1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

EPA Document #EPA-740-D-24-001
March 2024
Office of Chemical Safety and
Pollution Prevention

SEPA

United States

Environmental Protection Agency

Executive Summary of the Draft Risk Evaluation for

Formaldehyde

CASRN 50-00-0

H

O

A

H

March 2024


-------
28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

66

67

68

69

70

71

72

73

74

75

76

PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

The U.S. Environmental Protection Agency (EPA) has evaluated the health and environmental risks of
formaldehyde under the Toxic Substances Control Act (TSCA). In this draft risk evaluation, EPA
preliminarily finds that formaldehyde presents an unreasonable risk of injury to human health.

However, these risks result from specific activities using, and products containing, formaldehyde and
therefore may not apply to everyone, everywhere. Also, the draft risk evaluation points out uncertainties
in these findings that could cast doubt on whether all risk estimates presented in this draft evaluation—
even though the values are based on the best available scientific information—are reflective of real-life
exposure to formaldehyde in the workplace, outdoor ambient air, and inside homes and other indoor
situations. Therefore, EPA is releasing this draft risk evaluation and risk determination for public
comment and independent, expert peer review. Once EPA receives comment and input from peer
review, revisions will be made and the EPA will finalize and issue its assessments and risk
determination {i.e., risk evaluation).

EPA's TSCA existing chemical risk evaluations must determine whether a chemical substance does or
does not present unreasonable risk under its conditions of use. The unreasonable risk must be informed
by science, but the EPA, in making the finding of presents unreasonable risk, also considers risk-related
factors as described in its risk evaluation framework rule. Risk-related factors beyond the levels of
formaldehyde that can cause specific health effects include the type of health effect under consideration,
the reversibility of the health effect being evaluated, exposure-related considerations (e.g., duration,
magnitude, or frequency of exposure), population exposed (including any susceptible subpopulation),
and the confidence in the information used to inform the hazard and exposure values. Specifically, for
formaldehyde, and for reasons explained below, while EPA will consider the standard risk benchmarks
associated with interpreting margins of exposure and cancer risks, the EPA cannot solely rely on those
risk values. This is because in addition to formaldehyde generated under the conditions of use,
formaldehyde is naturally occurring and results from activities not associated with the conditions of use
covered by this draft risk evaluation. These considerations must be included as part of a pragmatic and
holistic evaluation of hazard and exposure to formaldehyde. If an estimate of risk for a specific scenario
exceeds the standard risk benchmarks, then the formal determination of whether those risks contribute to
the unreasonable risk of formaldehyde under TSCA must be both case-by-case and context-driven.

Formaldehyde is found nearly everywhere. Living things—plants, animals, and people—produce and
release formaldehyde just through natural life (biogenic) processes. It is also produced when other
chemicals break down in the environment and is released into the air when things burn, such as when
automobiles emit exhaust, when furnaces and stoves operate, and through forest fires. Formaldehyde is
also used to make many things, including composite wood products, plastics, paints, adhesives, and
sealants. Over time, formaldehyde can be released from these products. The formaldehyde sources that
EPA evaluates in this draft risk evaluation involve, in general, the production and use of these products
that are subject to TSCA (as opposed to those products that are excluded from TSCA, such as
pesticides). The unique challenge associated with this evaluation is that the formaldehyde released from
these commercial activities and products that are subject to TSCA is mixed in with the naturally formed
formaldehyde released from all the activities and processes mentioned above.

This draft risk evaluation attempts to understand whether the risk from specific activities subject to
TSCA (i.e., the conditions of use) contribute to the unreasonable risk presented by formaldehyde. And
the risk estimates from some conditions of use representing workplaces clearly indicate that the direct
use of formaldehyde of those conditions of use contributes to the unreasonable risk of formaldehyde.
However, EPA also acknowledges that it is often difficult—if not impossible—to understand what
contribution various conditions of use are making to the total level of formaldehyde to which a person is
exposed in any given place at any given time.

Page 2 of 17


-------
77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

98

99

100

101

102

103

104

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

TSCA requires the EPA to look at risks to the environment as well as to people. Formaldehyde is not
expected to last long (persist) in water, sediment, or soil based on its physical and chemical properties.
For this reason, in this draft evaluation EPA has been able to preliminarily conclude that formaldehyde
does not pose a risk to the environment. Therefore, the rest of this executive summary focuses on EPA's
evaluation of risks to people.

