rats,


                                Fisher Exact Test Results
             Species
             Polypoid
             Adenomas in
             Fischer 344 Rats
             of the CUT
             Study.
                                     Control
1/156 (1)
             Dose (ppm)
    2.0


7/159 (.04)
  pf=0.04
-j
i

-------
That study, however, was considered less appropriate for risk



estimation since it contains only one nonzero exposure



concentration, and, based on the CUT data, one would expect the



true dose-response curve in the experimental range to be highly



nonlinear'.  The Tobe study was not relied on for primary risk



estimation because a tumor response was seen only at the highest



dose group and the number of animals per group was relatively



small (32).   However,  risk estimates based on the Tobe data are



discussed in sections 7.3 and 7.4.  Although not statistically



significant,  the squamous cell carcinoma response in two B6C3F1



mice of the CUT study at 15 ppm is suggestive of carcinogenicity



from formaldehyde inhalation in another species due to the rarity



of this tumor.  This data set was not considered for dose-



response modeling,  however, because of the limited response at



the highest dose level.   The CUT study was chosen as the source



of data for several reasons:  it was an experiment by inhalation,



which is the primary route of exposure to man; the quality of the



study is considered to be high; and it includes four exposure



levels and responses at those levels for determining the shape of



the dose-response curve (Grindstaff, 1985).



     It was decided to estimate the risk of tumor to rats



chronically exposed up to time of death without intervention, or



to a terminal sacrifice at 24 months.  With some adjustments for



earlier sacrifice kills discussed below, this was estimated from



the CUT data.  The dosing regimen assumed is that of the CUT



study, where exposure was six hours per day for five days per
                               7-4

-------
week.  For estimation purposes, the animals that lived beyond 24
months were included with the animals sacrificed at 24 months.
     An adjustment was necessary to correct for animals that died
very early in the CUT study or that were sacrificed prior to 24
months.  The rats that died prior to the appearance of the first
squamous cell carcinoma at 11 months were not considered at
risk.  Rats sacrificed at 12 and 18 months would be treated as
though they would have responded in the same proportion as the
rats that remained alive at the respective sacrifice times.
     From this approach an estimate of the probability of death
with tumor within 24 months and an estimate of its variance was
obtained.   The number of animals at risk and the number with
tumors that would give the same estimates of mean and variance
for a 24-month study with no interim kills at 12 and 18 months
was determined, and used as the input data for risk analysis.
The data adjusted for sacrifice kills obtained in this manner are
0/156, 0/159, 2/153, 94/140 (figures rounded), at nominal dose
levels of 0, 2, 5.6, and 14.3 ppm.  These numbers were for the
significance tests in Table 7-1.
     Another method, which was not used, would simply omit from
the analysis all rats sacrificed prior to 24 months.  The data
adjusted for sacrifice kills by this method are 0/156, 0/159,
2/155, and 95/141.  The two constructed data sets produce a
negligible difference in estimated risk at very low doses under
the dose-response model discussed below.
                               7-5

-------
     Administered dose expressed as ambient air concentration was



used directly as the measure of dose in this assessment.  An



alternative method suggested by Casanova-Schmitz et al.  (1984)



and Starr et al. (1984) using data derived from the formation of



HCHO-DNA-adducts was not used because of the uncertainty



associated with this approach (as discussed previously).



However, use of these data reduces the maximum likelihood



estimate of risk approximately by a factor of 50 and reduces the



upper bound estimate of risk by a factor of 3.



     Since risk at low exposure levels cannot be measured



directly either by animal experiments or by epidemiologic



studies, a number of mathematical models and procedures  have been



developed to extrapolate from high to low doses.   Different



extrapolation methods may give a reasonable fit to the observed



data but may lead to large differences in the projected  risks at



low doses.   In keeping with.EPA's Guidelines for Carcinogen Risk



Assessment and the OSTP Principle Number 26, the choice  of low



dose extrapolation method is based on consistency  with current



understanding of the mechanisms of carcinogenesis  and not solely



on goodness of fit to the observed tumor data.  When data and



information are limited, and when uncertainty exists regarding



the mechanisms of carcinogenic action, the OSTP principles



suggest that models or procedures which incorporate low-dose



linearity are preferred when compatible with the limited



information available.  EPA's Guidelines recommend that  the



linearized multistage procedure be employed in the absence of
                               7-6

-------
adequate  information to the contrary and  specify  the possible
presentation of various other models for  comparative purposes.
This presentation  is given in Appendix  3.   In  addition,  see Conn
(1984), Siegel et  al.  (1983), Brown  (1984),  Sielken  (1983) and
Clement Associates (1982) for discussions concerning quantitative
methods/models for quantifying the potential risks to humans  from
HCHO based on the  Kerns et al. (1983) study.
     The behavior of eleven models used to  extrapolate risks was
examined  in Appendix 3.  These were all dichotomous models
("tumor-no tumor" models).  These models  along with their
parameter estimates, standard errors, log-likelihoods, and  2
                                                           /v
goodness-of-fit test statistics and p-values are  presented for
the CUT  Fischer 344 rat data on squamous cell carcinomas.  Those
interested in the  underlying assumptions  of  these models and
their mathematical form are referred to Appendix  4.
     Each of the eleven models listed in  Appendix 3 was  used to
extrapolate risks  from the CUT rat study.   They  were the
additive and independent forms of the probit,  logis.tic
regression, Weibull, and gamma-multihit models and the one, three
and five stage multistage models.
     The multistage model without restrictions on the order of
the polynomial in dose is the model of choice.  As discussed
above,  the Guidelines specify that unless another model  can be
justified, the linearized multistage procedure will be employed
(EPA, 1986).  In the case of HCHO, we know that it is mutagenic,
can react with nuclear material and processes, is structurally
                               7-7

-------
related to other carcinogens, is cytotoxic,  and is clearly
carcinogenic in the rat.  All reasons that taken together justify
use of the linearized multistage procedure.
     The formulation of the model for quantal response data was
preferred' to one including time as a variable.   Based on
simulation studies conducted under contract to EPA,  it was not at
all clear that inclusion of time as a variable would provide
improved estimation, and there would have been some question
about the validity of the results in this case, due to lack of
knowledge of the cause of death of experimental animals,  and due
to adjustments made for sacrifice data (Howe et al., 1984).  Risk
is summarized as model-derived point estimates and associated
upper bounds in the dose ranges of interest.  The latter
corresponds to the number from a linearized multistage model
procedure.
     Although arguments have been made that there may be a dose
level below which the added risk of cancer is zero,  there is no
consensus within the scientific community on this topic.   Through
use of mathematical models of dose-response, there is currently
no way to demonstrate either the existence or nonexistence of a
threshold.   In addition, if any thresholds exist, they are likely
to vary among members of the population at risk, and may be
modified by other environmental agents.  Therefore,  use of a
dose-response model incorporating a single threshold would
provide an estimate of an average population threshold that wouii
have little practical utility.  In the absence of clear evidence
                               7-8

-------
of a threshold and quantifiable supporting data that could be
utilized in risk assessment, it was felt that for dose-response
modeling of HCHO it should be assumed that there is no
threshold.  Such a conclusion is supported by the Consensus
Workshop on Formaldehyde (1984).  In addition,  although much data
have been developed to elucidate the possible mechanism for the
nonlinear carcinogenic response observed in the CUT rat study,
at this time low dose linearity cannot be ruled out.
     The likelihood of response was treated as equal in rats and
humans for the same exposure regimen and proportion of lifetime
exposed.   Although differences have been apparent in
susceptibility among the species that have been exposed to HCHO,
there are no data suggesting that man may be less susceptible
than rats.
     The estimated risk to rats is based on the CUT dosing
regimen for a period of 24 months, which may need to be adjusted
upward to obtain an estimate of risk for lifetime exposure.  It
may also be necessary to convert the estimated risk to a shorter
exposure duration in some cases, or to adjust for a different
exposure schedule (i.e., other than six hours per day, five days
per week).  However,  there is little scientific knowledge that
addresses these problems.  Consequently, each estimate of
lifetime risk from the model (assumed to be equivalent for humans
and rats as discussed in the proceeding issue) was multiplied by
the proportion of a human lifetime actually exposed.
Hypothetically,  then, at an exposure concentration producing a
                               7-9

-------
lifetime risk of 1/1000, the risk for exposure of half a lifetime



was estimated as 1/2000.  Similarly, if exposure was for 45 hours



per week instead of for 30 as in the CUT study, the risk



estimate would be multiplied by 45/30 = 1.5,  giving 3/2000.



Exposure of half a lifetime but at 45 hours per week would give



.5 times 1.5 times 1/1000 = 1/1333.   It should be noted that due



to the upward curvature of the dose-response curve the resultant



risk will be less than if the scaling factor were applied to dose



before substitution into the model if the factor is greater than



one,  and would be greater if the factor is less than one (in both



instances the difference would be less than 2 fold).  If the



response curve were linear there would be no difference between



scaling risk or scaling dose.  It is acknowledged that this rule



for adjustment is based on very simplified assumptions.



     The unit risk and estimated individual and population risks



to humans for various exposure categories are presented in Table



7-2.
                               7-10

-------
                                    Table  7-2.
                    ESTIMATED RISKS BASED ON SQUAMOUS  CELL
                        CARCINOMA DATA PROM  CUT STUDY.
             POPULATION RISKS  (number of excess  tumors)  APPEAR
              IN PARENTHESES BELOW  INDIVIDUAL RISK ESTIMATES.
Category

Nbbile Home
 Residents
1. Based on
   current
   monitoring
   data

2. Based on HUD
   target level
Nbnufacturers
 of /£parel    •
1. OSHA standard
2. Personal
   sample


3. Area
   sample


4. NIOSH data
Population

 7,800,000*
  777,000
Conventional
 Home Residents
Unit Risk
 6,310,000*
  Exposure
             0.10 ppn
             (112 hrs/wk
              for 10 yrs)
             0.15 ppn
             (112 hrs/wk
              for 10 yrs)
3.0 ppn
(36 hrs/wk
 for 40 yrs)

0.64 ppn
(36 hrs/wk
 for 40 yrs)

0. 23 ppn
(36 hrs/wk
 for 40 yrs)

0.17 ppn
(36 hrs/wk
 for 40 yrs)

0.07 ppn
(112 hrs/wk
 for 10 yrs)

1 ug/m3—
 0.00082 ppn
(for 70 yrs)
Maximum Likehihood
 Estimate of  Risk
  2 X 10
                                     '10
                            [81]
                  1 X 10~9 [Bl]
                                6 X lO"4
  6 X 10~7 [Bl]
  9 X 1CT9  [Bl]
                               4 X 10~9 [Bl]
  6 X 10'
                                                     rll
[Bl]
            Upper Bound
           Estimate of Risk
           1.5 X 10"4 [Bl]<
           (1,170)
                      2 X ID"4 [Bl]
                      (1,560)
                      6 X 10~3
                                                    1 X 10~3 [Bl]
                                                    (777)


                                                    4 X 10"4 [Bl]
                                                    (311)
3 X 10"4 [Bl]
(233)


1 X ID"4 [Bl]
(630)


1.3 X 10'5  [31]
* Population estimates are based on anticipated additions to the housing
 stock over the next 10 years as estimated by Schweer (1987).

**Classification under EPA's Guidelines for  Carcinogen Risk Assessment—
[Bl]=Probable Human Carcinogen.
                                       7-11

-------
7.2.   Risk Estimates Based on Polypoid Adenoma Data



     There appears to be little credible evidence that polypoid



adenomas progress to any of the malignant tumors seen in the Kern



et al. (1983) study.  However, while the adenomas should not be



combined statistically with the squamous carcinomas for hazard



identification purposes, they represent an endpoint that can be



quantified separately for analysis pruposes.



     Because it is beyond the capability of the various



extrapolation models to fit data with a negative slope, an



alternative extrapolation procedure is to drop the two highest



doses and use the data from the 2.0 ppm rat exposure group



(straight line to zero).  However, since the true slope of the



dose-response curve is unknown below 2.0 ppm,  this approach may



vastly overestimate the true risk if the curve is convex,  and



underestimate it if it is concave.  The reason the occurrence of



polypoid adenomas has a negative slope probably lies with the



fact that the cell type in the respiratory epithelium from which



these tumors arise is lost sooner and to a greater extent with



increasing dose due to squamous metaplasia.  The less respiratory



epithelium available the smaller the chance for adenomas to



develop.   Other explanations are also possible as discussed in



section 7.4.1.



     Risk estimates using polypoid adenomas appear in Table



7-3.   For polypoid adenoma as the endpoint instead of squamous



cell carcinoma there is no difference between the two procedures



described earlier to adjust for animals at risk.  The first
                               7-12

-------
    observation  of a polypoid  adenoma was  in a rat sacrificed at  10

    months.  Eliminating all rats dead of  any cause prior to that

    time and applying the method used for  the carcinoma  data leads to

    7/159 for the  response at  2 ppm with 1/156 at control,  the same

    as if all rats dead prior  to an including the 18  month sacrifice

    were excluded.
                                      Table 7-3.
                    RISK EXTIMATES  USING POLYPOID ADENOMA DATA

                                                                95 Upper
                                      Maximun Likelihood         Confidence
  Category               Cose            Estimate of Risk         Limit on  Risk

Mobile Hone
 Residents     '
 Based on HUD       0.15 ppn                 1 X 10~3               3 X 10~3
  Target Level      (112 hrs/wk
                    for 10 yrs)

Manufacturers
of Apparel
1.  Personal sample   0.64 ppn                 8 X 10~3               2 X 10~2
                   (36 hrs/wk
                    for 40 yrs)

2.  Area sample      0.25 ppn                 3 X 10~3               5 X 10~3
                   (36 hrs/wk
                    for 40 yrs)

3.  NIOSH data       0.17 ppn                 2 X 10~3               5 X 10~3
                   (36 hrs/wk
                    for 40 yrs)

Unit Risk           1 ug/m3—                                      1.7 X  KT4
                    0.00082 ppm
                   (for 70 yrs)
                                     7-13

-------
7.3.   Uncertainty in Risk Estimates

     Model-derived risk estimates should be viewed in the proper

context.  The upper bound estimate should not be viewed as a

point estimate of risk.  As the Guidelines state (EPA, 1986):

"the linearized multistage procedure leads to a plausible upper

limit to the risk that is consistent with some proposed

mechanisms of carcinogenesis.  Such an estimate, however, does

not necessarily give a realistic prediction of the risk.  The

true value of the risk is unknown, and may be as low as zero."

Other factors are also important.

     As Table 7-2 illustrates, there is a wide range between the

MLE and upper bound estimates, approximately 4 or 5 orders of

magnitude.   This illustrates the statistical uncertainty of the

estimates generated due to the input data from the study used,

which in this case is highly non-linear.  For instance, the

individual risks for apparel workers range from 1 X 10   [81] to

6 X 10"' [81].   In addition, it has been shown that the MLE is

sensitive to small changes in response data when the response is

very nonlinear in the experimental range.  For instance, the dose

giving a risk of 1 X 10   (MLE) varies significantly due to small

changes in the response data of the Kerns et al. (1983) study

(Conn,  198Sb).   The following illustrates this:
        Response at 2 ppm              Dose for Risk of
          (malignant)                   1 X 10~6 (MLE)

          1.   0 (actual)                 0.67 ppm
          2.   1/1,000                    0.0022 ppm
          3.   1                          0.0006 ppm
                               7-14

-------
     Ten perturbations of the squamous cell carcinoma data for



the Fischer 344 rats were selected by slight alteration in one of



the dose-response proportions or the elimination of a dose level



from the study in an attempt to show sensitivity to these



perturbations was examined by modeling.  These estimates appear



in Appendix 5.  It was found that,  in general, slight



perturbations of the data do not significantly disturb the



predictive power of the model for upper bound estimates.  This is



not the case for MLEs.  Only extreme perturbations significantly



affect upper bound risk estimates.   Consequently, when modeling



data that are very non-linear, one should not place great



certainty on MLE estimates.   In addition, model choice can lead



to uncertainty.  As Appendix 3 illustrates, there is a wide



divergence in risk estimates obtained using the CUT rat data.



Independent background, tolerance distribution models such as,



the probit,  logit,  and Weibull,  produce estimates indicating



virtually zero risk (probit predicts zero risk).  The independent



and additive background gamma-multihit models produce similar



results.   However,  when additive background models are used risk



estimates are much higher, with the multistage model giving the



highest risks.  As discussed in section 7.1, the linearized  ,



multistage procedure was used for primary risk estimation.



     As discussed above, the major contributor to the uncertainty



seen in the risk estimates using the multistage model is the



steep dose-response seen in the Kerns et al (1983) study.  There



were no carcinomas at 2 ppm, 2 at 5.6 ppm, and 103 at 14.5 ppm,
                               7-15

-------
which is a 50-fold increase for only a 2.5 times increase in



dose.  If changes in respiratory rate are taken into account (the



rats at 14.3 ppm are receiving the equivalent of a 12 ppm



exposure—use of this data leads to no significant change in



estimated risks at exposures of concern) (Grinstaff, 1985),  there



is a 50-fold increase for only a doubling of the dose.



     HCHO's ability to cause rapid cell proliferation,  cell



killing and subsequent restorative cell proliferation,  its



ability to interact with single-strand DNA (during replication),



interfere with DNA repair, its demonstrated mutagenicity, and the



fact that the dose was delivered to a finite area may help



explain the abrupt increase in the response.  However,  none  of



these factors demonstrate the presence of a threshold or minimal



risk at exposures below those that cause significant



nonneoplastic responses such as cell proliferation, restorative



cell growth,  etc.  For instance, although HCHO causes varying



degrees of cell proliferation in the nasal mucosa of rats due to



HCHO exposure,  it must be remembered that there is a natural rate



of cell turnover in this tissue.  While it is low in comparison



to HCHO induced increases, it does provide the opportunity for



HCHO to react with single-strand DNA during cell replication



possibly resulting in a mutant ceil which, if proper conditions



are met,  could result in a neoplasm.  While an event such as this



may be rare,  it is not unreasonable when one considers that the



opportunities for this event to occur are great due to the



immense number of cell-turnovers which may lead to defects in
                               7-16

-------
some cells of the population of the individuals exposed.  Even



so, the marked nonlinearity of the response introduces



considerable uncertainty into any discussion of the possible



mechanism of HCHO induced carcinogenicity at exposures below the



experimental range.



