1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 EPA Document #EPA-740-D-24-005 March 2024 Office of Chemical Safety and Pollution Prevention SEPA United States Environmental Protection Agency Unreasonable Risk Determination of the Draft Risk Evaluation for Formaldehyde CASRN 50-00-0 O A H H March 2024 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 27 TABLE OF CONTENTS 28 1 RISK EVALUATION SCOPE 3 29 2 UNREASONABLE RISK DETERMINATION 4 30 2.1 Unreasonable Risk to Human Health 8 31 2.1.1 Populations and Exposures EPA Assessed to Determine Unreasonable Risk to Human 32 Health 9 33 2.1.2 Summary of Unreasonable Risks to Human Health 9 34 2.1,3 Basis for Unreasonable Risk to Human Health 9 35 2.1.4 Unreasonable Risk in Occupational Settings 10 36 2.1.5 Unreasonable Risk to Consumers 11 37 2.1.6 Unreasonable Risk to the General Population 13 38 2.2 Unreasonable Risk to the Environment 15 39 2.2.1 Populations and Exposures EPA Assessed to Determine Unreasonable Risk to the 40 Environment 15 41 2.2.2 Summary of Unreasonable Risks to the Environment 16 42 2.2,3 Basis for Unreasonable Risk of Injury to the Environment 16 43 2.3 Additional Information Regarding the Basis for the Unreasonable Risk 16 44 45 LIST OF TABLES 46 Table 2-1. Supporting Basis for the Draft Unreasonable Risk Determination for Human Health 47 (Occupational Conditions of Use) 17 48 Table 2-2. Supporting Basis for the Draft Unreasonable Risk Determination for Human Health 49 (Consumer Conditions of Use) 25 50 51 LIST OF FIGURES 52 Figure 1-1. Risk Evaluation Document Summary Map 3 53 Page 2 of 28 ------- 54 55 56 57 58 59 60 61 62 63 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 1 RISK EVALUATION SCOPE The Toxic Substances Control Act (TSCA) draft risk evaluation of formaldehyde comprises several human health and environmental assessment modules and two risk assessment documents—the environmental risk assessment and the human health risk assessment. A basic diagram showing the layout of these modular assessments and their relationships is provided in Figure 1-1. In some cases, individual assessments were completed jointly under TSCA and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). These modules are shown in dark gray. Figure 1-1. Risk Evaluation Document Summary Map Page 3 of 28 ------- 64 65 66 67 68 69 70 71 72 73 74 75 76 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 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 2 UNREASONABLE RISK DETERMINATION TSCA section 6(b)(4) requires EPA to conduct a risk evaluation to determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, without consideration of costs or other non-risk factors, including an unreasonable risk to a potentially exposed or susceptible subpopulation identified by EPA as relevant to the risk evaluation, under the TSCA conditions of use (COUs). EPA is preliminarily determining that formaldehyde presents an unreasonable risk of injury to human health under the COUs. Risk of injury to the environment does not contribute to EPA's preliminary determination of unreasonable risk. This draft unreasonable risk determination is based on the information in previous sections of the modules and documents that comprise this draft risk evaluation and the appendices and supporting documents in accordance with TSCA section 6(b), as well as (1) the best available science (TSCA section 26(h)), (2) weight of the scientific evidence standards (TSCA section 26(i)), and (3) relevant implementing regulations in 40 CFR part 702. Formaldehyde is found nearly everywhere. Living things—plants, animals, and people—produce and release formaldehyde through natural life (biogenic) processes. Formaldehyde 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 and articles. The formaldehyde sources that EPA evaluates in this draft risk evaluation involve, in general, the production and use of 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 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 COUs representing workplaces clearly indicate that the direct use of formaldehyde of those COUs contributes to the unreasonable risk of formaldehyde. However, EPA also acknowledges that it is often difficult 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. Taking that context into consideration, as well as the uncertainties in the overall risk estimates, EPA examined whether the contribution of formaldehyde exposure from a COU was greater than or within typical expected exposures from indoor air to inform EPA's preliminary determination of whether that COU contributes to unreasonable risk. In this preliminary determination of formaldehyde unreasonable risk: 1. EPA has a high level of certainty that 41 occupational COUs and has less certainty that 5 additional occupational COUs 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 COUs 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 COUs and has less certainty that 35 additional occupational COUs contribute to the unreasonable risk due to non-cancer effects, Page 4 of 28 ------- 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 