For people, formaldehyde is a concern because it can cause health problems when inhaled and if it
contacts and is absorbed into skin. Breathing formaldehyde has been associated with a range of
respiratory and non-respiratory health effects in people. Inhaling formaldehyde for a short period of
time, such as for 15 minutes (called an acute exposure), for example after opening a product containing
formaldehyde, can cause sensory irritation such as eye irritation. Health effects that may be caused from
longer-term breathing of formaldehyde (called chronic exposure) include reduced pulmonary function,
increased asthma prevalence, decreased asthma control, allergy-related conditions, sensory irritation,
male and female reproductive toxicity, developmental effects, and cancer. This evaluation uses the
chronic hazard values calculated in EPA's IR > < xolomcalReview » >> naldehyde	Inhalation.

Specifically for cancer, this evaluation uses the hazard information for nasopharyngeal cancer included
in EPA's IRIS assessment. Although inhaled formaldehyde is associated with myeloid leukemia, another
type of cancer, the findings are not sufficient to complete a robust assessment of cancer risk for the
TSCA risk determinations or for use in the IRIS assessment. TSCA risk evaluations are also required to
consider risks to potentially exposed or susceptible subpopulations, such as children. Therefore, EPA
modified this cancer value using age-dependent adjustment factors to account for the possibility of
children's increased susceptibility to formaldehyde.

Skin (dermal) contact with formaldehyde has also been shown to cause sensitization, an allergic
reaction. EPA looked at the possibility of people getting formaldehyde on their skin through liquids,
such as detergents that may contain formaldehyde, as well as by getting paint and auto-care products
like car wax on their skin while using those products. Workers engaged in daily activities like spraying
liquids that contain formaldehyde may also have enough dermal contact with formaldehyde, particularly
if they are not wearing protective equipment like gloves, to develop skin sensitization.

While there are data on the hazards of oral ingestion, such as by drinking water, EPA did not use those
data because exposure is not expected. As mentioned above, formaldehyde is not expected to persist in
water or soils based on the physical and chemical properties and therefore is not expected in
groundwater or surface water used for drinking water.

In its evaluation of risks to people, EPA assessed exposure for 62 TSCA conditions of use of
formaldehyde, using many scenarios, considering multiple human life stages (e.g., childhood,
adulthood) and how people might be exposed outdoors in the open air, in their homes or other buildings,
and at workplaces that use formaldehyde. In some cases, EPA had data from air monitors; in other cases,
EPA used models to predict air concentrations and exposures. Both measured and modeled information
shows that people are exposed to formaldehyde at work, indoors, and outdoors at or above the levels
where adverse health effects such as sensory irritation, reduced pulmonary function, or cancer can occur.
Furthermore, multiple sources of formaldehyde—including sources not regulated under TSCA as well as
sources that are not regulated under TSCA (including natural sources as well as sources that are
regulated under other laws)—contribute to the total amount of formaldehyde that a person breathes
outside, inside, and at work, every day.

Page 3 of 17


-------
125

126

127

128

129

130

131

132

133

134

135

136

137

138

139

140

141

142

143

144

145

146

147

148

149

150

151

152

153

154

155

156

157

158

159

160

161

162

163

164

165

166

167

168

169

170

171

172

173

PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

Given this, EPA cannot solely rely on exceedances of the amounts of formaldehyde exposures known to
cause specific health effects in the risk evaluation to determine if conditions of use of formaldehyde that
are subject to TSCA contribute to the unreasonable risk. What that means is, for the risks described
below to workers and people who use formaldehyde-containing products or have formaldehyde-
containing furnishings or materials in their homes, those risks may not be any greater than (1) the risks
those same people are exposed to daily from the formaldehyde created naturally by plants, animals, and
people; (2) formaldehyde produced by natural and human-caused combustion; and (3) formaldehyde
produced by the breakdown of other chemicals in the air. Therefore, EPA believes that, in considering
whether a formaldehyde condition of use subject to TSCA contributes to unreasonable risks to people's
health, any risks—and what to do about them—need to be considered within the broader context of all
sources of formaldehyde, some of which people have been exposed throughout the course of human
existence.