     The different responses seen in the animals tested also



leads to a degree of uncertainty.   Although rats,  mice, and



hamsters have been tested in long-term bioassays,  only in rats



have statistically significant numbers of neoplasms been



observed.  Only two carcinomas were seen in mice at the highest



dose in the CUT study, but the nature of this response is



complicated by the fact that mice are able to reduce their



breathing rate to a greater extent than rats.   If this effect is



accounted for, the "dose" mice received at 14.3 ppm is



approximately that which the rats received at 5.6 ppm, where two



carcinomas were observed.  Consequently, on a. "dose" received



basis,  rats and mice may be equally sensitive to HCHO.  Although



no neoplasms were seen in the hamster study,  a number of factors



may be responsible.  First, there was poor survival.  About 40%



of the 88 hamster died before eighty weeks, and only 20 hamsters



survived ninety weeks or more.  If a response comparable to that



of the CUT study were expected, 25% or five of the hamsters



surviving ninety weeks or more would have had tumors.  However,



the duration of the study may not have permitted them to be



grossly visible.  Second, the limited pathology protocol may not



have been able to detect small tumors.  And third, the dosing
                               7-17

-------
regimen and physiologic factors (changes in breathing rate) may



have been factors (see section 4.1).



     Although the foregoing helps explain some of the species



differences observed, there remains the possibility that other,




unknown, factors may be important.  However, in any event, no



data have been developed to show that humans would respond



differently to HCHO than rats and data exist showing that rats



and monkeys respond similarly to HCHO when nasal irritation and



squamous metaplasia are used an endpoints.



     It is often useful to compare lifetime excess risks



estimated from the epidemiologic studies to those risks estimated



from animal data.  Tables 7-4 and 7-5 and Figure 7-1 present such



a comparison.  Estimated lifetime excess risk can be determined



for either occupational or domestic exposure to HCHO.  This



comparison assumes that exposure to HCHO is associated with an



increase in neoplasms at one site only and that the site-specific



excess risk observed in the epidemiological study is the excess



above a risk of one for the study population relative to the U.S.



population (Margosches and Springer, 1983).  Hence, lifetime



excess risks based on the epidemiological studies are calculated



by multiplying the excess risk observed in the epidemiologic



study by the site-specific mortality ratio.  1980 mortality data



are used in this calculation.



     The estimated lifetime excess risks were based on



significant associations observed in the Blair et al. (1986),



Vaughan et al.  (19S6a,b),  Hayes et al.  (1986),  Stroup,  Harrington



and Oakes (1982), and Harrington






                               7-18

-------
                              Table  7-4.
                 Upper Bound Risk Estimates  Based on
              the CUT Data  for Given Exposures  to HCHO
                                     Animal Based
Exposure -

Resin Worker


Furniture Worker

Patholocists
Mobile Home
Residents
(10 years)
Level (ppm)

0.
1.

0.
1.
3.
0.



24
4

1
3
2
19


Upper

5
3

1
2
6
3



X
X

X
X
X
X


Bound3
A
io'4
io-3
A
10'4
io-3
io-3
10"4


a Based on the linearized multistage model and the rat data
from Kerns et al.  (19R3).
                               7-19

-------
                                 Table 7-5

                      Estimated Lifetime Excess Risks
                 Calculated from the Epidemic-logic Studies
Exposure Author
Resins Blair et al.

Resin, Glue Vaughan et al.
HCHO & Wood Hayes et al .
Pathologists Harrington &
Shannon
Harrington &
Oakes
Anatomists Stroup
a Estimated lifetime excess risk
Site
Lung
Nasopharynx
Nasal
Cavity &
Sinuses
Nasal
Cavity &
Sinuses
Leukemia
Brain
Brain
r*
Risk
Ratio
1.32b
2.0C
3.8
1.9C
2.0
3.31
2.7
Estimated Lifetime
Excess Riska
2 X 10~2
8 X 10~4
7 X 1CT4
2 X 10"3
2 X 10~2
1 X 10"2
8 X 10~3
of site-specific deaths
- (KK-!) *|pr0protion
of site specific
leaths -»
   Mortality proportion based on 1980 deaths.


k  Analysis of white male wage workers with greater than 20 years latency
   and HCHO exposure above Oppm-year.


c  Analysis of white male wage worker with HCHO exposure greater than Oppm-
   year.
                                    7-20

-------
Pathologists
10
10
                                   -4
10"
                                                         3.2 ppm
                              io-2
                                                                             10
                                                 Stroup,   Harringtons Harringto
                                                 Brain     Oakes,      sShannon,
                                                           Brain       Leukemia
Resin Workers
                                      0.24 ppm    1.4 ppm

o-5 i

F
»-' 1 1

p
o-3 i

D-2l ID'
                                    Vaughan
                                    et al.,
                                    SNC*
                             Blair et al,
                             Nasopharynx
                                 Blair et al.,
                                 Lung- 20 yr
                                 latency
Furniture Workers
                  10
                    -5
Mobile Home
Residents
                  10
                    -5
                                0.1 pom
                               1.3 ppm
               10
                 -4
               10
                 -3
               10"
                                               Hayes et al.
                                               SVC, Controlled
                                               for high wood dust
                                               exposure
                                   0.19 ppm
10"
                              10
                                -3
                              10
                                -2
                                               T'aughan et al. ,
                                               -lasooharvnx
      Figure 7-1.  Comparison of the upper bound risks based on the animal
      data to estimated lifetime excess risks based on the epidemiological
      studies.   Animal-based upper bound risks for the identified exposure
      level to HCKO are above the line.  The estimated excess lifetime
      risks based on the observed excesses in site-specific neoplasms are
      below the line.
                                           7-21
      * Nasal sinus and cavity neoplasms.
                                            10"
                             10
                               -1

-------
and Shannon (1975) studies.  For example, when one examines lifetHls



risks from exposure to resins,  the estimated lifetime excess risk



associated with the 35% increase in lung cancer among white males



with a greater than 20 years latency reported by Blair et al. (1986)


               — 2
would be 2 X 10   and the estimated lifetime excess risk associated



with their reported 200% increase in nasopharyngeal cancers would be



8 X 10" .   The 280% increase observed by Vaughan et al., (as



reported in SAIC, 1986) for nasal sinus and cavity neoplasms in



conjunction with exposure greater than 10,000 hours to resins,



glues, and adhesives gives an estimated lifetime excess risk of 7 X



10" .  The upper bound risk for an exposure of 0.24 ppm HCHO based



on the animal data is 5 X 10" ,  and for an exposure of 1.4 ppm



HCHO, would be 3 X 10~3.



     Comparing the results reported by Hayes et al. (1986) is



more complicated since Hayes et al. do not delineate the exposed



population.  However, if one chooses an exposure group, such as



furniture workers who may be exposed to both wood dust and HCHO,



one can make some observations.   The reported exposure for



furniture workers ranges from 0.1 ppm to 1.3 ppm HCHO as an



8-hour, time-weighted-average.   Upper bound risks based on the



animal data associated with these exposures are 1 X 10"** and



2 X 10" ,  respectively.  Using the 90% increase in nasal cavity



and sinus risk observed in analyses which controlled for high



wood dust exposure, the estimated lifetime excess risk based on



the Hayes et al. study would be 2 X 10~3.



     Thus, when individual tumor types are examined, one can see



that the upper bounds are not indicating larger excesses than





                              7-22

-------
seen in certain studies given uncertainties about exposure.



Although HCHO's potential carcinogenic effects are not expected



to be limited to one site in humans because humans do not



necessarily breathe through their noses as rats do,  the analysis



described above provides a check of the risks derived from animal



data and those seen in human studies.



     Finally, a factor that can have a major bearing on



population risk estimates is the quality of the available



exposure data.  Assumptions made in reporting exposure levels can



have a major impact.  For instance, it is not uncommon during a



monitoring exercise to find a number of samples that are below



the detection limit of the analytical technique used.  Thus,  when



a mean exposure level is calculated it should be realized that if



the nondetectable (ND) samples are counted as 0 the calculated



mean will understate the actual situation.  Conversely, if the ND



samples are counted as the limit of detection, the mean win



overstate the true situation.   Another factor that can skew



exposure estimates are changes in non-governmental exposure limit



recommendations and the number of years over which the data are



collected.   Since a number of years of exposure data are often



used to calculate means, it is possible that the mean will be



weighted by samples taken prior to changes in voluntary exposure



limits.   Thus, the reported mean could be substantially



overestimating the true situation.  For instance, in the garment



industry, HCHO levels have apparently been falling since the  Late



70's and early 80's as a result of increased concern and a
                               7-23

-------
downward revision of the ACGIH recommendation for HCHO.
Consequently, an industry average calculated from data predating
1980 could cause the reported mean to be overstated.  This may
have a significant impact on the estimated population risks.  For
the apparel industry there are approximately 800,000 workers
exposed to HCHO.  The mean personal exposure level used for the
section 4(f) determination and this assessment is 0.64 ppm which
leads to population risks of <1-777 (MLE-upper bound).  If the
mean area exposure level of 0.23 ppm is used, and there is some
evidence that personnel levels may now be approaching this
figure, population risk estimates would range from <1-311, which
is a 60% induction at the high end.  However, the exposure data
for apparel workers are poor in its ability to characterize the
industry, and great confidence cannot be placed on an industry
mean as a fair representation of actual exposure levels in the
approximately 20,000 sites where workers are exposed.
     The data for mobile homes is qualitatively better in its
ability to characterize this group because of a greater number of
well conducted monitoring surveys.  Mobile home exposure studies
have been done by HUD, state and local government agencies, and
academic researchers.  Although data is generally only available
to estimate 10 year averages, data from complaint and non-
complaint homes produce 10 year averages which range  from 0.19 to
0.25 ppm.
                               7-24

-------
7.4.   Presentation of Risk Estimates
     As discussed in "Data Selection for Quantitative Analysis"
above, the recommendation is that risk estimates should be
separately derived from squamous cell carcinoma and polypoid
adenoma data.  However, three positions can be taken concerning
the presentation of the risk estimates.  One is to calculate risk
estimates separately for squamous cell carinomas and polypoid
adenomas.  The second is to add the risk estimates for an overall
estimate of carcinogenic risk,  and the third is to assume some
conversion rate for the benign tumors and then add the risk
estimates as in the second position.  These are discussed below.
7.4.1.   Separate Risk Estimates Derived From Squamous
         Cell Carcinoma and Polypoid Adenoma Data
     Because two risk estimates can be calculated, the
significance and uncertainties associated with each must be
explained.
     The squamous carcinomas observed in the Kerns et al. (1983)
study are frank evidence of carcinogenicity in the rat.  The
response at 14.3 ppm HCHO was highly significant in both sexes.
While not significant at 5.6 ppm, the observation of two squamous
cell carcinomas in 240 rats is considered biologically
significant, since the historical incidence of squamous cell
carcinomas in male and female F-344 rats is 1 in 3,000 rats (NTP,
1985).  In addition, significant numbers of squamous carcinomas
were observed in rats in two other  long-term inhalation studies
(Albert et al., 1982; and Tobe et al., 1985).  Consequently,
there is little uncertainty about the carcinoma results.
                               7-25

-------
     There is a positive dose-response relationship for squamous

ceil carcinomas in the Kerns et al. (1983) study.  However,

because of the nonlinearity of the dose-response relationship,

there is a wide divergence between the upper bound and maximum

likelihood estimates (MLE) of risk.  This introduces a large and

variable level of uncertainty into the risk estimates (see

preceeding section—Uncertainty in Risk Estimates).

     The situation for the polypoid adenoma data is not clear.

Although apparently causally related to HCHO exposure, the

statistical significance is poor.  The adenomas are not

significant at any dose level for male and female rats

separately.  Only when the response is pooled at 2.0 ppm is  there

significance.  However, even this is questionable since the

response rate in male and female rats is not comparable.  At the

5.6 ppm level responses in males and females were significantly

different from one, another. '  Moreover, two of the responses  at

2.0 ppm were borderline diagnostic calls between focal

hyperplasia and polypoid adenoma (Boorman, 1984), and if these

two responses are dropped, significance is lost at 2 ppm.  Also,

there is a negative dose-response relationship.  Several possible

explanations for these observations follow in roughly increasing

order of likelihood (SAB, 1985):

    o    lack of a causal relationship,

    o    tumor modulating factors in the rat, which are induced
         or enhanced by HCHO exposure,

    o    chance (random) fluctuations in the data,

    o    target size decreases with loss of ceil type of origin,


                               7-26

-------
    o    differences in time to tumor,

    o    differences in diagnostic efficiency between the two
         kinds of tumors, and

    o    competition with the simultaneously occurring carcinomas
        . at higher doses.

Thus, it is difficult to adequately characterize the relationship

between HCHO exposure and the polypoid adenoma response.   Because

of the negative dose-response relationship, it was necessary to

drop the two highest doses (5.6 and 14.3 ppm) and extrapolate

from 2.0 ppm to 0 (a straight line from 2.0 to 0 ppm).  Thus,  if

the true dose-response relationship is concave between 0  and 2.0

ppm,  estimated risks will be too low.  If upward convex they will

be too high (this seems more plausible given the benign and

malignant tumor responses in the Tobe et al. (1985) study and the

squamous cell carcinoma response in the Kerns et al. (1983)

study).

     As discusssed above, there is a greater level of certainty

in the squamous cell carcinoma response and risk estimates

derived from them.  Conversely, because of the nature of the

polypoid adenoma response, its weak statistical significance at

best, and the manner of risk estimation, the confidence in this

response and associated risk estimates is low.

7.4.2.   Calculate Risks Separately But Add The Risks

     The rationale for this option is that the polypoid adenomas

together with the squamous cell carcinomas observed in the Kerns

et al. (1983) study are an indication of HCHO's potential human

carcinogenicity.  Moverover,  benign tumors may be expected to


                               7-27

-------
appear in the human population (not just in the nasai cavity).



It may also be assumed that they have some ability to progress  to



cancers as a result of the promoting activity of other agents or



of the initiating agent.  Consequently, adding the risk estimates



from the'benign (polypoid adenomas) and malignant (squamous cell



carcinomas) data provides an overall estimate of carcinogenic



risk to humans.



     While such a line of reasoning is plausible, a number of



factors must be considered.



     First, if the separate risk estimates are added, that



estimated, from the squamous cell carcinoma data is dwarfed by the



estimated adenoma response.  For instance, the upper bound



estimate of risk to garment workers exposed to 0.64 ppm of HCHO



is 1 X 10~3 using squamous cell carcinoma data.  The risk



estimate based on benign tumors at the same concentration is



2 X 10~2.   Adding the two estimates gives 2.1 X 10~2.  Following



the Guidelines (EPA, 1986) this would be rounded to one



significant figure,  i.e., 2 X 10".  Thus, the contribution to



the risk estimate from the frank experimental evidence of



carcinogenic!ty is removed.  In addition, the uncertainties



unique to estimates of risk based on the squamous cell carcinoma



and polypoid adenoma data are not carried clearly forward in a



combined estimate of risk.



     The second, and major assumption is that there is



equivalence between benign and malignant tumors, i.e. a benign



tumor will progress to a cancer.  This is necessary because the
                               7-28

-------
combined risk estimate is nearly, entirely weighted by a risk



component generated from the benign polypoid adenoma tumor



data.  Since the estimate is presented as a cancer risk estimate,



equivalence (progression) must be assumed.  However, the basis



for this assumption must be reviewed.  Certainly there is much



literature on the progression of benign tumors/ but equivalence



is not automatically assumed, especially when the experimental



study (the Kerns study) suggests otherwise (see section 4.2.1).



     It may not be correct to assume that the majority of tumors



estimated for the human population from the Kerns study will



occur in the nasal cavity, since humans are not obliged to



breathe through their nose.  Consequently, it may be worthwhile



to look at the nature of benign tumors seen in the nasal cavity



of humans and animals as well as in other epithelial tissues in



humans.



     As discussed in section 4.2.1., the nature and progression



of benign tumors in the nasal cavity of rats is poorly



understood.   The polypoid adenomas observed in the Kerns et al.



(1983) study do not appear to be the benign counterparts of the



squamous cell carcinomas or other cancers observed.  The



situation for humans is similar, although based on clinical



experience some generalizations can be made.  However, it must be



remembered that the clinical cases are .the result of diverse



causes and may not share the same course as an HCHO-induced



lesion.   The following discussion is presented to highlight the



uncertainty involved in any discussion of cancer induction.
                               7-29

-------
     The common types of benign lesions seen in the nasal cavity
of humans are nasal polyps, squamous papillomas, and transitional
type papillomas.
     Nasal polyps are a common clinical condition in humans and
are frequently associated with allergic rhinitis,  inflammatory
diseases, and other disorders (Paludetti,  1983; Jacobs,  1983;
Frazer, 1984; Drake-Lee, 1984).   These polyps are not considered
to be true neoplasms, but are merely inflammatory hypertrophic
swellings (Robbins, 1974).
     On the other hand,  squamous and transitional type papillomas
are true neoplasms.  Squamous papilloma of the vestibule is the
most common tumor of the nasal cavity, representing approximately
one-third of all benign tumors found.  Malignant change is
considered a rare event (Friedmann and Osborn, 1982).
Transitional type papillomas have an incidence that is reported
to vary from 0.4 to 19 percent of all nasal and sinus neoplasms
of the mucosa (Bosley, 1984; Friedmann and Osborn, 1982; Hyams,
1971; Sellars,  1982; Lampertico et al., 1963; Seydell, 1933).
Their clinical appearance may vary from that of firm, bulky,
opaque polypoid lesions with marked vascularity to having the
same appearance as common inflammatory nasal polyps (Bosley,
1984; Perzin et al., 1981), and are variously described as
inverted squamous papilloma, cylindrical or transitional ceil
papilloma,  and inverting papilloma (Friedmann and Osborn,
1982).   The reported associated frequency of squamous cell
carcinoma with transitional papilloma is between 1.5 to 50
                               7-30

-------
percent  (Bosley, 1984; Friedmann. and Osborn, 1982; Hyams,  1971;



Snyder et al. 1972; Ridolfi et al., 1977; Lasser et al., 1976;



Vrabec,  1975; Osborn, 1970; Yamaguchi et al.,  1979; Brown,  1964).



     The most common benign mucosal gland tumor is the



microcystic papillary adenoma, which is the human counterpart of



the rat polypoid adenoma (Kerns, 1985).  In humans, these  tumors



represent 1.6 percent of all tumors of the nose and sinuses and



2.4 percent of all tumors in the nasal cavity region.   In



addition, malignant transformation has never been encountered



(Friedmann and Osborn, 1982)



     A. number of benign tumors are seen in the oral mucous



membrane of humans.  Fibromas, papillomas,  hemangiomas,



lymphangiomas, and less commonly myoblastomas and congenital



epulis.  However, in contrast approximately 90 percent of  oral



malignancies are squamous cell carcinomas (Robbins, 1974).



     The two most common benign tumors of the human larynx are



polyps and papillomas, other less common types run the gamut of



every cell type found within the larynx (Robbins, 1974).



Squamous papillomas are the most common type of benign tumors



seen in the larynx and are the most common of all childhood



laryngeal tumors.  These are frequently divided into adult and



juvenile groups.  However,  recent work has contradicted some of



the classical descriptions used to separate adult from juvenile



papillomas (Nikolaidis, 1985).



     However, while juvenile papillomas are thought not to, or to



rarely, undergo malignant transformation (Nikolaidsis, 1985; and
                               7-31

-------
Robbins, 1974) the adult type is.regarded as having the potenital
to progress to a malignancy (squamous cell carcinoma)  (Robbins,
1974).  In a study of 83 cases (73 juvenile and 10 adult)  of
tumors of the larynx, only one adult case was associated with a
squamous cell carcinoma (Nikolaidis, 1985).  This suggests a less
than one-to-one relationship between papillomas and carcinomas:
it should be pointed out that there was surgical intervention and
no follow-up.
     Although the above does not show that benign tumors caused
by HCHO will not progress to a malignant neoplasm, it  does show
the great uncertainty involved in assuming that there  is a one-
to-one relationship between risk estimates generated from benign
and malignant data sets.
7.4.3.   Calculate Risks Separately But Add the Risk After
         Assuming a Conversion Rate for the Benign Tumors
     This option is the same as the option described in section
7.4.2 except that the risk estimates generated from the benign
tumor data would be adjusted to reflect the potential  to progress
to malignancies.  This method may provide a more realistic
estimate of carcinogenic risk, but it still suffers from the
problem of adding estimates derived from different extrapolation
procedures.
     However, if one were to assume certain conversion rates
based on the bioassay and human data, overall estimates of cancer
risk can be presented.
                               7-32

-------
      In the Kerns study, 15 polypoid adenomas were observed in



the exposed groups  (see Table 4-1) versus one adenocarcinoma



(possible malignant counterpart), which is a 1:15 ratio.' For the



most  common human benign tumor of the nasal mucosa, transitional



type  papilloma, Friedmann and Osborn (1982) have documented 12



possible conversions related to between 700 and 800 papillonas, a



ratio of 1:50.  In contrast, the human counterpart of the rat



polypoid adenoma is the microcystic papillary adenoma (Swenberg



and Boreiko/  1985) which has never been reported to convert to



malignancy (Friedmann and Osborn, 1982).  In addition, multistage



carcinogenesic protocols on mouse skin and in rat liver produce



malignant to benign ratios of 1:20 to 1:100 (Swenberg and



Boreiko, 1985).  As discussed above, the conversion rates range



from  0 to about 7 percent.   Since there is uncertainty in any of



the ratios discussed, assuming a 1:10 ratio, or a 10 percent



conversion rate, appears reasonable.  If the estimates in Tables



7-2 and 7-3 are combined using a 10 percent conversion rate, then



risk estimates would be about a factor or 2.5 higher than those



based on the malignant tumor data.



7.4.4.   Other Conaiderations-Squamous Papillomaa



      In contrast to the Kerns study, the studies by Tobe and



Albert found significant numbers of squamous papillomas instead



of polypoid adenomas.  Because these tumors are of the same cell



type as the squamous cell carcinomas, these lesions are thought



to represent the benign counterpart of the carcinomas (Consensus



Workshop on Formaldehyde, 1984).  However, Takano et al. (1982)
                               7-33

-------
have questioned the importance of papillomas in relation to
carcinoma development.  In any event,  papillomas were seen in two
HCHO studies suggesting that both types of benign tumors should
be evaluated.
     The relationship between the papilloma/carcinoma response in
the Tobe and Albert studies is quite constant.   In the Tobe
study, 5 of 19 tumors observed or 26 percent were papillomas.   A
similar result was seen in the Albert study were 34 of 110 tumors
or 24 percent were papillomas.  The papilloma response is clearly
HCHO related and appeared in two strains of rats (Fischer 344 and
Sprague-Dawley rat).  It is not clear why no papillomas were
observed in the Kerns study.  However,  the behavior of papillomas
seen in the human population should also be evaluated since there
is no reason to assume that the polypoid adenoma response in the
CUT study is more important in determining human risk than the
papilloma response.
     To determine the contribution benign tumors would make to
risk estimates derived from the Tobe study, three data sets were
used to derive risk estimates.  (These estimates were not used as
primary estimators of risk because there was no response at the
lower dose levels which consequently leads to higher estimates of
risk than those derived from the CUT data. )  One consisted of
the benign tumors (5 per 32 rats), the second was the carcinoma
response (14 per 32 rats), and finally combined malignant/benign
(19 per 32 rats).  The results from the exercise appear in Table
7-6.
                               7-34

-------
                            Table 7-6.
                RISK ESTIMATES BASED ON TOBE  STUDY
               Response at 15.0     Risk Estimate     Added Risk
                ppm (32 rats)       (upper bound)     Estimates

Papilloma              5              2.3 X 10~3      5.1 X 10'3

Carcinoma             14              2.8 X 10~3

Pooled                19              2.8 X 10~3
 carcinoma/
 papiiloma


     As Table 7-6 illustrates, the benign tumors do not have any

impact on the risk estimate derived from the pooled data.  If one

were to simply add the separate benign and malignant risk

estimates, the resulting estimate would be about two times higher

than that derived from the pooled data.  Discounting the benign

estimate by 90 percent (assumes 10 percent will progress) and

then adding it to the malignant estimate gives a combined number

that is only slightly higher (3.0 X 10~3) than that derived from

the pooled data (2.8 X 10~3).  This illustrates some of the

uncertainty one encounters when using different methods of risk

estimation and, in this case, shows that if pooled or a

conversion rate is used, the benign tumors contribute little to

the risk ••timates.

7.4.5.   Conclusion

     Because of the uncertainties associated with the polypoid

adenoma data set, its statistical significance, the manner of

risk estimation, and the question of progression to malignant
                               7-35

-------
tumors, it  ia  recommended that unadjusted risk estimates (for
progression) derived from them not be added to estimates derived
from  squamous  cell carcinomas.   It is recommended that risk
estimates derived from squamous  cell carcinomas be used to
estimate human risk because of the frank expression of
carcinogenicity in the rat, evidenced by a statistically
significant, positive dose-response relationship.  Little weight
should be accorded risk estimates derived from adding adjusted
benign risks to carcinoma risks  because of the uncertainties (1)
inherent in adding risk estimates derived from different
mathematical procedures, (2) the nature of the benign tumor
response,  and  (3) uncertainties  surrounding the rate of benign to
malignant conversion.
7.5.   Summary
     Although  a number of factors that represent more or lesser
degrees of  uncertainty have been discussed above in relation to
the quantitative estimates of human cancer risk, no factor alone
or in combination with others indicates that the estimates of
risk are not reasonable as upper bounds.  The true risk could
certainly be lower, but no data or modeling procedure is
available to determine the true  risk.  Consequently, it is
recommended that the risk estimates derived from the CUT rat
squamous carcinoma data be used  as the estimates of potential
human cancer risk from exposure  to HCHO with due consideration
given to the strengths and weaknesses of the data base.
                               7-36

-------
                  8.   ESTIMATES OF HONCAHCER RISKS
8.1.   Introduction
     Although some of HCHO's noncarcinogenic effects are well
characterized, the problem of determining the dpse-reponse
characteristics in populations for these effects  remains.  This
section focuses on human data to determine if dose-response
relationships can be drawn.  Six cross-sectional  and three
controlled human studies were selected for review.  These studies
were identified by Battelle Columbus (1985) from  review articles by
Ulsamer et al. (1984) and the NRC  (1982).  From this group, six
studies were extensively analyzed  for presence of dose-response
relationships. Additional searching identified six studies which
were thought to have shown a possible dose-relationship; these were
also analyzed.  For a study to be  selected for review, the exposure
level and the prevalence or incidence of a health effect must have
been identified.
     Generally, an increase in the prevalence or  incidence of eye,
nose, or throat irritant effects with increasing  HCHO exposure was
observed across the studies.  Since exposures are identified as
ranges in seven of the studies, reductions in the prevalence or
incidence of the irritant endpoints from small changes in HCHO
levels are difficult to quantify.
     One study of randomly selected mobile home residents (Hanrahan
et al., 1984) reports a dose-response relationship between the
reporting of eye irritation and HCHO level.  Three clinical studies
of volunteers (Kulle, 1985, Andersen and Molhave, 1984, and Bender
et al., 1983) report irritant responses over several exposure
                                 8-1

-------
 levels and EPA analyzed  these data  in a similiar manner as that of
 Hanrahan et al.  (1984).  The predicted response curve of Andersen
 and Molhave and  Bender et al. are similiar to that of  Hanrahan et
 al., but the response curve for Kulle predictes lower  percentage
 response,.
     None of the twelve  studies provides adequate data to quantify
 population risks for the irritant effects of HCHO.  The studies, at
 best, provide a qualitative estimate of population response over a.
 wide exposure range and quantitative estimates of responses for
 very selected groups.
 8.2.  Studies Reviewed
     Studies examining ocular or nasal effects are reviewed since
 studies of these endpoints comprise the majority of literature
which reports both exposure level and magnitude of the effect.
 Studies which examined dermal responses were not selected since
 exposure is by either patch testing or dermal injection.  Results
 from this route of exposure are often difficult to generalize  for
dose-response relationships.  The reviewed studies are of two
designs:   cross-sectional and controlled clinical experiments.  A
 search of the literature did not reveal any case-control designed
study.   The cross-sectional studies were of mobile home residents
and of occupationally exposed workers.  In the clinicai studies,
 small groups of healthy volunteers, fewer than 30, were exposed to
 varying concentrations of HCHO and  their responses were recorded.
 8.3.  Limitations of Studies
     Even though response trends are identified for individuals
 under study, the studies reviewed have major limitations which
                                 8-2

-------
prevent their use to infer the magnitude of general population

risks.

8.3.1  Study Design Limitations

     The data on acute effects come from controlled human studies

or cross-sectional studies.  The majority of the studies were

designed as cross-sectional studies, also known as survey

studies, where random or nonrandom sampling frames were

employed.*  In addition, two of these studies' designs did not

incorporate a nonexposed or control group (Garry et al. and

Anderson et al.).  Without a control group, it is impossible to

determine the attributable magnitude of a reported symptom.

     A cross-sectional study measures the study factor level, in

this instance the HCHO level,  and disease outcome at the same

time.  This type of study does not incorporate a follow-up

period, so that the prevalence of the disease outcome, and not

the incidence, is obtained.**  Cross-sectional studies are often

used to generate hypotheses,  but they have serious limitations in

making causal inferences.

     Controlled human studies test etiologic hypotheses and can

identify acute effects.  The three controlled human studies

identified did not utilize a randomization scheme.  Study

participants were self-selected and may not be representative of

the general population.


* Use of nonrandom sampling prevents extrapolating the results
  beyond the studied population.  Random sampling, on the other
  hand, allows statistical inference from the studied population
  to the general population.
**Prevalence is the number of cases existing with the outcome at
  a single point in time.  Incidence is the number of new cases
  observed over a period of time.


                               8-3

-------
8.3.2  Bias Limitations



     Other limitations regard potential bias in the results.  The



cross-sectional studies do not control for confounding exposures,



such as other occupational exposures, and an observed effect may



not solely be due to HCHO exposure.  Second, many studies report



subjective or self-reported symptoms.  These symptoms have not been



medically verified, and thus results may be biased by over-



reporting or under-reporting.  A third problem of the cross-



sectional studies concerns the quality of the environmental



exposure measurement.  HCHO levels vary depending on the season of



the year, hour of the day, temperature, and humidity.  These



factors must be known to evaluate the intensity of the disease



endpoint.



8.4  Results



     The principal acute effects of HCHO, reported by all studies



which were extensively examined, are those of irritations to eyes,



nose, throat, upper respiratory tract, and skin.  Tables 8-1 and 8-



2 list, by study design, the prevalence or incidence of each effect



and the associated HCHO level.



     Evaluation of the results documented ia the different papers



indicates that these effects exist in varying degrees in people




exposed to HCHO.  The exposure levels may range between 0.037-3.0



ppm.  However, the intensity of the symptoms differs depending on



the location of the study (mobile homes, industry, anatomy lab), on



ambient air conditions, and on individual characteristics and



personal habits.
                                  8-4

-------
                                       TABLE 8-1  SUMMARY OF SELECTED CHOSS SECTIONAL STUDIES3'b
EXPOSURE
LEVEL (ppn) SYMPTOMS
ESTIMATED
SUBJECf OF STUDY PREVALENCE STUDY COMMENTS
<0.02-0.78
0.037
   oo
   I
   en
Cold Symptons
Headaches
Sneezing
Any nasal
 abnormality
Seborrhea
Pressure in chest
Sneezing
Inflamed
 mucous membranes

Persistent courjh
 & phlegm
Itch
Rash
Shortness of
 breath
Chest sputnum
Burning sensation
 in heart region
24C
64C
91C
females  (>16  yrs)      2.
females  (5-15 yrs)     4.
females  (>16  yrs)      1,
males &  females       1.73^
   Oil yrs)
males &  females       11.85d
males (>16 yrs)        11.74°
females  (5-15 yrs)     2.86C
males &  females       4.49d
 Oil yrs)

50 non-                  10%
hexamethylene-
tetramine workers        23%
re soreino1               17%
workers  in a             17%
tire
manufacturing           20%
plant                    11%
Texas Indoor
Air Quality
Study
Study ot mobile homes.
           Gamble et al
                    HR exposed  workers had si(jnitic\in(
                    reductions  in expiratory flow at  In
                    lung volumes, indicating
                    resistance  in small  airways
                    compared  to a rjroup of workers
                    from the entire  plant.
a
   Rattelle Columbus (
   Only those  studies when; l»otli exposure and prevalence  are represented.
h  iTev.'jIi'iu'i? r~.it jo c.il i -ul.ii »l I nin the il.il d 
-------
                                                       TABLE  8-1  (Continued)
EXPOSURE
LEVEL (ppm)
SYMPTOMS
SUBJECT OF STUD*
ESTIMATE!)
PREVALENCE
STUD*
CCMMENPS
0.02-0.05
0.04-0.09
0.19-0.44
   CO
   I
Persistent cough
 & phlegm
Itch
Rash
Shortness of breath
Chest sputnum
Burning sensation
 in heart region

Eye irritation
Nose, throat
 irritation

Eye irritation
Sinusitis
Nose, throat
 irritation
52 hexamethylene-
tetramine
resorcinol workers
34 permanent day
care center staff
13%

35%
23%
19%
23%
17%
15%
23%
70 mobile hone day  57%
care center staff   16%
                    73%
Olsen and
Dossing
Control group and 34
mobile home day care centers.

-------
TABLE 8-1 (Continued)
EXPOSURE
LEVEL (ppm)
<0. 10-2.84











0.1-0.8
03
1
0.1-3.0
















SYMPFCMS
Burning eyes
Ifetering eyes
Dry throat
Swollen glands
Diarrhea
Running nose
Sneezing
Phlegm
Inlteezing
tough
Headache
Rash
Runny nose
Dry/Sore throat
toughing
Ear, nose, throat

Cough & wheeze


Respiratory
problan
Diarrhea


Headaches


Nausea & v/oniting


Skin rash
SUBJECT OF STUD*
Residents of
mobile hones










Residents of
Mobile hones

Adults
0-12 yrs
Adults
3-12 yrs
0-2 yrs
Adults
0-12 yrs
Adults
3-12 yrs
0-2 yrs
Adults
3-12 yrs
0-2 yrs
Adults
3-12 yrs
0-2 yrs
Aiults
ESTIMATED
PREVALENCE STUD* CQMMENFS
25% Anderson Study of mobile hoaes.
20% et al.
24%
6%
10%
35%
45%
25%
17%
44%
29%
11%
34% Hanrahan et al. Study of mobile hones.
33%
28%
79% Garry et al. Mobile hones.
60% Measurement of formaldehyde
38% vary with month of measurement.
54%
61%
36%
24%
22%
19%
58%
50%
38%
0%
20%
15%
38%
0*
   m

-------
                                                    TABLE 8-1 (Continued)
EXPOSURE
LEVEL (ppm) SYMPTOMS SUBJECT OF STUDY
0.40-0.806 Cough Present-line
>5 yrs
1-5 yrs
<1 yr
Previous on line
Never on line


Phlegm Present- line
>5 yrs
i 1-5 yrs
00 <1 yr
Previous on line
Never on line
Dyspnea Present line:
>5 yrs
1-5 yrs
<1 yr
Previous on line
Never on line
ESTIMATED
PREVALENCE STUDY
Schoenberg
33% & Mitchell
30%
40%
12.5%
6.7%



26.7%
20%
26.7%
0.0%
6.7%

6.7*
20.0%
20.7%
12.5%
6.7%
COMMENTS
63 filter manufacturing workers
No significant differences
(p>.05) among any of the groups
in either FVC or FEVj 0. The
group, present line more than
5 years or more, had a lower
FEVj Q/KVC ratio; anU signifi-
cantly lower (p<0.05) MEFcQ/FVC
than the never-on-line group.












u
Kx pi is ure
                      ure tor  pi c.seri t-on- I i ne-woi ket a  only

-------
                                      TABLE .8-2 (Continued)
Level of
Bxposure (ppn)
3.0

5.0
Symptom Study Subject
Odor perception
Conjunctival
sensitivity
Nose, Throat
sensitivity
Throat dryness
Odor perception
Conj unct ival
sensitivity
Nose, Throat
sensitivity
Throat dryness
Response Author
30
80
75
15
20
190
200
10
0.24
0.40
0.80
1.60
Conj unct ival
 irritation and
 dryness in nose,
 throat

Conjunctival
 irritation and
 dryness in nose,
 throat

Conjunctival
 irritation and
 dryness in nose,
 throat

Conjunctival
 irritation and
 dryness in nose,
 throat
Healthy students
2C (19%)
                          5 (31%)
                         15 (94%)
                         15 (94%)
Andersen
and •
c  Number of conplaints among 16 subjects after a 5-hour exposure to formaldehyde.