Workers who are in workplaces where formaldehyde is used are at the most risk from
formaldehyde exposure. Workplace formaldehyde air concentrations are generally higher than ambient
outdoor concentrations as well as residential indoor air concentrations. Workers may be exposed to
formaldehyde by inhaling it after it is released into the air during processing and manufacturing of
articles, particularly when respirators are not worn. Workers can also be exposed to formaldehyde by
making skin contact with formaldehyde-containing materials when personal protective equipment like
gloves are not worn.

Workers are most likely to be at risk for acute and chronic non-cancer inhalation effects. Workers
may experience sensory eye irritation from short-term exposures (15-minute) and decreased lung
function or other respiratory effects from longer-term exposures (full work shift over many years). EPA
has an overall medium confidence in the reported workplace air exposure estimates because most of the
values are based on recent (1992 to 2020) real workplace monitoring data from multiple sources, and
therefore are expected to be reflective of current industrial practices. The reported exposure estimates,
however, did not always provide supplemental information such as the specific worker activities and
associated process conditions when formaldehyde was being made or used in the facilities.

EPA estimated short-term dermal exposures based on workers' skin contact with liquid formulations
containing formaldehyde. The highest dermal exposure was estimated for spray application of products
such as paints and automotive care products. EPA has medium confidence in the dermal exposure
estimates because the estimates were derived using a standard peer-reviewed model based on measured
data on the retention of liquids on the skin surface. The EPA does not have higher confidence in the
reported values because EPA did not have monitored formaldehyde dermal exposure data to ground-
truth these exposure estimates.

Overall, EPA determined with high confidence that most formaldehyde conditions of use can lead
to adverse health outcomes based on calculated risk estimates if workers are not protected from
breathing or touching formaldehyde. EPA estimated risks assuming that these protections are not in
place because EPA cannot guarantee that, in all cases, personal protective equipment is provided and
worn. However, EPA also is aware that many employers do take measures to protect the safety of
workers in their facilities.

At the next-highest risk from formaldehyde are people who frequently use certain consumer
products that contain formaldehyde. These include automotive-care products like car waxes; crafting
supplies such as some glues and sealants; and fabrics, textiles, and leather goods treated with
formaldehyde. However, whether there are any risks of concern from these products depends

Page 4 of 17


-------
174

175

176

111

178

179

180

181

182

183

184

185

186

187

188

189

190

191

192

193

194

195

196

197

198

199

200

201

202

203

204

205

206

207

208

209

210

211

212

213

214

215

216

217

218

219

220

221

PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

correspondingly on the amount of time and how frequently they are used. EPA has medium confidence
in the inhalation exposure estimates based on the number of monitoring data sources, use of the EPA's
Exposure Factors Handbook and survey data on consumer behavior and activities, and chemical
amounts reported on product-specific safety data sheets. EPA estimated short-term dermal exposures
based on skin contact with products containing formaldehyde. The highest concentrations were
estimated for exterior car waxes and polishes followed by photographic processing solutions.

Monitoring data that can be tied to specific ways people use these products are not available. People
using formaldehyde-containing products may experience dermal sensitization after short-term exposures
to their skin. Risk estimates for these dermal exposures are based on modeled estimates. Because
monitoring data are not available to determine how frequently these exposures may occur for consumers
or ground-truth these estimates, EPA has medium confidence in these risk estimates.

Finally, consumer products that contain formaldehyde can contribute to the formaldehyde present
in homes or other indoor places where they spend extended periods of time. There are many sources
of formaldehyde within homes and vehicles. These include sources from articles such as building
materials, wood flooring, paint, and fabrics as well as combustion sources like candles, fireplaces or
stoves. Additionally, consumer products containing formaldehyde may also add to indoor concentrations
of formaldehyde. EPA used computer-based models to estimate formaldehyde concentrations from
TSCA conditions of use that cannot otherwise be distinguished from other sources of formaldehyde
reflected in measured indoor concentration data. This is because the levels of formaldehyde coming
from many conditions of use are the same order of magnitude as the levels of formaldehyde from other
activities in the home (e.g., cooking or smoking), and because the measured concentration data represent
total exposure of formaldehyde from all sources at a given time and place.