                                         3-10

-------
                     TABLE 8-2  SUMMAPY OF  SELECTED CONTROLLED HUMAN STUDIES
 Levels of
 Exposure (ppn)
Symptom
Study Subject
Response
Author
0.1
0.2
0.5
1.0
Odor perception
Conjunctival
 sensitivity
Nose, Throat
 sensitivity
Throat dryness

Odor perception
Conjunctival
 sensitivity
Nose, Throat
 sensitivity
Throat dryness

Odor perception
Conjunctival
 sensitivity
Nose, Throat
 sensitivity
Throat dryness

Odor perception
Conjunctival
 sensitivity
Nose, Throat
 sensitivity
Throat dryness

Odor perception
Conjunctival
 sensitivity
Nose, Throat
 sensitivity
Throat dryness
                                     Anatomy lab students   133
                                      Each group contains   25
                                      six students
                                                            20
                       14
                       15

                       21

                       15

                       35
                       35

                       35

                        2

                       30
                       18

                       20

                        4

                       40
                       30

                       40

                        2
                                    Rader*3
^Response represents the log of a weighted average of the concentration x time-factor.
°Dose response trend was observed for all complaints.

                                          3-9

-------
                                     TABLE 8-2  (Continued)
 Level  of
 Exposure  (pan)
Symptom
Study Subject
Response
Author
 0.0
 0.5
 1.0
2.0
3.0
 Eye/>tose/Throat
   Irritation
 Eye  Irritation

 Nose/Throat
   Irritation

 Eye/Nose/Throa t
   Irritation
 Eye  Irritation
 ^se/Throat
   Irritation

 Eye/Nose/Throa t
   Irritation
 Eye  Irritation
 Nose/Throat
   Irritation

 Eye/Nose/Throa t
   Irritation.
 Eye  Irritation
>fose/Throat
   Irritation

 Eye/Nose/Throat
   Irritation
Eye  Irritation
Nose/Throat
  Irritation
Healthy Volunteers     3d (14%)

                      1 (41)

                      3 (14%)


                      le (10%)

                      0 (0%)
                      1 (10%)
                      6d (27%)
                                                         4  (18%)
                                                         2  (9%)
                      12d (55%)

                      10 (46%)
                      7 (32%)
                      9r (100%)

                      9 (100%)
                      2 (22%)
                                                                        Kulle
dA  total  of 22  subjects were  exposed
? A  total  of 10  subjects were  exposed
 A  total  of 9 subjects  were exposed.
                                         9-11

-------
                           Table 3-2 (continued,'
Level of
Exposure
(ppm)
0
0.35
0. 56
0.7
0.9
1.0


Sy. Tip torn
Eye
Eye
Eye
Eye
Eye
Eye

Study Subject Response Author
irritation Research Staff - Bender at al.
irritation 41.7%gh
irritation 53.8%^-
irritation 57. l%3
irritation 60.0%k
irritation 74. 1%^
9  Subjects with HCHO response time less than clean air response time.



n  Total of 12 subjects were exposed.



L  Total of 26 subjects were exposed.



J  Total of 7 subjects were exposed.
1
Total of 5 subjects were exposed.



Total of 27 subjects were exposed.
                                       8-12

-------
      Five of the studies (e.g..  Texas Air Quality,  1983,  Anderson
 et al.,  1983,  Garry at al.,  1980,  Olsen and Dossing,  .1982 and
 Hanrahan et al. ,  1984) were  of occupants of mobile  homes.   Among
 these  studies/ the  symptoms  with the  highest prevalence  across
 different age  groups  were  headaches,  muscle aches,  eye  symptoms
 (burning eyes,  watery eyes,  itchy  eyes),  nose symptoms,  and
 coughing.   Some  differences  were detected among  the different age
 groups.   The youngest groups (0-2  yrs)  experienced  a  higher rate
 of diarrhea while the adults had a relatively high  rate  of
 complaints  from headaches  (Texas Air  Quality,  1983).  Three
 studies  (Texas Air  Quality,  1983;  Anderson et al.,  1983.
 Hanrahan,  1984) report significant (p<0.05)  dose-response
 relationships  between certain acute effects and  HCHO  level. The
 Texas Air Quality (1983) study  reports  significant  increases in
 the prevalence of certain  acute  effects such as  headaches,
 sneezing, and  nasal symptoms  among occupants exposed  to  either
 1.0 ppm  HCHO or greater, or  2.0  ppm HCHO or greater.  Anderson et
 al. (1983)  reported in  occupants of a random sample of 100 mobile
 homes that  burning of the  eye was  significantly  associated with
 the level of HCHO in  the home.   Not only did the prevalence of
 burning  eyes increase significantly with increasing mean HCHO
 level, but  also the proportion of  individuals  who believed their
 burning  ey«a were related  to  household  conditions went  from 50
 percent  to  87  percent.  Hanrahan et al.  (1984) reported  a
 significant  dose-response  relationship  between burning eyes/aye
 irritation and HCHO among  study  volunteers  who lived  in  mobile
homes.   This observation had been  adjusted  for age.
                                9-13

-------
      When studies  of  mobile  home  residents  are  evaluated,  it  nust
 be  noted  that  not  only  ambient  conditions within  the  hone,  but
 also  seasonal  temperature/humidity  fluctuations can affect  the
 rates  of  off-gassing  (Anderson  and  Lundquist,  1985).   Because
 most  mobile  homes  are tightly sealed  and do not use a continuous
 influx of outside  air,  other gases  such as  carbon monoxide, which
 were  not  measured, may  contribute to  the acute  effects
 experienced  by the residents.   Hanrahan et  al.  (1984), however,
 stated that  these  factors  did not influence HCHO  levels  in  their
 study.
      In three  studies of workers  in occupational  settings,
 statistically  significant  increases in the  number of  complaints
 from acute sensory effects were observed among  workers exposed  to
 HCHO.  The reported symptoms — itch, rash,  breathing better  away
 from work, cough,  chest tightness,  burning  eyes,  running  nose ^ni
burning sensation  in the heart region — all were significantly
 increased  in a group of rubber workers exposed  to a HCHO-resin
when compared  to non-HCHO exposed workers (Gamble et  al.,
 1976).  Assessment of lung function in these workers  showed
significant reductions in expiratory  flow rates,  with the
greatest  reductions being  shown by  smokers.  Area sampling  of
 formald«hyd« showed a mean concentration of 0.06  mg/m3 for  those
workers Who were in the exposed group.  In  another study  of
acrylic-wool filter manufacturing workers exposed to  phenol-
formaldehyde resin, Schoenberg and  Mitchell  (1975) observed
significant increases in the prevalence of  cough  and  cough-plus-
phlegm symptoms when compared to never-on-line  and previous-line
                                8-14

-------
workers.  Workers  exposed  for  5 or more years had  lower  lung

function parameters  (FEV^/FVC  ratio) than a group  of workers who

had  smoked more but  who had never been consistently exposed to

resin fumes.  Breathing zone measurements of HCHO  ranged 0.40 -

0.80 ppm in this study, with higher  levels (8.48 - 13.04 ppm)

observed when cross-current fans were not operational.   Kerfoot

and Mooney (1975)  also reported nose and eye irritation  in

morticians.  These results are qualitative in nature; they

indicate that morticians who spent more time embalming than in

general funeral work more often complained of upper respiratory

irritation.  For all three studies, other chemical exposure's were

present and it is  not known to what degree the observed  effects

were due to possible interactions.

     Four studies  were of volunteers in controlled clinical

experiments.  Findings from these studies are similar to those of

mobile home and occupational populations.  Rader (1975), in

testing six student  volunteers in an anatomy laboratory, found

that the concentration levels of HCHO in ambient air are affected

by seasonal changes, time of measurements, room temperature, and

humidity level.   Dose and response showed correlations and there

was a statistically  significant increase in each of the  dose

groups ov«r the control group  for the total complaint score* of

acute effects.  The  summed complaint score was for the acute

effects:  odor perception, conjunctival sensitivity, nose/throat

irritation, throat dryness, nasal secretions, and  tear  flow.
*The complaint score was a sum of the number of complaints tines
 the severity of the response.
                               9-15

-------
     In a study by Bender at al- (1983), varying size groups of



volunteers preselected by responding positively to HCHO at 1.3



and 2.2 ppm HCHO, were exposed to HCHO or clean air for six




minutes (0, 0.35, 0.56, 0.7, 0.9, or 1.0 ppm).  Eye irritation



was measured as response time which was the length of time from



initial exposure of the subject's eyes to the gas until eye



irritation was noticed.  Subjects were also asked to rate the



severity of the response using a 0-3 scale (0=none, l=slight,



2=moderate, 3=severe).



     Although only the response at 1.0 ppm was statistically



different than clean air,  there was a trend toward earlier



response to HCHO with increasing concentration.  If the exposure



groups for 0.7 and 0.9 ppm had been larger (5 and 7 subjects,



respectively), the response might have been statistically



different than clean air.



     Severity of response was rated slightly  to moderately



irritating only at 1.0 ppm.  The rating was less than slightly



irritative for 0.35 to 0.9 ppm.  In addition, severity was rated



lower at the end of the six minute exposure indicating dimunition



of response.  This effect has been noted by Weber-Tschopp et al.



(1977) and Kane et al. (1977) (Bender et al.).



     Andersen and Molhave (1984) assessed the human health



effects associated with prolonged exposure to HCHO under



controlled thermal and atmospheric conditions.  They observed an



increasing trend in eye and nose irritation between exposure



levels of 0.3 to 2.0 mg/m^ HCHO.  Among 16 subjects, human



response increased from 19 percent to 94 percent over this
                                 8-16

-------
 exposure range.   In addition,  mean mucous flow rate  decreased  at
 the higher concentrations  of HCHO.   Changes  in airway resistance
 were significant for nasal pressure drop,  vital capacity,  and
 several  lung  function parameters.
      Finally,  Kulle (1985),  of the University of Maryland,
 examined irritant  symptomology among volunteers who  were  exposed
 randomly to HCHO concentrations of 0.5,  1.0,  2.0,  and 3.0  ppm.
 Odor  and irritation determinations  were  made  before  exposure and
 at  180 minutes after exposure  completion.  Statistically
 significant increases in the number of eye and eye/nose/throat
 combined symptoms  were observed for exposures over 2.0 ppm.  The
 number of  subjects  detecting HCHO  odor was statistically
 increased  at HCHO  levels of  0.5 ppm and  above.   Kulle notes  that
 for subjects exposed to 1.0,  2.0,  and 3.0 ppm HCHO,  a significant
 linear trend with  dose was observed for  both  odor  and eye
 irritation  and for  all eye/nose/throat irritation.
 8.5.   Discussion
     Both HUD and OSHA have  assessed the  acute  effects  due to
 HCHO.  HUD's assessment was  used to  support changes  in  the
 Manufactured Home Construction and  Safety Standards,  while OSHA's
assessment  will be  used to support  a possible  change  in OSHA's
permissible exposure level for HCHO.
     HUD'» assessment  consisted  of  an evaluation of  the cost-
benefit  relationships  of regulatory alternatives to  control -iCHO
 levels in mobile homes.  A computer  model  was developed using
data from mobile home  residents  in  Wisconsin, Minnesota, and
Washington to assess the relationship between HCHO levels and
                               8-17

-------
 mobile home  age.   The  cost  of  ilLnes3  was  calculated  for a  20-
 year  exposure  period under  various  assumptions,  such  as initial
 HCHO  concentrations  in homes,  type  and cost  of  resulting health
 effect,  and  number of  homes  and  persons  affected.   HUD used  the
 CPSC  injury-cost  model to estimate  an  average cost  of illness
 assuming that  exposure to HCHO could cause one  of several types
 of  health problems (for example, dermatitis  of  the  face or
 conjunctivitis).  The  HUD document  did not report the incidence
 or  prevalence  of  symptoms for  persons  residing  in homes with
 varying  detectable levels of HCHO.  HUD's  study method assumed
 that  75  percent of the occupants of the  mobile  home with HCHO
 would  experience a health problem,  but the concentration
 producing  this effect  was not  derived  or estimated.
     There were no data  presented in the HUD analysis which
 support  a  dose-response  relationship between sensory  effects and
 HCHO levels in mobile  homes.   Data  presented do  support a
qualitative relationship.   It  is also  important  to  note, however,
 that HUD's review does  not address  the question  of  concentration
 levels of  HCHO in the  mobile home and  the magnitude of the
possible effect on the  resident.
     OSHA has produced  an assessment of  both noncancer irritant
and canc«r effects.  For the noncancerous effects assessment,
OSHA relics on data submitted  by industry  (SOCMA, 197,9) and
certain assumptions.    SOCMA collected  information on  nose and eye
irritation from 17 industries  where HCHO exposure occurs and
calculated average exposure  levels.  OSHA only used the endpoint
 "nose irritation" in their assessment, which SOCMA  defined as the
                                 8-18

-------
ability  to detect HCHO odor.  One must assume, however, that odor

recognition coincides with eye, nose, and throat irritation.  it

may  in some individuals, but not in others.   For instance, an

individual may have a high odor threshold (1.5 ppm), but a low

eye  irritation threshold.  Odor perception  (strength) is very

subjective.*  Consequently, odor recognition and strength should

only be  used as qualitative markers of HCHO level and any

corresponding eye, nose, and throat irritation.

     In  summary  HUD's and OSHA's approaches provide some

qualitative measure of acute effects from HCHO exposure.  These

techniques, however, can not identify a true dose-response

relationship.   The individual reviewed studies can only be used

in the same manner; for qualitative estimates of population-based

risks.

     All but two of the reviewed studies estimate the prevalence

of irritant effects for a given exposure level.  Table 3-3

presents response data over a range of exposures for three acute

endpoints.  As can be seen from the table, reductions in the

prevalence of these endpoints from small changes in HCHO levels,

say from 0.4 to 0.1 ppm, are difficult to quantify.

     Only the studies by Bender et al. (1983), Andersen and

Molhave  (1984),  Hanrahan et al. (1984), and Kulle (1985)

presented response data over a range of doses so as to allow

estimation of irritation prevalence for a particular exposure


*01factory receptors can become saturated when breathing HCHO for
 a period of time and, when this occurs, people become refractory
 to the odor perception.  Also, when saturation occurs, it would
 be extremely difficult to link odor perception to the
 manifestation of symptoms such as irritation.
                               8-19

-------
                     Table 8-3.   RXPOSURR  RANGES FOR SELECTED  ENDPOINTS
    Acute Effect
Exposure Level
PrevaJ ence
Author
CD

to
o
Nose Irritation
Fye Irritation
Couqh and
Wheez inn
0.04-0.09
<0. 01-2. 84
0.10-3.00
0.19-0.44
0.04-0.09
0.10-0.09
0.40-0.80
0.02-0.05
<0. 10-2.84
0.10-1.00
0.40-0. 80
23%
45%
79%
73%
15%
57%
25%
13%
44%
54%
31*
Olsen and Dossinq
Anderson et al.
Garry et al.
Olsen and Dossinq
Olsen and Dossinq
Anderson et al.
Olsen and Dossinq
Gamble et a 1 .
Anderson et al .
Garry et al.
Schoenherq and
                                                                    Mitchel1

-------
 level.   The  data  of  Andersen  and  Molhave (1984)  and  Kulle (1985)
 have been  analyzed by  EPA  using logistic regression  analyses  for
 comparability.  Hanrahan et al. (1984) presented  in  their paper
 results  of logistic  regression analyses  of their  data.   The
 Hanrahan et  al. (1984) results were controlled for age,  gender,
 and smoking.  Figures 8-1  - 8-4 show the  percent  response
 predicted  at selected exposures for eye  irritation (Hanrahan  et
 al., 1984) and eye,  nose,  and throat irritation  (Andersen  and
 Molhave, 1984 and Kulle, 1985).   The trends for all  three  curves
 are statistically significant.  The predicted response curves  for
 Hanrahan et al.,  (1984) who studied randomly sampled mobile home
 residents,  and for Andersen and Molhave  (1984) and Bender  et  al.
 (1983), who clinically studied volunteers, are very  similiar.
 The response curve for Kulle  (1985), on  the other hand,  predicts
 a lower percentage response than  the three above  studies  for  a
 given exposure level.  Likewise,  for exposure levels above 0.5
ppm, the upper 95% confidence intervals  for predicted response
 from Kulle1s data are lower than  the 95%  confidence  bounds of the
 Andersen and Molhave and the Hanrahan et  al. predicted response
 curves.
                              8-21

-------
oo
I
ro
K)
          Figure 8-1.  Predicted  irritative response oven  a
                          range of  HCHO  levels
                   (Data from Hanrahan.  et al.  1984).
      Response  (%)
         100
          80
          60
          40
          20
                       *
                       i
                 0.1   0.2   0.3    0.4   0.5   0.6    0.7   0.8
                          Exposure Level (ppra)

              o Predicted response    *95X loner CI    *95% upper CI

-------
oo
I
t\J
          Figure  8-2.  Predicted irritative  response oven a
                          range  of HCHO levels
                (Data  from Andersen  and Molhave  1984).
     Response (%)
         100
          80
60
          40
          20
                0.2   0.4    0.6   0.8    1     1.2   1.4    1.6
                          Exposure Level (ppm)

              o Predicted response    *95% lower CI    *95% upper CI

-------
00
I
K>
          Figure  8-3
     Response (X)
         100 r
          80
60
          20
                   o
                   t
              Predicted  irritative response  oven  a
                range of  HCHO  levels
               (Data  from Kulle 1985).
                  0.5       1      1.5       2
                          Exposure Level (ppm)

              oPredicted response    *95X lower CI
                                       2.5
                                      *95X upper CI

-------
00
tSJ
in
             Figure 8-4.  Eye  irritation  response oven  a
                          range of HCHO levels
                       (Data  from  Bender,  et al.) .
     Response  (%)
         100 r
          80
60
          40
          20
                0.1   0.2
                0.3   0.4  0.5  0.6   0.7
                  Exposure Level (ppm)

                      o Response
0.8   0.9

-------
     Car* put be taken in inferring from  the  results  in  Figures



8-1 to 8-4 to the general population.  First,  three of the



studies are based on study subjects who are  volunteers and



selection bias may be present.  The one study  whose population



was randomly selected is of a cross-sectional  design, making



causation difficult to infer.  Second,  all studies had small



numbers of subjects, 16 in Andersen and Molhave, 28 in Bender et



al., 61 in Hanrahan et al., and 22 in Kulle.   Larger studies of



randomly selected subjects are needed to estimate general



population risks.



     In conclusion, none of the reviewed studies provide  adequate



data to quantify general population risks  for  the acute effects



of HCHO.   At best, the studies provide a qualitative estimate of



population responses over a wide range of  exposure and



quantitative estimates of responses for very select populations.



Consequently,  for small differences in concentration, say 0.4 to



0.8 ppm,  it is not possible to determine the change in response



rates of a given exposed population.
                                8-26

-------
                   9.
                        REFERENCES
Acheson, E.D., Gardner, M.J.,  Pannett,  B.,  Barnes,  H. R. ,
Osmond, C. and Tyalor,  C.P.   1984a .   The  Lancet  1:  6L1.

Acheson, E.D., Barnes,  H. R. ,  Gardner, M.J.,  Osmond,  C. ,
P-annett, B. and Taylor, C.P.   1984b.  The Lancet  1:  1066.

Alarie, Y.  1985.   Personal communication to Richard
Hefter.  N'o studies are known  of  the  respiratory  response
of hamsters to sensory  irritants.   However,  since hamsters
have a  trigeminal nerve syste:n, a similar response  to
sensory irritants as  seen  in  rats and mice  would be
e xpected .

Albert, R.E., Sellakumar,  A.R., Laskin, 5.,  Kuschner,  M.,
Nelson, N. , and Snyder, D. A.   1982.   Gaseous . formaldehyde
and hydrogen chloride  induction of  nasal  cancer  in  the
rat.  J. Natl. Cancer  Inst.   63:  597-603.

A?A.  1984.  American  Plywood  Association comments
pertaining to the advance  notice  of proposed rulemaking  on
formaldehyde under  section 4(f) of  the  Toxic Substances
Control Act.  Docket OPTS  62033.

Andersen, I., Lundquist,  G.R., and  Molhave,  L.   1975.
Indoor air pollution due  to chipboard used  as  a
construction material.  Atmosphere  Environment 9:1121-1127.

Anderson, H.A. , Dally, K.A. , and  Eckmann,  A.D. et al .
1983.  The epidemiology of mobile home  formaldehyde  vapor
concentration and resident's health status.   Wisconsin
Division of Health, Wisconsin  State Laboratory of Hygiene,
and University of Wisconsin Department  of Preventive
Medicine.

Anderson, H.A. , Dally, K.A.,  Hanrahan,  L.P.,  Eckmann,  A.D.,
Kanarek, M.S., and  Rankin, J.  1983.  The epidemiology of
mobile home formaldehyde  vapor concentration and  residents'
health status.  Wisconsin  Division of Health.  Report to
U.S. Environmental  Protection  Agency, EPA-905/1-83-001.
Andersen, I., and Molhave, L.
studies with formaldehyde, pp
(ed.) Formaldehyde Toxic ity.
Publishing Corporation, 1983.
                                1984.  Controlled human
                              .  154-165.   In  James  E.  Gibson
                              Washington:  Hemisphere
Ashby, J. and Ratpan, F.  1986.   Evidence  to  Associate  the
Teratogenicity of Glycerol  Formal with  Ethylene-Glycol
Monomethylether  (EGME) Rather than with Formaldehyde.
Environ. Muta. 8: 6.
                         9-1

-------
Auerbach, C., Moutschen-Dahmen,  M.,  and  Moutschen,  J.
1977.  Genetic and Cytogenetical  Effects  of  Formaldehyde
and Related Compounds.  Mutation  Res.  39:   317-362.

Ayres, P.H., Marshall, T.C.,  Sun,  J.D.,  Bond,  J.A.,  and
Hobbs, C.H.  1985.   Interaction  of Formaldehyde with
Glutathione in the Isolated/Ventilated  Perfused Lung and
the Isolated Perfused Liver.  J.  Toxicol.  Environ.  Health
15:  655-662.

Bardana, E.J.  1984.  Effect  of  cigarette srnoke on
formaldehyde data.  J. Occ. Med.  26(6):   410  (letter).

Bartnik, F.G., Gloxhuber,  CHR. ,  and  Zi-nmermann,  V.   1985.
Percutaneous Absorption of  Formaldehyde  in Rats.
Toxicology Letters 25:   L67-172.

3attelle Columbus.  1985.   Formaldehyde  Dose-Response
Estimations for Non-Cancer  Outcomes,  Draft Report.   Task
93, Contract No.  68-01-6721,  U.S.  Environmental Protection
Agency, OPTS, OTS, EED, DDB.

Battelle Columbus Laboratories.   Final  Report  on a  Chronic
Inhalation Toxicology Study in  Rats  a-vj  Mice  Exposed to
Formaldehyde to Chemical  Industry  Ins-.itute of Toxicology,
submitted September 18, 1981; revised  December 31,  1981.

Bauchinger, M. and Schmid,  E.   1985.   Cytogenetic Effects
in Lymphocytes of Formaldehyde Workers  of a  Paper
Factory.  Mutation Res. 158:  195-199.

Beall, J.R. and Ulsamer,  A.G.   1984.   Formaldehyde  and
Hepatotoxicity:  A Review.  J. Toxicol.  Environ.  Health
14: 1-21.

Bender, J.R., Mullin, L.S., Graepel,  G.J.,  and Wilson,  W.E.
1983.  Eye Irritation Response of  Humans  to  Formaldehyde.
Am. Ind. Hyg. Assoc. J.   44:  463-465.

Berg, P.  1951.  Synthesis  of labile  methyl  groups  by
guinea pig tissue in vitro.   J.  Biol.  Chem.   190: 31-38.

Bertazzi, P.A., Zochetti,  C., Pesatori,  A.,  Radice,  L.  and
Vai, T. 1984.  Mortality  of workers  exposed  to formaldehyde
in resin manufacturing.   Presented at  the XXI  Congress on
Occupational Health, Dublin,  Ireland,  September 1984.

Billings, R.E., Ku, R.H.,  Brower,  M.E.,  Dallas,  C.E.,  and
Theiss, J.C.  1984.  Disposition of  Formaldehyde (CH20)  in
Mice.  Toxicologist 4:  8.
                          9-2

-------
Blair, A., Stewart,  P., O'Berg,  M.,  Gaffey,  W.,  Walrath,
J.,  Ward, J., Bales,  R.,  Kaplan,  S.  and  Cubit,  D.   1986,
JNCI, 76: 1071-1084.

31air, A., Stewart,  P.A.,  Hoover,  R.N.,  craumeni,  J.F.  Jr.,
Walrath,  J., O'Berg,  M.,  and  Gaffey,  W.   In  Press.   Cancers
of the ^"aso/Harynx  and  Oropharynx  and Formaldehyde
Exposure.  J. Natl.  Cancer  Inst.

Qogdanffy, M.S., Morgan,  P.M.,  Morgan, K.T.,  and Starr,
T.3.  1985.  Binding Kinetics of  Fornaldehdye  to Rat and
Hunan N'asal Mucus,  and  Bovine Se run  Albumin.   Asnet-ACS DM 3
Meeting,  Boston, MA.

3oja, J.W., Nielsen,  J.A.,  Foldvary,  E.,  and  Truitt,  E.3.
Jr.  1985.  Acute Low-Level  Formaldehyde  Behavioral and
Neurochemical Toxicity  in the Rat.   Prog.  N'euro-Psycho-
Pharnacol. and Biol.  Psychiat.  9:  671-674.

Boorrnan,  G.A.  1984.   Letter  to  Dr.  James  Swenberg,  Chemical
industry Institute of Toxicology,  Research Triangle Park,
North Carolina.

Boreiko,  C.J., Couch,  D.B., and  Swenberg,  J.A.   1982.
Mutagenic and Carcinogenic  Effects of Formaldehyde.
Environ.  Sci. Res.  25:  353-367.

Bosley,  C.E. and Pruet, C.S.  1984.   Inverted  Sinonasal
Papillomas.  Ear, Nose  and  Throat  Journal  63:  509-513.

Brendel,  R.  1964.   Untersuchungen an ratten  zur
vertraeglichkeit von hexamethylentetramin
examethylenetetramine tolerance  in rats].
Arzneimittelforsch  14:  51-53.

Breysse,  P.A.  1984.  Formaldehyde levels  and  accompanying
symptoms associated  with  individuals  residing  in over 1000
conventional and mobile homes in  the  State of  Washington.
Stockholm:  August  1984,  Proc.  3rd Int'l.  Conf.  Indoor  Air
Qual. and Climate.

Brinton,  L.A., Blot,  W.J.,  Becker, J.A.,  Winn,  D, M.,
Browder,  J.P., Farmer,  J.C. and  Fraumeni,  J.F.   1984a.   A
case-control study of cancers of the nasal cavity and
paranasal sinuses.   American  Journal  of  Epidemiology 119:
896-906.

Brinton,  L.A., Blot,  W.J.  and Fraumeni,  J.F.   1984(b).
Nasal cancer in the  textile and  apparel  industries.
Submitted for publication.
                         9-3

-------
Brooks, S.M., Weiss, M.A., and  Bernstein,  I.L.   1985.
Reactive Airways Dysuction Syndrome.  J. Occup.  Med.  27-
473-476.

Brown, 3.   1964.  The Papillomatous  Tumours  of  the  Mose.
J. Laryngol. Otol. 73: 339-905.

Brown, K.G.  L934.  Risk  Assessment  of  Laboratory Rats
Exposed to  Formaldehyde Vapors.  National  Institute of
Environmental Health Sciences,  Research Triangle Park,
North Carolina.
3uckl
Barrow
Sensory
Appl
ey,  L.A., Jiang, Y.Z., Janes,  R.A.,  Morgan,  K.T.  and
iw, C.S.   1984.   Respiratory Tract  Lesions  Induced  by
iry Irritants  at  the  RDrg  Concentration.   Toxicol.
  Pharmacol. 74:  417-429.
Burge, P.S., Harries, M.G., Lam, W.K., O'Brien,  I.M.  and
Patchett, P.A.  1935.  Occupational Asthma  Due  to
Formaldehyde.  Thorax 40:  225-260.

Caceres,  T., Soto, H., Lissi, E. and Cisternas,  R.   1983.
Indoor House Pollution:  Appliance Emissions  and  Indoor
Ambient Concentrations.  Atmospheric Environment  17:
1009-1013.

Cantoni,  0. and Cattabeni, F.   1985.   Inhibition  of  DNA
Repair by Metal Compounds  and Formaldehyde.

Casanova-Schmitz, M., David, R.M., and Heck,  H.  D'A.
1984.   Oxidation of formaldehyde and acetaldehyde by NAD+-
dependent dehydrogenases in rat nasal mucosal
homogenates.  Biochem. Pharmacol. 33: 1137-1142.

Casanova-Schmitz, M. and Heck,  H. d'A.   1983.   Effects of
Formaldehyde Exposure on the Extractability of  DNA from
Proteins in the Rat Nasal  Mucosa.  Toxicol. Appl.
Pharmacol. 70:  121-132.

Caaanova-Schmitz, M. and Heck,  H.d'A.  1984.  Differential
Labelling of Rat Nasal Mucosal  DNA Fractions  by C^C]- and
C3H]-Pormaldehyde (CH20).  Toxicologist  4:  29.

Casanova-Schmitz, M., Starr, T.B. and Heck, H.D'A.   1984.
Differentiation Between Metabolic Incorporation and
Covalent Binding in the Labeling of Macromolecules in the
Rat Nasal Mucosa and Bone  Marrow by Inhaled Ci^C]- and [ H]
Formaldehyde.  toxicol. Appl. Pharmocol.  76:  26-44.

Casanova-Schmitz, M. and Heck,  H. d'A.   1984.   Effects of
Glutathione (GSH) Depletion on  Formaldehyde-Induced  DNA-
Protein Cross-Links in the Rat  Respiratory  Mucosa.
Toxicologist 4:  29.
                         9-4

-------
Commoner, B.  1976.   "Reliability of  Bacterial  Mutagenesis
Techniques to Distinguish Carcinogenic and Noncarcinogenic
Chemicals."  United States Environmental  Protection  Agency
Report No. 600/1-76/002.  PB 259934.  Springfield, VA.
l.'ational Technical Information Service.

Couiroe, Jr., J.H. et  al.  1974.  Defense  Mechanisms  of  the
Lung's  (Chap. 17).  in:  Physiology of  Respiration, po.
220-229.

Conners, J.C.  1984 (March 9).  Manufactured Housing
Institute.  Results of  a single-wide demonstration home.
Report to Shirley Wiseman, General Deputy Assistant
Secretary of Housing,  HUD, Washington, D.C.

Connor, T.H., Ward, Jr., J.B., and Legator, M.S.  1985.
Absence of Mutagenicity in the Urine of Autopsy Service
Workers Exposed  to Formaldehdye:  Factors Influencing
Mutagenicity Testing of Urine.  Int. Arch. Occup. Environ.
Health 56:  225-237.

Consensus Workshop on Formaldehyde.   1984.  Conclusions of
the Epidemiology Panel.  Little Rock, Arkansas.

Consensus Workshop on Formaldehyde.   1984.  Final Report:
Deliberations of the  Consensus Workshop on Formaldehyde,
October 3-6, 1983, Little rock, Arkansas.

Conyers, E.P.  1984.  Letter and enclosures sent to
G. Schweer (USEPA/OTS).  Frankfort, KY:   Kentucky
Department for Health Services, Radiation and Product
Safety Branch.

Cornet, J.P.  1983.   Results and conclusions of the  search
for formaldehyde in houses and retirement homes in which no
chipboard is used as  building material.   Haarlem District,
The Netherlands:  Product Analysis Agency, [In  Dutch;
English trans.]

Coyne, L.B., Cook, R.E., Mann, J.R.,  Bonyoucos,  S.,
McDonald, O.F. and Baldwin,  C.L.  1985.   Am. Ind. Hyg.
Asao. J., 46: 609-619.

Craft, T.R. and  Skopek, T.R.  1986.   Formaldehyde
Mutagenesis in Human  Lymphoblasts in vitro;  Effect  of  Dose
Rate on Cumulative Induced Mutant Fraction.  Environ. Muta.
8: 19.

Dahl, A.R. and Hadley,  W.M.  1983.  Formaldehyde Production
Promoted by Rat  Nasal Gytochrome P-450-Dependent
Monooxygenases with Nasal Decongestants,  Essences,
Solvents, Air Pollutants, Nicotine, and Cocaine as
Substrates.  Toxicol. Appl. Pharmacol. 67:  200-205.
                         9-6

-------
Casanova-Schmitz,  M. and Heck, H. d'A.   1985.  DMA-Protein
Cross-Linking Induced by Formaldehyde  (FA) in the Rat
Respiratory Mucosa:  Dependence on FA  Concentration  in
Vormal Rats and in Rats Depleted of Glutathione  (GSH).
Toxi.colegists 5:  128.

Chang, J.C.F., Gross, E.A.,  Swenberg,  J.A. and
Barrow,  C.S.  1983.  \'asal Cavity deposition
histopathology,  and cell proliferation after single or
repeatad formaldehyde exposures in 36C3F1 mice and F-344
rats.  Toxicol.  Appl. Pharmacol.  68:  161-176.

Chang, J.C.F., Steinhagen, W.H., and Barrow, C.S.  1981.
Effect of single or repeated  formaldehyde exposure on
.ninute volume of B6C3F1 mice  and F-344 rats.  Toxicol.
Appl. Pharmacol.  6: 451-459.

CUT.  1981.  Final report on a chronic  inhalation
toxicology study in rats and  mice exposed to
formaldehyde.  Chemical Industry Institute of Toxicology,
December 31, 1981.

CIR Expert Panel.   1984.  Final Report on the Safety
Assessment of Formaldehyde.    Journal ~>f  the American
College of Toxicology 3: 157-184.

Clement Associates.  1982.  Formaldehyde Risk Assessment
for Occupationally Exposed Workers.  Clements Associates,
Arlington,  VA.

Conn, M.S.   1981.   Revised carcinogenic  risk assesment  for
urea formaldehyde foam insulation:  estimates of cancer
risk due to inhalation of formaldehyde releasd'ed by  UFFI.
Washington, D.C.:   U.S. Consumer Product Safety  Commission.

Cohn, M.S.   1984.   Formaldehyde carcinogenic risk
assessment:  exposure in manufactured  housing.   In:
Comments of the staff of the  U.S. Consumer Product Safety
Commission to the Department  of Housing  and Urban
Development's Proposed Revisions of the  Manufactured Home
Construction and Safety Standards (24  CFR Part 3280), April
1984.

Cohn, M.S., DiCarlo, F.J., Turturro, A.  and Ulsamer, A.G.
1985.  Letter to the Editor:  Toxicol. and Appl. Pharmacol.
77: 363-364.

Cohn, M.S.   1985.   Personal communication on Sensitivity of
MLE Estimates.
                         9-5

-------
Dalbey, W.E.  1982.  Formaldehyde and Tumors  in  Hamster
Respiratory Tract.  Toxicology 24:  9-14.

Dallas, C.E., Theiss, J.C., Harrist,  R.B  ,  and Fairchild,
E.J.   1985.  Effects of Subchronic  Formaldehyde  Inhalation
on Minute Volume and Nasal Deposition in  Sprague-Qawley
Rats.  J. Toxicol. Environ. Health  16: 553-564.

Day, J.H., Lees, R.E.M., Clark,  R.H., and  Pattee,  P.L.
1984.  Respiratory Responses to  Formaldehyde  and Off-Gas of
Urea Formaldehyde Foan  Insulation.  Can.  Med. Assoc. J.
131: 1061-1065.

Delia  Porta, G.  and Cabral, J.G.  1970.   Studio  della
tossicita transolancentare di cancerogenesi in ratti
trattati con esametilentetramina.   [Transplacental  toxicity
and carcinogenesis studies in rats  with hexamethylene-
tetramine].  Tumori 56: 325-334.

Delia  Porta, G.  and Colnaghi, M.I.G.  1968.
Noncarcinogenicity of hexamethylenetetramine  in  mice and
rats.  Food Cosmet. Toxicol.  6: 707-715.

Delzell, E. and Grufferman.  1983.  Cancer  and other causes
of death among female textile workers, 1976-78.  Journal of
the National Cancer Institute.   71(4): 735-739.

Den Engelse, L. , Gekbbink, M. and Emmelot,  P.  1975.
Studies on lung tumors. III.  Oxidative metabolism  of
demethylnitrosamine by  rodent and human lung  tissue.  Chem.
Biol.  Interact.   11: 535-544.

Department of Housing and Urban  Development.  1981.  An
evaluation of formaldehyde problems in residential  mobile
homes.  Final Report.   Office of Policy Development and
Research, Washington, DC.