The highest formaldehyde concentrations from TSCA sources in indoor environments are expected in
newly constructed homes and mobile homes. In these settings, multiple sources of formaldehyde
contribute to total indoor air concentrations—especially during the peak product emission period when
new formaldehyde-containing articles and products are introduced. These concentrations substantially
diminish within the first 2 years of the product life based on open literature data. Peak exposures to
formaldehyde from these products is expected to occur within 1 year of manufacture or use. Indoor air
concentrations of formaldehyde can also be high when new materials like hardwood floors or wallpaper
are installed in homes. Similarly, fabric in new furniture may also release formaldehyde in indoor
environments after being introduced. Therefore, formaldehyde concentrations in indoor environments
are expected to vary greatly over longer time periods (e.g., an individual's lifetime) and are highly
dependent on a person's likelihood to move into newly constructed homes and what products they
acquire while they live there. Many of the products that fall within this condition of use are also subject
to EPA's 2018 emission standards under TSCA Title VI (jjLiiSl- ^2697). which have not been fully
implemented as of the time of publication of this draft risk evaluation. Therefore, it is reasonable to
expect that less formaldehyde will be released from many wood products in the future than occurred in
the past.

EPA has medium confidence in the indoor air concentration estimates because the values are based on
product-specific emission rates and product-specific formulations of formaldehyde. The EPA does not
have high confidence in the indoor air concentration estimates because available monitoring data could
not corroborate the full range of estimates. In addition, the EPA does not have high confidence because
(1) dissipation rates of formaldehyde cannot be determined for indoor air for all types of furniture, wood
or other products, and (2) the available monitoring data cannot be directly tied to specific products (e.g.,
wood and fabric products) and associated conditions of use.

Page 5 of 17


-------
222

223

224

225

226

227

228

229

230

231

232

233

234

235

236

237

238

239

240

241

242

243

244

245

246

247

248

249

250

251

252

253

254

255

256

257

258

259

260

261

262

263

264

265

266

267

268

269

PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

EPA did not find that people face unreasonable risks from outdoor exposure to formaldehyde created
through TSCA conditions of use (such as a nearby industrial facility that makes or uses formaldehyde).
The evaluation considered levels of formaldehyde within a half mile from facilities releasing
formaldehyde through conditions of use. Formaldehyde concentrations are generally within the range of
concentrations of formaldehyde that come from natural sources (such as decomposing leaves) or
combustion sources such as car exhaust. In some locations under certain conditions, formaldehyde
concentrations may be higher; however, the concentrations are below most air concentrations of
formaldehyde typically found inside the home. This finding may partially be due to the fact that
formaldehyde is expected to rapidly transform into other chemicals during daylight hours. Based on this
knowledge, the EPA does not believe these risks to be unreasonable. That does not mean that, in specific
communities, efforts should not be taken to better understand and, if necessary, reduce formaldehyde
releases from facilities. EPA has high confidence in the outdoor air concentration estimates because the
values are based on reported formaldehyde releases from EPA databases, uses standard risk assessment
approaches, and utilizes more refined models to better understand location and populations near
releasing facilities.

Therefore, in this preliminary determination of formaldehyde unreasonable risk:

1.	EPA has a high level of certainty that 41 occupational conditions of use and has less certainty
that 5 additional occupational conditions of use contribute to unreasonable risk due to non-cancer
effects, specifically sensory eye irritation associated with acute inhalation of formaldehyde;

2.	EPA has a high level of certainty that 7 consumer conditions of use contribute to the
unreasonable risk due to non-cancer effects, specifically sensory eye irritation associated with
acute inhalation of formaldehyde;

3.	EPA has a high level of certainty that 10 occupational conditions of use and has less certainty
that 35 additional occupational conditions of use contribute to the unreasonable risk due to non-
cancer effects— specifically respiratory and non-respiratory health effects in workers, including
reduced pulmonary function, increased asthma prevalence, reduced asthma control, allergy-
related conditions, male and female reproductive toxicity, and developmental effects, associated
with chronic inhalation exposures;

4.	EPA is less certain about the contribution from 3 consumer conditions of use to the unreasonable
risk due to non-cancer effects—specifically respiratory and non-respiratory health effects,
including reduced pulmonary function, increased asthma prevalence, reduced asthma control,
allergy-related conditions, male and female reproductive toxicity, and developmental effects
associated with chronic inhalation exposures; and

5.	EPA is less certain about the contribution from 1 occupational COU to the unreasonable risk of
formaldehyde due to nasopharyngeal cancer from chronic inhalation exposures.

In this preliminary risk determination, EPA has high level of certainty of the contribution to the
unreasonable risk of formaldehyde from a COU when the risk from such COU is much greater than the
risk expected from the formaldehyde based on monitored concentrations in the indoor air, and EPA is
less certain of the contribution by the COU when the risk from the COU is within the expected risk
based on monitored concentrations in the indoor air. In addition, most of the occupational and consumer
conditions of use (47 and 7, respectively) contribute to the unreasonable risk due to non-cancer effects,
specifically dermal sensitization associated with acute dermal exposure, meaning that skin contact can
result in an allergic response.

It is important to recognize that this is a draft risk evaluation, and in some cases, EPA's preliminary
conclusions reflect uncertainties. Due to the magnitude of available scientific information on
formaldehyde coupled with the complex toxicology and exposure profiles for formaldehyde, EPA

Page 6 of 17


-------
PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

270	acknowledges that the evaluation of formaldehyde hazard and exposure is challenging. The EPA is at a

271	critical point in the development of the risk evaluation, where expert peer review and public input is

272	important. EPA is also seeking peer review and public input on the hazard data as well as, for example,

273	its use of inputs and assumptions in the exposure assessments for consumer and indoor air scenarios, in

274	part to understand if the approach EPA utilized compounds conservative assumptions, leading to

275	unrealistic or un-addressable outcomes. Following the peer review and public comment period, EPA will

276	revise the draft risk evaluation and issue a final evaluation that will include a final determination of

277	whether, under its TSCA conditions of use of use, formaldehyde presents unreasonable risk to health and

278	the environment.

Page 7 of 17


-------
PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

279	Occupational Conditions of Use that Support the Preliminary Unreasonable Risk Determination

280	S EPA has high level of certainty of the contribution to the unreasonable risk

281	~ EPA has less certainty of the contribution to the unreasonable risk

282	ONU stands for occupational non-user, or someone in a workplace who is not using the chemical but is nearby

283

Chemical Life
Cycle Stage









Human Health Effects''

Category

Subcategory

Population

Exposure Route"

Acute
Non-cancer

Chronic
Non-cancer

Cancer







Worker

Dermal

~







Domestic

Domestic Manufacturing

Inhalation

•/

~





Manufacturing

ONU

Inhalation







Manufacturing





General Population

Inhalation - Ambient Air











Worker

Dermal

V







Import

Import

Inhalation

S

~





ONU

Inhalation













General Population

Inhalation - Ambient Air













Worker

Dermal

V









Use in adhesives and sealant

Inhalation

V

~







chemicals

ONU

Inhalation













General Population

Inhalation - Ambient Air













Worker

Dermal

V









Use as an intermediate

Inhalation

S

~







ONU

Inhalation







Processing

Processing -



General Population

Inhalation - Ambient Air









reactant



Worker

Dermal

V









Use as a functional fluid

Inhalation

S

~







ONU

Inhalation













General Population

Inhalation - Ambient Air











Processing aids, specific to
petroleum production in all other
basic chemical manufacturing

Worker

Dermal

S









Inhalation

V

~







ONU

Inhalation











General Population

Inhalation - Ambient Air








-------
PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

Chemical Life
Cycle Stage









Human Health Effects''

Category

Subcategory

Population

Exposure Route"

Acute
Non-cancer

Chronic
Non-cancer

Cancer







Worker

Dermal

~









Bleaching agent in wood product

Inhalation

•/

~







manufacturing

ONU

Inhalation













General Population

Inhalation - Ambient Air













Worker

Dermal











Agricultural chemicals in
agriculture, forestry, fishing, and
hunting

Inhalation

•/

~







ONU

Inhalation











General Population

Inhalation - Ambient Air













Worker

Dermal

V









Finishing agents in textiles,
apparel, and leather
manufacturing

Inhalation

S

~







ONU

Inhalation







Processing



General Population

Inhalation - Ambient Air









Paint additives and coating

Worker

Dermal

V









additives not described by other
categories in transportation
equipment manufacturing
(including aerospace)