Dooley, J.F., Blackburn, G.R., Schreiner,  C.A.,  and
Mackerer, C.R.  1985.   Inhibition of  the  Mutagenicity of
Formaldehyde (HCHO) in  the L5178Y TK  +/-  Mouse Lymphoma
Assay  by Formaldehyde Dehydrogenase (FDH):  Application  to
Characterization of Mutagenic components.   EMS Abstracts: 9.

Drake-Lee, A.B., Lowe,  D. , Swanston,  A. and Grace,  A.
1984.  Clinical Profile and Recurrence of  Nasal  Polyps.
Journal of Laryngology  and Otology  98: 783-793.

DuVigneaud, V.T., Varby, W.G, and Wilson,  J.E.   1950.
Incorporation of the carbon of formaldehyde and  formate
into the methyl groups  of choline.  J. Am.  Chem. Soc. 72:
2819-2820.
                         9-7

-------
Edling, C., Odkvist, L. , and Hellquist, H.   1985.
Formaldehyde and the Nasal Mucosa.  Br. J.  Ind. Med. 42:
570-571.

Egle, J.L.  1972.  Retention of inhaled formaldehyde,
propionaldehyde, and acrolein in the dog.   Arch. Environ.
Health 25: 119-124.

Einbrodt, J.J., Prajsnar, D. and Erpenbeck,  J.  1976.  Der
formaldehyde und ameisensaeurespiegel im blut und urin beim
menschen nach formaldehyd-exposition.  [Effect of
formaldehyde exposure on people in school and living
areas.]  Zentralbl. Arbeitsmed. Arbeitsschutz Prophyl.
26(8): 154-158.

Environmental Protection Agency.  1981.  Priority Review
Level 1:  Formaldehyde.

Environmental Protection Agency.  1984a.  Formaldehyde;
Determination of Significant Risk; Advance  Notice of
Proposed Rulemaking and Notice.  49 FR 21870-21898.

Environmental Protection Agency.  1984b.  Determination of
Significant Risk.  49 FR 21880-21884.

Environmental Protection Agency.  1986.  Proposed
Guidelines for Carcinogen Risk Assessment.   49 FR 46294.

Everett, L.H.  1983.  Urea formaldehyde foam and
formaldehyde emission, UK experience with cavity wall
insulation.  A contribution to the formaldehyde workshop,
Little Rock, Arkansas.  England:  Building  Research
Station.

Fayerweather, W.E., Pell, S. and Bender, J.R.  1982.
Case-control study of cancer deaths in DuPont workers with
potential exposure to formaldehyde.  In:  Formaldehyde:
toxicity, epidemiology, and mechanisms.  JJ Clary, JE
Gibson, RS Waritz, eds.  New York; Marcel Dekker, Inc.

Feron, V.J.  1979.  Effects of Exposure to  Acetaldehyde in
Syrian Hamsters Simultaneously Treated with Benzo(a)pyrene
or Diethylnitrosamine.  Prog. Exp. Tumor Res. 24: 162
(Karger, Basel).

Feron, V.J.  1984.  Summary Tumor Results-Acetaldehy3e.
Proided to Dr. H. Milman, U.S. EPA, Washington, DC.

Feron, V.J., Kruysse, A., Til, H.P. and Immel, H.R.
1978.  Repeated Exposure to Acrolein Vapour:  Subacute
Studies in Hamsters, Rats, and Rabbits.  Toxicology 9:
47-57.
                         9-8

-------
Feron, V.J., Kruysse, A. and Wouterson,  R.A.   1982.
Respiraory Tract Tumors in Hamsters  Exposed to  Acetaldehyde
Vapour Alone or SimiItaneously  to  Benzo(a)pyrene  or
diethylnitrosamine.  Eur. J. Cancer  Clin. Oncol.  18:  13.

Fleij, I., Petri,  M. , Stocker,  W.G.  and  Thiess, A.M.
1982.  Cytogenetic Analyses of  31ood  Lymphocytes  of  Workers
Exposed to FormaIdahydein Formaldehyde Manufacturing  and
Processing.  J. Occup. Med. 24:  1009-1012.

Foeke.-is,  J.\., Rennie, P.S., Cheng,  H. and Bruchovsky,  \'.
1985.  In Situ Cross-Linking of  Androgen  Receptors to
1,'uclear Acceptor Sites of Rat Prostate with Formaldehyde.
J. Biol.  chem. 260:  10093-10098.

Formaldehyde Institute.  1984.   Comments  pertaining  to  the
Advance Notice of  Proposed Rulemaking on  Formaldehyde under
Section 4(f) of the  Toxic Substances  Control  Act.  Docket
OPTS 62033.

Fortmann, R.C., Borrazzo, J.E.  and Davidson,  C.I.  1984.
Characterization of  Parameters  Influencing Indoor Pollutant
Concentrations.  Proceedings of  the  Third International
Conference on  Indoor Air Quality and  Climate,  Stokholm,
Sweden.

Frazer, J.P.   1984.  Allergic Rhinitis and Nasal  Polyps.
Ear,  Nose, and Throat Journal 63:  172-176.

Friedmann, I.  and Osborn, D. A.   1982.  Pathology  of
Granulomas and Neoplasms of the  Nose  and  Paranasal Sinuses,
Churchill Livingstone, New York.

Gamble, J.F.,  McMichael, A.J.,  Williams,  T. and
Battigelli, M.  1976.  Respiratory function and symptoms:
An environmental-epidemiological study of rubber  workers
exposed to a phenol-formaldehyde type resin.   Am.  Ind.  Hyg.
Assoc. J., 37: 499-513.

Garry, V.F., Oatman, L, Pleus,  R., and Gray,  D.   1980.
Formaldehyde in the  home:  Some  environmental  dis-ease
perspectives.  Minn. Med., 63:  107-111.

Gastwirth, J.L.  1983.  Combined tests of significance  in
EEO cases.  Presented at the 1983  Annual  Meeting  of  the ASA
in Toronto, Canada.

Gibson, J.E.   1984.  Comments on "Formaldehyde and
Hepatotoxicity" by Beall and Ulsamer.  J. Toxicol. Environ.
Health  14: 465-467.
                         9-9

-------
airman, J.R., Geisling, K.L., and Hodgson,  A.T.   L983.
Sources and concentrations of formaldehyde  in  indoor
environments.  Presented at  the 75th  Air  Pollution  Control
Association Annual Meeting,  New Orleans,  L.A.   June 20-25,
1332.  Washington, DC:  Energy and Environmental  Division,
U.S. Department of Energy.   Contract  No.  DE-AC03-76 5F00093.

Godish, T.  1933.  Interpretation of  one-time  formaldehyde
sampling results  from measurements of environmental
variables.  Chicago,   IL: Proc. APCA Specialty  Conference  -
Measurement and Monitoring of Non-Criteria  (Toxic)
Contaminants in Air.

Goldmacher, V.S.  and Th i I ly, W.G.  1933.  Formaldehyde  is
Mutagenic for Cultured  Hunan Cells.   Mutation  Res.  116:
417-422.

Goodman, J.I. and Tephly T.R.  1971.  A comparison  of rat
and human liver formaldehyde dehydrogenease.   Biochem.
Biophys. Acta 252: 439-505.

Gottschling, L.M., Beaulieu, H.J., and Melvin,  W.W.
1984.  Monitoring of Formic  Acid  in Urine of Humans Exposed
to Low Levels of  Formaldehyde.  Am. Ind.  Hyg.  Assoc. J.
45:  19-23.

Grafstrom, R.C.,  Curren, R.D., Yang,  l.L. and  Harris, C.C.
1985.  Genotoxicityof Formaldehyde in Cultured Human
Bronchial Fibroblasts.  Science 228:  39-90.

Grafstrom, R.C.,  Fornace,  A., Jr. and Harris,  C.C.  1984.
Repair of DNA Damage Caused  by Formaldehyde in Human Cells.
Cancer Research 44: 4323-4327.

Grafstrom, R.C.,  Fornace,  A.J., Jr.,  Autrup, H.,  Lechner,
J.F. and Harris,  C.C.   1983.  Formaldehyde  Damage to DNA
and Inhibition of DNA Repair in Human Bronchial Cells.
Science 220: 216-218.

Gralla E.J., Heck, H d'A., Hrubesh, L.W.  and
Meadows/ G.W.  1980.   A report of the review of the
formaldehyde exposure made by the CUT ad hoc  analytical
chemistry investigative team held at  the  Battelle Memorial
Columbus (Ohio) Laboratory.  Releigh, NC:   Chemical
Industry Institute of Toxicology.  CUT Docket No.  62620.

Grindstaff, G.F.  1985.  Revised  Cancer Risks  for
Formaldehyde.  Memorandum to Richard  Hefter.

Groan,  W.J., Gramp, G.D., Garrison, S.B., and  Walcott,
R.J.  1985.  Factors that influence formaldehyde  air levels
in mobile homes.  Forest Products Journal 35:  11-18.
                         9-10

-------
Hanrahan, L.P./ Anderson,  H.A.,  Dally,  K.A.,  Eckmann,  A.D.
and Kanarek, M.S.   1983.   An  Investigation  of  the
Offgassing  Decay Function  in  Aging  Mobile Homes  with
Climate Corrected Formaldehyde  Readings.  Wisconsin
Division of Health, Wisconsin State Laboratory of  Hygiene,
and j'niversity of Wisconsin,  Department of  Preventive
Medici ne.

Hanrahan, L.P. Dally, K.A., Anderson,  H.A.,  Kanarek, M.S.
and Rankin, J.  1904.  AJPA 74:  1026-1027.

Hardell, L., Johansson,  3. and  Axelson, 0.   1982.   American
Journal of  Industrial Medicine  3: 247-2S7/

Harrington, J. and  Oakes,  D.  1984.   Mortality Among
British Pathologists.  Br  J Ind  Med 41: 138-191.

Harrington, J. and  Shannon, H.   1975.   Mortality study of
oathologists and medical laboratory technicians.   British
Medical Journal 4:  329-332.

Hawthorne,  A. R. , Gammage,  and Dudney,  C.S.  et  al.   1984.
Oak Ridge National  Laboratory.   An  indoor air  quality  study
of forty east Tennessee homes.   Draft  report.  Washington,
DC:  U.S. Department of  Energy  *FTP/.-.-001701.  ORNL-5965.

Hayes, R.B., Raatgever, J.W. and deBruyn, A.   1984.  Tumors
of the nose and nasal sinuses:   A case-control study.
Presented at the XXI Congress on Occupational  Health,
Dublin, Ireland, September 1984.

Hayes, R.B., Raatgever, J.W. and Gerin, M.   1986.   Int.  J.
Cancer, 37: 487-492.

Heck,  H. d'A.  1982.  CUT Activities  2: 3-7.

Heck,  H. d'A and Casanova-Schmitz.   1983.   Reaction of
Formaldehyde in the Rat Nasal Mucosa.   In:   Formaldehyde:
Toxicology-Epidemiology-Mechanisms.   Clay,  J.J., Gibson,
J.E.,  and Waritz, R.S.,  Eds.  Marcel  Dekker,  Inc.,  New
York.

Heck,  H. d'A, Casanova-Schmitz,  M.,  Dodd, P.B.,  schachter,
E.N.,  Witek, T.J. and Tosun,  T.  1985.  Formaldehyde  (CH20)
Concentrations in the Blood of  Humans  and Fischer-344  Rats
Exposed to CH20 Under Controlled Conditions.   Am.  Ind.  Hyg.
Assoc. J. 46: 1-3.

Heck,  H. d'A, Chin, T.Y.,  and Schmitz,  M.C.   1980.
Distribution of 14-C-formaldehyde in  rats after  inhalation
exposure.   In Formaldehyde Toxicity,  ed. J.  Gibson, pp.
26-37.  Washington: Hemisphere.
                         9-11

-------
Heck, H. d'A, White, E.I. and Casanova-Schmitze.   1982.
Biomed. Mass Spectrom. 9: 347-353.

'iemminki, X., Falck, K. and Vainio,  H.   1980.   Comparison
of Alkylation Rates and Mutagenicity of  Directly  Acting
Industrial and Laboratory Chemicals.   Arch.  Toxicol.  46:
277. '

Hendrick, D.J., Rando, R.J.,  Lane,  D.J.,  and  Morris,  M.J.
1982.  Formaldehyde Asthma:   Challenge Exposure Levels and
Fate After Five '/ears.  J. Occup.  Med.   24:  393-397.

Hern'oerg, S. , Westerhol.m, ?., Schultz-Larsen,  K. ,
Dogerth, R., Kuosma, E.,  Englund,  A.,  Hansen,  H.S.  and
Mutanen, ?.  1983.  \rasal and sinunasal  cancer.   Scand.  J.
Work. Environ.  Health 9: 315-326.

Hodges, H.E.  1984.  Letter with enclosures  to USEPA,
Office of Toxic Substances.   Mashville,  TN:   Tennessee
Department of Health and  Environment,  Air  Pollution Control
Divi sion.

Horton, A.W., Tye, R. and Stemmer,  K.L.   1963.
Experimental carcinogenesis of the  lu-ig.   Inhalation  of
gaseous formaldehyde or an aerosol  of  coal  tar by C3H
mice.  J. Natl. Cancer Inst.  30:  31-43.

Howe, R.B.,  Crockett, P.W. and Crump,  K.S.   1984.   Weibull-
A and Probit-A Fortrain Programs Implementing Weibull and
Generalized  Probit Models with Additive  Background  Response
Rates for the Analysis of Animal Bioassay  Data.   Battelle,
Washington,  DC.

HPMA.  1984.  Hardwood Plywood Manufacturers'
Association.  Comments before the  USEPA,  May  23,  1984,
Formaldehyde: Determination of significant  risk,  NAPR, and
notice.  Docket No. OPTS  62033.  Reston,  VA:   Hardwood
Plywood Manufacturers' Association.

Huennekens,  F.M and Osborn, M.J.   1959.   Folic acid
coenzymes and 1-carbon metabolism.   Adv.  Enzymol.   21:
369-446.

Hyams,  V.J.  1971.  Papillomas of  the  Nasal  Cavity  and
Paranasal Sinuses A Clinico-Pathologi  Study  of 315  Cases.
Ann. Otol. 80: 192-206.

IARC Monograph.  1982.  Some  Industrial  Chemicals and Dye
Stuffs.  IARC 29: 345-389.

IRMC.  1984.  Draft Report of the  Risk Assessment Subgroup
of the IRMC-Formaldehyde  Work Group.
                         9-12

-------
IRMC.  1984a.  Report of  the  Subcommittee  on  Formaldehyde
Sensitization.

IRMC.  I934b.  Report of  the  Subgroup  on Systemic  Effects--
For^aliehyda.

Iversen,  O.H.  1934.  :Jrethan  (Ethyl Carbamate)  Alone  is
Carcinogenic  for Mouse Skin.   Carcinogenesis  5:  911-915.

Jacobs, R.L., Freda, A.J. and  Culver,  W.G.   1933.   Primary
N'asal  Polyoosis Annals of Allergy  51:  500-505.

Kane,  L.E.,  Barrow, C.S.  and Alarie, Y.  1979.   A  Short-
Term Test to  Predict Acceptable Levels of  Exposure  to
Airborne Sensory Irritants.   Am.  Ind.  Hyg.  Assoc.  J. 40:
207-229.

Kane,  L.E. and Alarie, Y.   1977.   Sensory  Irritation to
Formaldehyde and Acrolein During Single and Repeated
Exposures in Mice.  Am.  Ind.  Hyg.  Assoc. J.   38: 509-521.

Kendrick,  J., Nettesheim, P.,  Guerin,  M.,  Caton, J.,
Dalbey, W., Griesemer, R.,  Rubin,  I.,  and  Maddox,  W.
1976.  Tobacco Smoke Inhalation Studies in Rats.   Toxicol.
Appl.  Pharmacol. 37:  557-569.

Kerfoot,  E.J., and Mooney,  T.F.  1975.  Formaldehyde and
paraformaldehyde study in funeral  homes.   Am.  Ind.  Hyg.
Assoc. J., 36 533-537.

Kerns, W.D., Pavkov, K.L.,  Donofrio, D.J.,  Gralla,  E.J. and
Swenberg,  J.A.  1983.  Carcinogenicity of  Formaldehyde in
Rats and Mice After Long-Term  Inhalation Exposure.  Cancer
Research 43: 4382-4392.

Kilburn,  K.H., Warshaw,  R., Boylen, C.T.,  Johnson,  S.-J.S.,
Seidman,  B., Sinclair, R.,  and Takaro, T.   1985a.
Pulmonary and Neurobehavioral  Effects  of Formaldehyde
Exposure.   Arch. Environ. Health 40: 254-160.

Kilburn,  K.H., Seidman,  B.C.,  and  Warshaw,  R.   1985b.
Neurobehavioral and Respiratory Symptoms of Formaldehyde
and Xylene Exposure in Histology Technicians.   Arch.
Environ.  Health 40: 229-233.

Kimmel, C.A., Cook, R.O., and  Staples, R.E.   1976.
Teratogenic Potential of  Noise in  Mice and Rats.   Toxicol.
Appl.  Pharmacol. 36: 239-245.
                         9-13

-------
Kitchens, J.F, Casner, R.E.,  Edwards,  G.S.,  Harvard,  W.E,
III and Macri, B.J.   1976.   Investigation of  selected
potential environmental contaminants:   formaldehyde.
Washington,  DC:  U.S. Environmental  Protection  Agency.
EPA-560/2-76-009.

Klenitzky, J.S.  1940.  On experimental  cancer  of  the
uterine cervix.  Bull. Biol.  Med.  Exp.  9: 3-6.

Konopinski,  V.J.   1983.   Residential  formaldehyde  and
carbon dioxide.  Indiana  State Board of  Health,
Indianapolis,  IN.  329-334.

Krivanek, N.D., Chroney,  N.C. and  McAlack, J.W.  1983.
Skin Initiation Promotion Study  with Formaldehyde  in  CD-I
Mice.  In: Formaldehyde:  Toxicology-Epidemiology-
Mechanisrns.   J.J.  Clary,  J.E. Gibson,  and R.S.  Waritz,
Eds., Marcel Dekker,   Mew  York.

Ku, R.H. and Billings, R.E.   1984.   Relationship Between
Formaldehyde Metabolism and  Toxicity and Glutathione
Concentrations in  Isolated Rat Hepatocytes.   Chem.  Biol.
Interactions 51:   25-36.