Inhalation

S

V







ONU

Inhalation



V





Processing -
incorporation
into an article

General Population

Inhalation - Ambient Air











Worker

Dermal











Additive in rubber product

Inhalation

V









manufacturing

ONU

Inhalation













General Population

Inhalation - Ambient Air













Worker

Dermal

S









Adhesives and sealant chemicals

Inhalation

V

V







in wood product manufacturing

ONU

Inhalation

S

V









General Population

Inhalation - Ambient Air









Processing -



Worker

Dermal

S







incorporation
into formulation,
mixture, or
reaction product

Petrochemical manufacturing

Inhalation

V

~





ONU

Inhalation

S









General Population

Inhalation - Ambient Air











Worker

Dermal

S





Page 9 of 17


-------
PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

Chemical Life
Cycle Stage









Human Health Effects''

Category

Subcategory

Population

Exposure Route"

Acute
Non-cancer

Chronic
Non-cancer

Cancer





Asphalt, paving, roofing, and
coating materials manufacturing



Inhalation

~

~







ONU

Inhalation

•/









General Population

Inhalation - Ambient Air











Solvents (which become part of a
product formulation or mixture)

Worker

Dermal

•/









Inhalation



~







in paint and coating

ONU

Inhalation

•/









manufacturing

General Population

Inhalation - Ambient Air













Worker

Dermal

S









Processing aids, specific to

Inhalation

V

~







petroleum production

ONU

Inhalation

S







Processing -



General Population

Inhalation - Ambient Air







Processing

incorporation

Paint additives and coating
additives not described by other
categories

Worker

Dermal

S





into formulation,
mixture, or
reaction product

Inhalation

V

~





ONU

Inhalation

S







General Population

Inhalation - Ambient Air













Worker

Dermal

S









Processing for use as an

Inhalation

V

~







intermediate

ONU

Inhalation

V











General Population

Inhalation - Ambient Air













Worker

Dermal

V









Solid separation agents in

Inhalation

S

~







miscellaneous manufacturing

ONU

Inhalation

V











General Population

Inhalation - Ambient Air













Worker

Dermal

V









Agricultural chemicals

Inhalation

S

~







(nonpesticidal)

ONU

Inhalation

V











General Population

Inhalation - Ambient Air











Surface active agents in plastic

Worker

Dermal

V









material and resin manufacturing

Inhalation

S

~



Page 10 of 17


-------
PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

Chemical Life
Cycle Stage









Human Health Effects''

Category

Subcategory

Population

Exposure Route"

Acute
Non-cancer

Chronic
Non-cancer

Cancer







ONU

Inhalation

~











General Population

Inhalation - Ambient Air













Worker

Dermal

~









Ion exchange agents in adhesive
manufacturing and paint and
coating manufacturing

Inhalation

•/

~







ONU

Inhalation

S









General Population

Inhalation - Ambient Air













Worker

Dermal

V









Lubricant and lubricant additive

Inhalation

S

~







in adhesive manufacturing

ONU

Inhalation

V











General Population

Inhalation - Ambient Air











Plating agents and surface
treating agents in all other

Worker

Dermal

V







Processing -

Inhalation

S

~



Processing

incorporation
into formulation,
mixture, or
reaction product

chemical product and preparation

ONU

Inhalation

V





manufacturing

General Population

Inhalation - Ambient Air











Worker

Dermal

V









Soap, cleaning compound, and

Inhalation

S

~







toilet preparation manufacturing

ONU

Inhalation

V











General Population

Inhalation - Ambient Air













Worker

Dermal

S









Laboratory chemicals

Inhalation

V

~







ONU

Inhalation

S











General Population

Inhalation - Ambient Air













Worker

Dermal

S









Adhesive and sealant chemical in

Inhalation

V

~







adhesive manufacturing

ONU

Inhalation

S











General Population

Inhalation - Ambient Air











Bleaching agents in textile,
apparel, and leather

Worker

Dermal

S









Inhalation

V

~







manufacturing

ONU

Inhalation

S





Page 11 of 17


-------
PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

Chemical Life
Cycle Stage









Human Health Effects''

Category

Subcategory

Population

Exposure Route"

Acute
Non-cancer

Chronic
Non-cancer

Cancer







General Population

Inhalation - Ambient Air













Worker

Dermal

•/







Repackaging

Sales to distributors for laboratory

Inhalation



~



Processing



chemicals

ONU

Inhalation











General Population

Inhalation - Ambient Air













Worker

Dermal

•/







Recyling

Recycling

Inhalation

V

~





ONU

Inhalation













General Population

Inhalation - Ambient Air













Worker

Dermal







Distribution in

Distribution in

Distribution in commerce

Inhalation

V

V



Commerce

Commerce

ONU

Inhalation



V









General Population

Inhalation - Ambient Air











Process aid in: Oil and gas

Worker

Dermal

S









drilling, extraction, and support
activities; process aid specific to
petroleum production, hydraulic
fracturing

Inhalation



V







ONU

Inhalation



V







General Population

Inhalation - Ambient Air









Non-

incorporative
activities



Worker

Dermal

V







Use in construction

Inhalation

S

V





ONU

Inhalation



V



Industrial Use





General Population

Inhalation - Ambient Air











Worker

Dermal

V









Oxidizing/reducing agent;
processing aids, not otherwise
listed

Inhalation

S

~







ONU

Inhalation











General Population

Inhalation - Ambient Air













Worker

Dermal

V







Industrial

Paints and coatings; adhesives

Inhalation

S

V





products

and sealants; lubricants

ONU

Inhalation



V









General Population

Inhalation - Ambient Air







Page 12 of 17


-------
PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

Chemical Life
Cycle Stage

Category

Subcategory

Population

Exposure Route"

Human Health Effects''

Acute
Non-cancer

Chronic
Non-cancer

Cancer

Commercial Use

Furnishing
treatment/ care
products

Floor coverings; foam seating and
bedding products; furniture &
furnishings including stone,
plaster, cement, glass and ceramic
articles; metal articles; or rubber
articles; cleaning and furniture
care products; leather conditioner;
leather tanning, dye, finishing
impregnation and care products;
textile (fabric) dyes; textile
finishing and impregnating/
surface treatment products.

Worker

Dermal

•/





Inhalation

S

V



ONU

Inhalation



V



Treatment
products

Water treatment products

Worker

Dermal

V





Inhalation

S

~



ONU

Inhalation







Treatment/ care
products

Laundry and dishwashing
products

Worker

Dermal

S





Inhalation







ONU

Inhalation







Construction,
paint, electrical,
and metal
products

Adhesives and sealants; Paint and
coatings

Worker

Dermal

V





Inhalation

S

V



ONU

Inhalation



V



Furnishing

treatment/care

products

Construction and building
materials covering large surface
areas, including wood articles;
construction and building
materials covering large surface
areas, including paper articles;
metal articles; stone, plaster,
cement, glass and ceramic articles

Worker

Dermal

S





Inhalation

S

V



ONU

Inhalation



V



Electrical
products

Machinery, mechanical
appliances, electrical/electronic
articles; other machinery,

Worker

Dermal

V





Inhalation

S

~



ONU

Inhalation







Page 13 of 17


-------
PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

Chemical Life
Cycle Stage









Human Health Effects''

Category

Subcategory

Population

Exposure Route"

Acute
Non-cancer

Chronic
Non-cancer

Cancer





mechanical appliances,
electronic/electronic articles















Construction and building
materials covering large surface

Worker

Dermal

~







Metal products

Inhalation

•/

~







areas, including metal articles

ONU

Inhalation









Automotive and
fuel products

Automotive care products;
lubricants and greases; fuels and

Worker

Dermal

•/







Inhalation

V

V

~



related products

ONU

Inhalation



V

~



Agriculture use
products



Worker

Dermal

V







Lawn and garden products

Inhalation

S

~



Commercial Use



ONU

Inhalation







Outdoor use
products



Worker

Dermal

V







Explosive materials

Inhalation

S

~







ONU

Inhalation









Packaging,
paper, plastic,

Paper products; plastic and rubber
products; toys, playground, and

Worker

Dermal









Inhalation









hobby products

sporting equipment

ONU

Inhalation









Packaging,
paper, plastic,



Worker

Dermal

V







Arts, crafts, and hobby materials

Inhalation

S

~





hobby products



ONU

Inhalation



~





Packaging,
paper, plastic,

Ink, toner, and colorant products;
photographic supplies

Worker

Dermal

S







Inhalation

V

~





hobby products

ONU

Inhalation









Products not



Worker

Dermal

V







described by

Laboratory chemicals

Inhalation

S

V





other codes



ONU

Inhalation



V









Worker

Dermal

S





Disposal

Disposal

Disposal

Inhalation

V

~









ONU

Inhalation







Page 14 of 17


-------
PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

Chemical Life
Cycle Stage

Category

Subcategory

Population

Exposure Route"

Human Health Effects''

Acute
Non-cancer

Chronic
Non-cancer

Cancer

General Population

Inhalation - Ambient Air







a Only Inhalation exposure routes were assessed for ONUs and General Population. Additionally, General Population inhalation exposure routes were assessed
using the ambient air pathway and are labeled to reflect the specific route.

h Grayed-out boxes indicate certain exposure routes that were not assessed because it was determined that there was no viable exposure pathway.