Kucharczyk,  N., Yang, J.T.,  Wong,  K.K.,  and  Sofia,  R.D.
1984.  The Formaldehyde-Donating Activity of  N5, N10-
Methylene Tetrahydrofolic Acid in  Xenobiotic
Biotransformation.   Xenobiotica  14:  667-676.

Kuhn, M. and Wanner,   H: U.  1984.   Indoor air  pollution by
building materials.   August  1984.  Stockholm, Sweden:
Proc. Intl.  Con. Indoor Air  Qual.  and  Climate.

Kulle,  T.J.   Letter to C.S.  Scott, U.S.  EPA.  August  28,
1985.

Lacroix, J., Chad,  Z., Gauthier, M., LaPointe,  N.,  Haley,
N., Lapierre, J. G.,   and  Masson, P.  1985.   Urea-
Formaldehyde Foam  Insulation-Clinical  Experience in 76
Children.  Union Medicale Du  Canada.   114: 542-547.
                                                 •*
Lara, C.W., Casanova-Schmitz,  M., and Heck, H. d'A.  1985.
Acetaldehyde (AA)  but not Formaldehyde (FA)  Depletes  Nasal
Mucosal Glutathione:   An  Investigation of the Role  of
Organic Peroxides.   Toxicologist 5:  128.

Lampertico,  P., Russell,  W.O. and  Macomb, W.S.  1963.
Squamous Papilloma of Upper  Respiratory  Epithelium.   Arch.
Path. 75: 293-302.

Lasser, A.,  Rothfeld, P.R.,  and  Shapiro, R.S.   1976.
Epithelial Papilloma  and  Squamous  Cell Carcinoma of the
Nasal Cavity and Paranasal Sinuses.  Cancer  38: 2503-2510.
                         9-14

-------
Lee, H.K., Alarie, Y.,  and Karol,  M.H.   1984.   Induction of
Formaldehyde Sensitivity  in Guinea Pigs.   Toxicol.  AppL.
Pharmacol.  75:  147-155.

Lee, K.P. and Trochinowicz, H.J.   1982.   Induction  of  :«'asal
Turaqrs in Rats Exposed  to Hexa;nethylphosphoranide by
Exhalation.  J.  MatL. Cancer  last.  68:  157-164.

Lee, K.P. and Trochinowicz, H.J.   1984.   Morphogenesis of
Masai Tumors in  Rats  Exposed  to  Hexamethylphosphoranide  by
Inhalation.  Environmental Research  33:  106-113.

Lees, R.E.M., Clark,  R.H., and Day,  J.H.   1985.
Respiratory Responses to  Formaldehyde,  Formaldehyde Free
UFFI Off-Gas and Particles in UFFI  Related Asthma.  J.
Allergy Clin. Immun.  75: 169.

Levine,  R.J., And je Ikovich, D.A. and Shaw,  L.K.   1984.   The
mortality of Ontario  undertakers and a  review  of  the
formaldehyde-related  mortality studies.   Journal  of
Occupational Medicine 26(10): 740-746.

Levine,  R.J., DalCorso, R.D., Blunden,  P.B., and
Battigelli, M.C.  1984.   The  Effects of  Occupational
Exposure on the  Respiratory Health of West Virginia
Morticians.  J.  Occup.  Med. 26:  91-98.

Liebling, F., Rosenman, K., Pastides, H.,  Griffith, R.  and
Lemeshow, S.  1984.   American Journal of Industrial
Medicine 5: 423-429.

Ma, T.-H., Harris, M.M.,  and  Lin,  G.  1985.  Genotoxicity
Studies of Formaldehyde Using Tradescantia-Micronucleus
Test.  EMS Abstracts:   42.

Main, D.  and Hogan, T.J.  1983.  Health  Effects of  Low-
Level Exposure to Formaldehyde.. J.  Occup.  Med. 25: 896-
900.

Malorny,  G., Rietbrock, N. and Schneider,  M.   1965.   Die
oxydation des Formaldehyds zu ameisensaeure  im Blut, ein
Beitrag zum Stoffwechsel  des  Formaldehyds.   [Oxidation  of
formaldehyde to  formic  acid in blood, a  contribution to  the
metabolism of formaldehyde.]  Naunyn Schmiedebergs  Arch.
Exp. Pharmakol.  250: 419-436.

Margosches, E.H. and  Springer, J.   One  Way Animal Data  Can
Help with Epidemiology  Planning.   Presentation at Eastern
North American Region,  Biometric Society Meetings,  March
1983.
                         9-15

-------
Marks, T.A., Worthy, W.C., and Staples,  R.E.   1980.
Influence of Formaldehyde and Sonacide©  (Potentiated  Acid
Glutaraldehyde) on Embryo and Fetal  Development  in  Mice.
Teratology 22: 52-58.

Marsh, G.  1933.  Proportional mortality  among chemical
workers exposed to formaldehyde.  British Journal of
Industrial Medicine 39: 313-322.

Marsh, G.  1983.  Mortality among workers from a plastic
producing plant:  A natched case-control  study nestle.1  in  a
retrospective cohort study.  Journal of Occupational
Medicine 25(3): 219-2030.

Mashford, P.M. and Jones, A. R.   1982.  Xenobiotics  12:
119-124.

Matanoski, G.  1980.   Data presented at  the 49th meeting of
the Interagency Collaborative Group or Environmental
Carcinogenesis, February 6, 1980, Bethesda, Maryland.

Matthews, T.G., Howell, T.C. and Gammage, R.B.   1981(a).
Formaldehyde Release from Plywood, Particleboard,
Fiberboard,  and Paneling.  Oak Ridge National Laboratory,
Monthly Report I,  CPSC-IAG-81-1360.

Matthews, T.G., Allen,  R.J. and Gammage,  R.B.  1981(b)
Formaldehyde Release from Plywood, Particleboard,
Fiberboard,  and Paneling.  Oak Ridge National Laboratory,
Monthly Report II, CPSC-IAG-81-1360.

Matthews, T.G. and Westley, R.R.  1983.   Determination of
Formaldehyde Emission  Levels from Ceiling Tiles  and
Fiberglas Insulation Products.  Oak  Ridge National
Laboratory,  Report No.  CPSC-IAG-82-1181.

Matthews, T.G., Daffron, C. R. , Hawthorne, A.R.,  Reed, T.J.,
and Tromberg, B.J.  1984.  Formaldehyde  emissions  from
consumer and construction products:  potential impact on
indoor formaldehyde concentrations.  August 1984.
Stockholm:  Proc.   3rd Intl. Conf. Indoor air Quality and
Climate.

McMartin, K.E., Martin-Amat, G., Makar,  A.B. and
Tephly, T.R.  1977.  Methanol poisoning.  V.  Role  of
formate metabolism in  the monkey.  J. Pharmacol. Exp.
Therap.  201: 564-572.

McMartin, K.E, Martin-Amat, G., Noker, P.E. and
Tephly, T. R.  1979.  Lack of role for formaldehyde  in
methanol poisoning in  the monkey.  Biochem. Pharmacol.   28:
645-649.
                         9-16

-------
Meittinen, O.S and Wang, J.   198L.   An  alternative  to  the
proportionate mortality ratio.  Americal Journal of
Epidemiology 116: 144-148.

Meullsr,  R., Raabe,  G. and Schumann,  D.  1978.  Leukoplakia
indaced by repeated deposition of  formalin  in  rabbit oral
rnucosa:   Long-term experiments with  a new  "oral tank."
Exp. Pathol.  16: 36-42.

Meyer, 3., and Hermanns, K.   1984a.   Formaldehyde  indoor
air problems.  Seattle Washington:   University of
Washington.  ?roc. Air Poll.  Control  Assoc.  Annual  Meeting,
1984,  San Francisco,  CA.  APCA paper  34-35.2.

Meysr, 3., and Hermanns, K.   1984b.   Diurnal variations of
formaldehyde exposure in mobile homes.  Berkeley, CA:
Lawrence  Berkeley National Laboratory,  Report  #13573.

MHI.  1984.  Manufactured Home Inst.  Comments pertaining
to the advance notice of proposed  rulemaking on
formaldehyde under section 4(f) of the  Toxic Substances
Control Act.

Mierauskiene, J.R. and Lekevicius, R.K.  1985.  Cytogenetic
Studies of Workers Occupationally  Exposed  to Phenol,
Styrene and Formaldehyde.  Mutation  Fes. 147:  308-309.

Mizenina, O.A.,  Kiseleva, N.P., Kaftanova,   A.S., and
Dobrov, E.N.  1984.   Formaldehyde-Induced  Crosslinking of
RNA with  Protein in Small Ribonucleoprotein Particles
Reconstituted from Tobacco Mosaic  Virus Protein and
Fragments of its RNA.

Morgan, K.T., Patterson, D.L. and  Gross, E.A.  1983.
Formaldehyde and the Nasal Mucociliary  Apparatus.   In:
Formaldehyde:  Toxicology-Epidemiology-Mechanisms.  Clary,
J.J.,  Gibson, J.E.,  and Waritz, R.S., Eds.   Marcel  Dekker,
Inc.,  New York.

Morgan, K.T., Patterson, D.L. and  Gross, E.A.  1983.
Localization of Areas of Inhibition of  Nasal Mucociliary
Function  in Rats Following in Vivo Exposure to
Formaldehyde.  Am. Rev. Respir. Dis.  127:  166.

Morgan, K.T., Patterson, D.L. and  Gross, E.A.  1984.   Froc
Palate Mucociliary Apparatus:  Structure,  Function, and
Response  to Formaldehyde Gas. Fundam. Appl.  Toxicol. 4:
58-68.
                         9-17

-------
Morgan, K.T., Jiang, X.-Z., Starr, T.B.,  and Kerns, W.D.
1985.  More Precise Localization of Nasal Tumors Associated
with Chronic Exposure to Formaldehyde Gas.  Toxicol.  Appl.
Phamacol., Submitted.

Mor-jan, K.T., Patterson, D.L., and Gross, E.A.   L986.
Responses of the Nasal Mucociliary Apparatus of  F-344 Rats
ti Formaldehyde Gas.  Toxicol. Appl. Pharmacol.  32_:  L-13.

Moschanireas, D.J., Stark, J.W.C., McFadden, J.-E., and
Morse, 5.S.  1978.  Geonet, Inc.   Indoor  air pollution  in
the residential environment, Vol.  I, Data Analysis anl
Interpretation.  Washington, DC:   U.S.  Environmental
Protection Agency.  E?A-600/7-73-229a.

Myers, G.E. and Nagaoka, M.  1981.  Formaldehyde
Emission:  Methods of Measurement an
-------
NPA.  1984.  National Particleboard Association.   4-F
comment:  Comments of the National Particleboard Assoc. on
advance notice of proposed rulemaking on  formaldehyde  under
section 4(f) of the Toxic Substances Control Act.

Neely, W.B.  1964.  The metabolic  fate of  formaldehyde-14C
iritraperitoneally administered to the rat.  Biochem.
Pharmacol.  13: 1137-1142.

Nikolaidis, E.T.,  Trost, D.C., Buchholz, C.L. and
Wilkinson, E.J.   1985.  The Relationship of Histologic and
Clinical Factors  in Laryngeal Papillomatosis.  Arch.
Pathol. Lab. Med.  L09:  24-29.

Nordman, H., Keskinen,  H., and Tuppurainen, M.  1985.
Formaldehyde Asthma-Rare or Overlooked?  J. Allergy Clin.
Immunol.  75:  91-99.

Obe, G. and Ristow,  H.  1977.  Acetaldehyde Not Ethanol
Induces Sister Chromatid Exchanges in Chinese Hamster  Cells
In Vitro.  Mutat.  Res.  56: 211.

Occupational Safety and Health Administration.  1984.
Preliminary assessment  of the health effects of
Formaldehyde.   November 5, 1984.

Olson, J.H., and  Dossing, M.  1982.  Formaldehyde  Induced
Symptoms in Day Care Centers.  Am. Ind. Hyg. Assoc. J. 43:
366-370.

Olsen, J.H. and Jensen, O.M. 1984.  Case-control study on
sinonasal cancer  and formaldehyde exposure based on a
national data linkage system for occupation and cancer.
Presented at the  Society for Epidemiologic Research, 17th
Annual Meeting, Houston, Texas, June 13-15, 1984.  Am  J
Epidemiology 120:  459.

Osborn, D.A.  1970.   Nature and Behavior of Transitional
Tumors in the Upper Respiratory Tract.  Cancer 25: 50-60.

Overman, D.O.   1985.  Absence of Embryonic Effects of
Formaldehyde After Percutaneous Exposure in Hamsters.
Toxicology Letters 24:  107-110.

Palese, M. and Tephly,  T.R.  1975.  Metabolism of  formate
in therat.  J. Toxicol. Environ. Health.   1: 13-24.

Paludetti, G., Maurizi, M., Tassoni,  A., Tosti, M. and
Altissim, G.  1983.   Nasal Polyps: A comparative Study of
Morphologic and Etiopathogenetic Aspects.  Rhinology 21:
347-360.
                         9-19

-------
Partanen, T., Kauppinen, T., Nurminen, M., Nickels, J.,
Hernberg, S. , Hakuliner, T., Pukkala, E. and Savoner, E.
1985.  Scand J. Work Environ. Health 11: 409-415.

Patterson, R.,  Pateras, V., Grammer, L.C., and Harris,
K.E.  1986.  Human Antibodies Against Formaldehyde Human
Serum Albumin Conjugates or Human Serum Albumin in
Individuals Exposed to Formaldehyde.  Int. Archs. Allergy
Appl. Immun.  79: 53-59.

Perzin, J.H., Lefkowitch, J.H. and Hui, R.M.  1981.
Bilateral Nasal Squamous Carcinoma Arising in
Papillomatosis.  Cancer 48: 2375-2382.

Pickrell, J.A., Griffis, L.C. and Hobbs, C.H.  1982..
Release of formaldehyde from various consumer products.
Albuquerque, NM:  Lovelace Biomed. andEnviron. Res.
Institute.

Pickrell, J.A., Griffis, L.C., Hobbs, C.H., Kanapilly, G.M.
and Mokler, B.V.  1984.  Formaldehyde release from selected
consumer products: influence of chamber loading, multiple
products, relative humidity, and temperature.
Environmental Science Technol.  18: 682-686.

Podall, H.  1984.  A review of the state-of-the-art on
urea-formaldehyde resins for wood anJ causes of
formaldehyde release.  Draft report.  U.S. Environmental
Protection Agency, Office of Toxic Substances, Economics
and Technology Division, Washington, D.C.

Proctor, D.F.  1982.  The Mucociliary System (Chap. 10).
In: The Nose: Upper Airway Physiology and the Atmospheric
Environment.  Proctor/Anderson (eds.).  Elsevier Biomedical
Press, pp. 245-278.

Pruett, J.J., Scheuenstuhl, H. and Michaeli, D.L.  1980.
The incorporation and localization of aldehydes (highly
reactive cigarette smoke components) into cellular
fractions of cultured human lung cells.  Arch. Environ.
Health.  35: 15-20.

Rader, J.  1974.  Irritative Effects of Formaldehyde in
Laboratory Halls, Analytical and Experimental
Investigations.  Dissertation for M.D. Degree.  Institute
of Pharmacology and Toxicology,  University of Wurzberg,
Federal Republic of Germany.

Ragan, D.L. and Boreiko, C.J.  1981.  Initiation of
C3H/10T1/2 Cell Transformation by Formaldehyde.  Cancer
Letters 13:  325-331.
                         9-20

-------
Rapoport, I.A.  1948.  Mutation Under  the  Effect  of
Unsaturated Aldehydes.  Dokl. Akad. Nauk.  S.S.S.R. 61:  713
(in Russian).

Report of the Federal Panel on Formaldehyde.   1982
Environ. Health Perspect:  43: 139-168.

Reznik, G., Reznik-Schuller, H. , Ward, J.M. and Stinson,
S.F.  1980.  Morphology of Nasal-Cavity Tumours in Rats
After Chronic Inhalation of 1,2-Dibromo-3-Chloropropane.
Br. J. Cancer 42: 772-781.

Ridolfi, R.L./ Lieberman, P.H., Erlandson, R.A. and Moore,
O.S.  1977.  Schneiderian Papillomas:  A Clinicopathologic
Study of 30 Cases..  Am. J. Surg. Pathol. 1: 43-53.

Rietbrock, N.  1969.  Kinetik and Wege des
Methanolumsatzes.  [kinetics and pathways  of methanol
metabolism.]  Naunyn Schmiedebergs Arch. Pharmakol. Exp.
Pathol.  263: 88-105.

Ristow, H. and Obe,  G.  1978.  Acetaldehyde Induces Cross-
links in DNA nad Causes Sister-chromatid Exchanges in Human
Cells.  Mutat. Res.  58: 115.

Robbins, J.D., Norred, W.P., Bathija,  A.,  and  Ulsamer,
A.G.  1984.  Bioavailability in Rabbits of Formaldehyde
from Durable-Press Textiles.  J. Toxicol.  Environ. Health
14:  453-463.

Robbins, S.L.  1974.  Pathologic Basis of  Disease.  W.B.
Saunders Co., Philadelphia, pp. 845-849, 885-892.

Rothman, K.J. and Boice, J.D.  1982.   Epidemiologic
analysis with a programmable calculator, 2nd Edition.
Boston:  Epidemiology Resources, Inc.

Roush, G., Walrath,  J., Stayner, L., Kaplan, S. and
Blair, A.  1985.  American Journal of  Epidemiology.

Rubin, I.B., Gill, B.E., Guerin, M.R., Kendrick,  J., and
Nettesheim, P.  1978.  Correlation of  Respiratory
Parameters in Hamsters with the Lung Deposition of
Radiolabelled Cigarette Smoke.  Environ. Res.  16: 70-76.

Rusch, G.M., Clary,  J.J., Rinehart, W.E. and Bolte, H.F.
1983.  A 26-Week Inhalation Toxicity Study with
Formaldehyde in the Monkey, Rat, and Hamster.  Toxicol.
Appl. Pharmacol. 68: 329-343.
                         9-21

-------
SAB.  1985.  EPA Science Advisory Board, Environmental
Health Committee:  Review of Draft Document-Preliminary
Assessment of Health Risks to Garment Workers  and  Certain
Home Residents from Exposures to Formaldehyde,  Draft May
1985.  Letter to Lee M. Thomas, October 1,  1985, from
Griesemer, R.A. and Nelson, N.