Consumer Conditions of Use that Support the Preliminary Unreasonable Risk Determination

¦S EPA has high level of certainty of the contribution to the unreasonable risk
~ EPA has less certainty of the contribution to the unreasonable risk

Life









Human Health Effects'

Cycle
Stage

Category

Subcategory

Population"''

Exposure Route

Acute Non-cancer

Chronic Non-
cancer





Floor coverings; foam seating and bedding
products; cleaning and furniture care

Consumer

Dermal

V





Furnishings

Inhalation

V





treatment/
care products

products; furniture & furnishings including
stone, plaster, cement, glass and ceramic
articles; metal articles; or rubber articles

Bystander

Inhalation

V





General
Population

Inhalation - Indoor Air











Consumer

Dermal





Consumer

Furnishing

Fabric, textile, and leather products not
covered elsewhere (clothing)

Inhalation

V



Use

treatment/
care products

Bystander

Inhalation

V







General
Population

Inhalation - Indoor Air







Treatment
products



Consumer

Dermal







Water treatment products

Inhalation









Bystander

Inhalation







Treatment/

Laundry and dishwashing products

Consumer

Dermal

V





care products

Inhalation





Page 15 of 17


-------
PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

Life
Cycle
Stage

Consumer
Use

Category

Subcategory

Population"''

Exposure Route

Human Health Effects'

Acute Non-cancer

Chronic Non-
cancer

Bystander

Inhalation





Construction,
paint,
electrical,
and metal
products

Adhesives and sealants; paint and coatings

Consumer

Dermal

V



Inhalation

V

~

Bystander

Inhalation

V



Construction,
paint,
electrical,
and metal
products

Construction and building materials
covering large surface areas, including wood
articles; construction and building materials
covering large surface areas, including paper
articles; metal articles; stone, plaster,
cement, glass and ceramic articles

Consumer

Dermal

V



Inhalation

V



Bystander

Inhalation

V



General
Population

Inhalation - Indoor Air





Electrical
products

Machinery, mechanical appliances,
electrical/ electronic articles; other
machinery, mechanical appliances,
electronic/ electronic articles

Consumer

Dermal





Inhalation





Bystander

Inhalation





Automotive
and fuel
products

Automotive care products; lubricants and
greases; fuels and related products

Consumer

Dermal

V



Inhalation

V



Bystander

Inhalation

V



Agriculture
use products

Lawn and garden products

Consumer

Dermal





Inhalation





Bystander

Inhalation





Packaging,

paper,

plastic,

hobby

products

Paper products; plastic and rubber products;
toys, playground, and sporting equipment

Consumer

Dermal





Inhalation

V



Bystander

Inhalation

V



General
Population

Inhalation - Indoor Air







Arts, crafts, and hobby materials

Consumer

Dermal

V



Page 16 of 17


-------
PUBLIC RELEASE - DO NOT CITE OR QUOTE
March 2024

Life
Cycle
Stage

Category

Hobby
products

Subcategory

Population"''

Exposure Route

Human Health Effects'

Acute Non-cancer

Chronic Non-
cancer

Inhalation



~

Bystander

Inhalation





Packaging,
paper, and
plastic

Ink, toner, and colorant products;
photographic supplies

Consumer

Dermal

V



Inhalation

V

~

Bystander

Inhalation

V



" Only inhalation exposure routes were assessed for Bystander.

b Typically, "Consumer" represents "Adult" or "Youth" age groups; "Bystander" typically represents "Child" and "Infant" age groups. "Infant" represents ages 0-2;
"Child" represents ages 3-10; "Youth" represents ages 11-20; and "Adult" represents ages >21.

c Grayed-out boxes indicate certain exposure routes that were not assessed because it was determined that there was no viable exposure pathway.

289

Page 17 of 17


-------