SAJ.  1984.  Science Applications, Inc.  Formaldehyde:  A
survey of airborne conentrations and sources.   Final
report.  Sacramento, CA:  State of California  Air  Resources
Board.  Contract No. A2-059-32.

SAIC.  1986.  Science Applications International
Corporation.  Formaldehyde Exposure and Cancers of the
Nose, Sinus, and Pharynx.  Final Report, Contract No. 68-
01-6280,  U.S. Environmental Protection Agency, OPTS, OTS,
EED, DDB.

Schoenberg, J.B. and Mitchell, C.A.  1975.  Airway Disease
Caused by Phenolic (Phenol-Formaldehyde) Resin Exposure.
Arch. Environ. Health 30: 574-577.

Schottenfeld, D. and Fraumeni, J.F., Jr.  1982.  Cancer
Epidemiology Prevention, pp 46-47, W.B. Saunders Co.

Schouten, J.P.  1985.  Hybridization Selection of  Covalent
Nucleic Acid-Protein Complexes.  J. Biol. Chem. 260:
9929-9935.

Schutte,  W., Frank, C.W., Hoffman, J., Sailer,  S., and
Scarpellino, C.  1981.  Final report to the Formaldehyde
Institute.  Iowa City, Iowa.  University of Iowa.

Schweer,  G.  1987.  Estimates of Populations Exposed to
Formaldehyde in New Residential Construction.   Memo dated
March 2,  1987 from G. Schweer (EPA/OTS/EED) to G.  Semeniuk
(E)A/OTS/CCD).

Scott, M.J., Ward, J.B., Dallas, C.E., and Theiss, °J.C.
1985.  Chromosome Damage Observed in Lung but  not  Bone
Marrow or Sprague-Dawley Rats Exposed to Formaldehyde by
Inhalation.  EMS Abstracts:  53-54.

Sellakumar, A.R., Snyder, C.A., Solomon, J.J.,  and Albert,
R.E.  1985.  Carcinogenicity of Formaldehyde and Hydrogen
Chloride in Rats.  Toxicol. Appl. Pharmacol. 81:   401-406.

Sellars,  S.L.  1982.  The Inverted Nasal Papilloma.  J.
Laryngol. Otol. 96: 1109-1112.
                         9-22

-------
Seydell, E.M.  1933.  Fibro-Epithelial Tumors of the Nose
(Papillomata) and Their Relationship to Carcinoma.  Ann.
Otol. 42; 1081-1103.

Sexton, K., Petreas, M.X., Lui, J.S. and Kulasingam, G.L.
1985.  California Department of Health Services.
Formaldehyde concentrations measured in California mobile
homes.  Detroit, MI:  Proc. 78th Annual Meeting Air Poll.
Control Assoc.

Sexton, K., Liu, K.S. and Petreas, M.X.  1985.  Measuring
indoor air quality by mail.  Berkeley,  CA:  California
Dept. of Health Sevices.  In press.

Sheppard, D., Eschenbacher, W.L., and Epstein, J.  1984.
Lack of Bronchomotor Response to up to 3 ppm Formaldehyde
in Subjects with Asthma.  Environ. Res.  35: 133-139.

Siegel, D.M., Frankos, V.H., and Schneiderman, M.A.  1983.
Formaldehyde Risk Assessment for Occupationally Exposed
Workers.  Reg. Toxicol. Pharmacol.  3:  355-371.

Sielken, R.L.  1983.  Incorporating Time into the
Estimation of the Potential Human Cancer Risk from
Formaldehyde Inhalation.  Institute of Statistics, Texas
A&M University.

Singh, J., Walcott, R., St. Pierre, C., Coffman, M.A.,
Ferrel, T.W., Opthoff, D., and Montgomery, D.  1982.
Clayton Environmental Consultants Inc.   Evaluation of
formaldehyde problem in mobile homes - testing and
evaluation.  Washington, DC:  Office of Policy Development
and Research, U.S. Department of Housing and Urban
Development.  Contract No. HC-5222, Volume 3.

Snyder, R.N. and Perzin, K.H.  1972.  Papillomatosis of the
Nasal Cavity and Paranasal Sinuses (Inverted Papilloma
Squamous Papilloma) A Clinicopathologic Study.  Cancer 30:
668-690.

Snyder, R.D. and Van Houten, D.  1986.   Genotoxicity of
Formaldehyde and an Evaluation of its Effects on the DNA
Repair Process in Human Diploid Fibroblasts.  Mutation Res.
165:  21-30.

SOCMA:  Booz, Allen, and Hamilton.  1979.  Preliminary
study of the costs of increased regulation offormaldehyde
exposure in the U.S. workplace.  Prepared for Synthetic
Organic Chemical Manufacturers Association.  Scarsdale, New
York.
                         9-23

-------
Sokal, R.R. and Rohlf, F.J.  Biometry, W.H.  Freeman and
Company, San Francisco, 1969.

Solomon, M.J., and Varshavsky, A.  1985.   Formaldehyde-
mediated DNA-Protein Crosslinking:  A Probe  for  In Vivo
Chromatin Structures.  Prod. Natl. Acad. Sci.  USA 82:
6470-6474.

Solomons, K. and Cochrane, J.W.C.  1984.   Formaldehyde
Toxicity:  Part I.  Occupational Exposure  and  a  Report of  5
Cases.  S. FR. Med. J.  66: 101-102.

Spangler, F. an dWard, J.M.  1983.  Skin Initiation-
Promotion Study with Formaldehyde in Sencar  Mice.  In:
Formaldehyde: Toxicology-Epidemiology-Mechanisms.  J.j.
Clary, J.E. Gibson and R.S. Waritz, Eds. Marcel  Dekker, New
York.

Spear, R.  1982.  Formaldehyde Study Shows Gene  Effect in
Anatomy Students.  The New Physcian 6: 17.

Stankowski, L.F. Jr., Tuman, W.G., Godek,  E.G.,  and Kasper,
G.J.  1986.  Induction of Mammalian Cell Mutations By
Formaldehyde. Environ. Muta. 8: 81.

Starr, T.B. and Buck, R.D.  1984.  The Importance of
Delivered Dose in Estimating Low-Dose Cancer Risk From
Inhalation Exposure to Formaldehyde.  Fundam.  Appl.
Toxicol. 4: 740-753.

Starr, T.B., Gibson, J.E., Barrow, C.S., Boreiko, C.J.,
Heck,  H. d'A.,  Levine, R.J., Morgan, K.T., and Swenberg,
J.A.  1984.  Estimating Human Cancer Risk  From
Formaldehyde: Criticla Issues.  Chemical Industry Institute
of Toxicology, Research Triangle Park, North Carolina.

Stayner, L., Smith, A.B.,  Reeve,  G., Blade,  L. ,  Elliott,
L., Keenlyside, R. and Halperin,  W.  1984.   Proportionate
mortality study of workers exposed to formaldehyde in the
garment industry.  Presented at the Society  for
Epidemiologic Research 17th Annual Meeting,  Houston, Texas,
June 13-15, 1984.  Am J Epidemiology 120:  458-9.

Stewart, H.L.,  Dunn, T.B., Snell, K.C. and Deringer, M.K.
Tumors of the Respirator Tract.  In: V.S.  Turosou (ed.),
Pathology of Laboratory Animals,  Vol. 2, pp. 251-288.
Lyon,  France:  IARC, 1979.

Stock, T.H. and Mendez, S.R.  1985.  University  of Texas,
School of Public Health.  A survey of typical  exposures to
formaldehyde in Houston area residences.   Am.  Ind. Hyg.
Assoc. J. 46: 313-317.
                         9-24

-------
Stone, R., DePaso, D., Shephard, E., To, T., Tucker, B. and
Villarreal, E.  1981.  Technology and Economics  Inc.  An
evaluation of formaldehyde problems in  residential mobile
homes.  Draft final report.  Washington, DC:  Dept. of
Housing ad Urban Development, Office of Policy Development
and Research.  Contract No. HC-5105.

Stroup, N., Blair, A., and Erickson, G.  1984.   Brain
cancer and other causes of death in anatomists.  Presented
at the Society for Epidemiologic Research 17th Annual
Meeting, Houston, Texas, June 13-15, 1984.  Am J
Epidemiology 120: 500

Strittmatter, P. and Ball, E.G.  1975.  Formaldehyde
dehydrogenase, a glutathione-dependent enzyme system.
J. Biol. Chem.  213: 445-461.

Swenberg, J.A., Barrow, C.S., Boreiko, C.J., Hick, H.
I'A., Levine, F.J., Morgan, K.T., and Starr, T.B.  1983.
Nonlinear biological responses to formaldehyde and their
implications for carcinogenic risk assessment.
Carcinogenesis 4: 945-952.

Swenberg, J.A., Gross, E.A., Martin, J., and Popp, J.A.
1983.  Mechanisms of formaldehyde toxicity.  In:  J.E.
Gibson (ed.), Formaldehyde Toxicity.  Hemisphere Publishing
Corp., Washington.

Swenberg, J.A. and Boreiko, C.J.  1985.  Appropriateness of
Polypoid Adenoma for Quantitative Risk Assessment.
Chemical Industry Institute of Toxicology.

Swenberg, J.A., Heck, H. d'A., Dudek,  B.R., and  Halliwell,
W.H.  1984.  Inhalation Toxicity of HCL Gas to Sprague-
Dawley and F-344 Rats.  Toxicologist 4:  27.

Tabershaw Associates.  1982.  Historical prospective
mortality study of past and present employees of the
Celanese chemical and plastics plant located in  Bishop,
Texas.  Tabershaw Associates, Rockville, Maryland.

Takano, T., Shirai, T.S., Ogiso, T., Tsuoa, H. ,  Baba, S.
and Ito, N.  1982.  Sequential Changes in Tumor  Development
Induced by 1,4-Dinitrosopiperazine in the Nasal  Cavity of
F344 Rats.  Cancer Research 42: 4236-4240.

Thomson, E.J., Shackleton, S. and Harrington, J.M.  1984.
Chromosome Aberrations and Sister-Chromatid Exchange
Frequencies in Pathology Staff Occupationally Exposed to
Formaldehyde.  Mutation Res. 141: 89-93.
                         9-25

-------
Timm, W. and Smith, P.  1979.  Formaldehyde odor and healtn
problems within residences.  Journal of Thermal Insulation,
Vol. 3, p. 104.

Tola, S., Hernberg, S. , Collan, Y., Linderborg, H. and
Korkala, M.L.  1980.  A case-control study of the etiology
of nasal cancer in Finland.  Int.  Arch. Occup. Environ.
Health 46: 79-85.

Tobe, M., Kaneko, T., Uchida, Y.,  Kamata, E., Ogawa, Y.,
Ikeda, Y. and Saito, M.  1985.  Studies of the Inhalation
Toxicity of Formaldehyde.  National Sanitary and Medical
Laboratory Service (Japan), pp. 1294.

Traynor, G.W., Anthon, D.W. and Hollowell, C.D.  1982.
Technique for Determining Pollutants from a Gas-Fired
Range.  Atmos. Environ. 16: 2979-2988.

Traynor, G.W., Allen, J.R., Apte, M.G., Girman, J.R. and
Hollowell, C.D.  19B3.  Pollutant  Emissions from Portable
Kerosene-Fired Space Heaters.  Environ. Sci. and Technol.
17: 369.

Traynor, G.W. and Nitschke, A.  1984.  Field survey of
indoor air pollution in residences with suspected
combustion-related sources.  August 1984.  Stockholm:
Proc. 3rd Int'l. Conf. Indoor Air Quality and Climate.

Tuthill, R.W.  1984.  Woodstoves,  Focmaldehyde, and
Respiratory Disease.  Am. J. Epid.  120: 952-955.

Tuttle, W.W. and Schottelius, B.A.  1969.  Gas  Exchange-
Respiration. In: Textbook of Physiology.  The C.U. Mosby
Company, St. Louis.

UFFI/ICC.  1981.  Urea Formaldehyde Foam Insulation
Information and Coordination Centre.  The report on the
national testing survey to the board of review by the
UFFI/ICC.  Canada.

Ulsamer, A.G. , Beall, J.R., Rang,  H.K., Frazier, J.A.
Overview of Health Effects of Formaldehyde.  1984.  In
Saxsena, J. (ed.),  Hazard Assessment of Chemicals--Current
Developments.  New York,  Academic  Press, Inc. 3: 337-400.

University of Texas, School of Public Health.  1983.  Final
report.  Texas indoor air quality study.  Houston, TX:
University of Texas.
                         9-26

-------
Uotila, L. and Koivusalo, M.  1974.  Formaldehyde
dehydrogenase from human liver; purification, properties,
and evidence for the formation of glutathione thiol esters
by the enzyme.  J. Biol. Chem.  249: 7653-7663.

Usdin, V.R. and Arnold, G.B.  1979.  Transfer of
formaldehyde to guinea pig skin.  Gillette Research
Institute Report.  Contract No. 78-391.

Van der Wai, J.F.  1982.  Formaldehyde measurements in
Dutch houses, schools, and offices in the years 1977-
1980.  Atmosphere Environment 16: 2471-2478.

Vaughan, T.L., Strader, C., Davis, S. and Daling, J.R.
1986a.  Submitted for publication.

Vaughan, T.L., Strader,, C., Davis,,- S. and Daling, J.R.
1986b.  Submitted for publication.

Versar.  1982.  Final Draft Report—Exposure Assessment  for
Formaldehyde.  Versar, Inc... Springfield-, .VA.

Versar.  1986a.  Maximum Levels of Formaldehyde Exposure in
Residential Settings.  EPA Contract No;: 681-02-3968, Task
No. 14.  Versar, Inc., Springfield, VA.  .

Versar.  1986b.  Formaldehyde exposure model-description
and demonstration.  Final report.  Washington DC:  US
Environmental Protection Agency, Office of Toxic
Substances, EPA Contract NQ. 68-02-3968.

Versar.  1986c.  Formaldehyde Exposure in Residential
Settings: Sources, Levels, and Effectiveness of Control
Options.  EPA Contract No. 68-02-3968, Task No. 14.  Versar
Inc., Springfield, VA.

Vital Statistics of the U.S.  1974. . 19,70 Volume II-
Mortality, Part A. United States Department of Health,
Education and Welfare.  Health Resources Administration
75-1104.

Vrabec, D.P.  1975.  The Inverted Schneiderian Papilloma: A
Clinical and Pathological Study.  Laryngoscope 85: 186-220.

Wagner, B.S.  1982.  Lawrence Berkeley Laboratory.
Residential indoor air quality/air infiltration study.
Washington, D.C.:  U.S. Department of Energy.  Contract  No.
DE-AC03-76SF00098.

Walrath, J. and Fraumeni, J.  1983.  Mortality patterns
among embalmers, International Journal of Cancer 31:
407-411.
                         9-27

-------
Walrath, J. and Fraumeni/ J.F.  1984.  Cancer Research 44:
4638-4641.

Ward, E.  1984.  Memorandum:  Formaldehyde Interim Exposure
Report.  U.S. EPA, Washington, DC.

Ward, Jr., J.B., Hokanson, J.^A;, Smith, E.R., Chang, L.W.,
Pereira, M.A., Whorton, Jr., E.B. and Legator, M.S.
1984.  Sperm Count, Morphology and Fluorescent Body
Frequency in Autopsy Service Workers Exposed to
Formaldehyde.  Mutation res. 130: 417-424..

Watanabe,*F., Matsunaga, T., Soejimai T. and Iwata, Y.
1954.  Study oh aldehyde carcinogenic!ty;  Part I.
Experimentally induced rat sarcomas by repeated injection
of formalin.  Gann 45? .451-452.

Watanabe, F. and Sugimoto, S.  1955.  Studies on aldehyde
carcihogenicity.  Part II.  Seven cases of transplantable
sarcomas of rats developed in the area of repeated
subcutaneous injections of urotropin (hexamethylene-
tetramine).  Gann 46: 365-367.

Waydhas, C., Weigl, K. and Sies, H.  1978.  The disposition
of formaldehyde and formate arising from drug N-
demethylations dependent on cytochrome P-450 in hepatocytes
and in perfused rat liver.  Eur. J. Biochem.  89(1): 143-150

Weber-Tschopp, A., Fischer, L., and Grandjean, E.  1977.
Irritating Effects of Formaldehyde (HCHO) on Humans.  Int.
Arch. Occup. Environ. Health  39: 207-218.

Widdicombe, J.G.  1977.  Defense Mechanisms of the
Respiratory System (Chap. 9).  In: Respiratory Physiology
II.  University Park Press, Baltimore,  pp 291-315.

Wisconsin Division of Health.  1984.  Magnetic tape of data
collected by Anderson et al. (1983).

Witek, T.J., Schachter, E.N., Brody, D., Tosun, T., Beck,
G.J., and Leaderer, B.P.  1985.  A Study of Lung Function
and Irritation From Exposure to Formaldehyde in Routinely
Exposed Laboratory Workers.  Chest 88: 65.

Wong, 0.  1983.  An epidemiologic mortality study of a
cohort of chemical workers potentially exposed to
formaldehyde.  In: Formaldehyde:  toxicity.  J.J. Clary,
J.E.  Gibson, R.S. Waritz, eds.  New York:  Hemisphere
Publishing Corp.
                         9-28

-------
 Woodruff,  R.C.,  Mason,  J.M., Valencia, R., and
 Zinunering,  S.   1985.   Chemical-Mutagenesis testing in
 Droaophila.  v.  Results  of 53 Coded Compounds Tested foi* the
 National Toxicology Program.  Environ. Mutagen.
 7:  677-702.

 Woutersen,  R.A.,  Appelman,  L.M.,  Wilmer,  J.W.G.M., Spit,
 B.J., and Falke,  H.E.   1984.  Subchronic (13-week)
 Inhalation Toxicity Study with Formaldehyde in Rats
 (Appendices),, pp.  1-88.   Submitted to Dr.  Harry A. Milman,
 U.S. EPA,.Washington, DC.

 Woutersen, R.A.,  Van Garderen-Hoetmer, A., and Appelman,
 L.M.  1985. . : Li,fe-Span  (27,,months)  inhalation
 Carcinogeni.cTity.. Study of  Acetaldehyde in Rats.   Final
 Report.  ' Report No. V85.145/190I72  Dated  June,  1985 from
 the Civo Institutes TNO>;Division  for Nutrition and Food
 Research TNO, the Netherlands.

Yamaguchi, K.T.,  Shaapshay,  S.M.,  Incze,  J.S.,  Vaughan,
C.W. and Strong, M.S.  J. Qtolaryngol.  8:  171-178.
                        9-29

-------