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 COUs 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 COUs (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. Taking those uncertainties into consideration, in this preliminary determination EPA is concluding that the following COUs contribute to the unreasonable risk (see Table 2-1 and Table 2-2 for further detail regarding the contribution from each COU): • Manufacturing (domestic manufacture) • Manufacturing (import) • Processing - as a reactant in: o Adhesives and sealant chemicals in plastic and resin manufacturing; wood product manufacturing; paint and coating manufacturing; and basic organic chemical manufacturing; o An intermediate in pesticide, fertilizer, and other agricultural chemical manufacturing; petrochemical manufacturing; soap, cleaning compound, and toilet preparation manufacturing; basic organic chemical manufacturing; plastic materials and resin manufacturing; adhesive manufacturing; chemical product and preparation manufacturing; paper manufacturing; paint and coating manufacturing; plastic products manufacturing; synthetic rubber manufacturing; wood product manufacturing; construction; and agriculture, forestry, fishing, and hunting; o A functional fluid in oil and gas drilling, extraction, and support activities; o processing aids specific to petroleum production in all other basic chemical manufacturing; o Bleaching agent in wood product manufacturing; and o Agricultural chemicals in agriculture, forestry, fishing, and hunting • Processing - incorporation into an article, in: o Finishing agents in textiles, apparel, and leather manufacturing; o Paint additives and coating additives not described by other categories in transportation equipment manufacturing (including aerospace); o Additive in rubber product manufacturing; and Page 5 of28 ------- 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 199 200 201 202 203 204 205 206 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 o Adhesives and sealant chemicals in wood product manufacturing; plastic material and resin manufacturing (including structural and fireworthy aerospace interiors); construction (including roofing materials); and paper manufacturing • Processing - incorporation into a formulation, mixture, or reaction product, in: o Petrochemical manufacturing; petroleum, lubricating oil and grease manufacturing; fuel and fuel additives; lubricant and lubricant additives; petroleum and coal products manufacturing; and basic organic chemical manufacturing; o Asphalt, paving, roofing, and coating materials manufacturing; o Solvents (which become part of a product formulation or mixture) in paint and coating manufacturing; o Processing aids, specific to petroleum production oil and gas drilling, extraction, and support activities; chemical product and preparation manufacturing; and basic inorganic chemical manufacturing; o Paint additives and coating additives not described by other categories in paint and coating manufacturing and plastic material and resin manufacturing; o An intermediate in basic chemical manufacturing; chemical product and preparation manufacturing; plastic material and resin manufacturing; oil and gas drilling, extraction, and support activities; and wholesale and retail trade; o Solid separation agents in miscellaneous manufacturing; o Agricultural chemicals (nonpesticidal) in agriculture, forestry, fishing, and hunting; pesticide, fertilizer, and agricultural chemical manufacturing; o Surface active agents in plastic material and resin manufacturing; o Ion exchange agents in adhesive manufacturing and paint and coating manufacturing; o Lubricant and lubricant additive in adhesive manufacturing; o Plating agents and surface treating agents in chemical product and preparation manufacturing; o Soap, cleaning compound, and toilet preparation manufacturing; o Laboratory chemicals; o Adhesive and sealant chemical in adhesive manufacturing; o Bleaching agents in textile, apparel, and leather manufacturing • Processing - repackaging - sales to distributors for laboratory chemicals • Processing - recycling • Distribution - distribution in commerce • Industrial use (non-incorporative activities): o as a process aid in oil and gas drilling, extraction, and support activities; process aid specific to petroleum production, hydraulic fracturing; o used in: construction; and o oxidizing/ reducing agent; processing aids, not otherwise listed • Industrial use - chemical substances in industrial products - paints and coatings; adhesives and sealants; lubricants • Commercial use in: o 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; o Water treatment products; o Laundry and dishwashing products; o Adhesives and sealants; paint and coatings; Page 6 of 28 ------- 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 231 232 233 234 235 236 237 238 239 240 241 242 243 244 245 246 247 248 249 250 251 252 253 254 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 o 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; o Machinery, mechanical appliances, electrical/electronic articles; other machinery, mechanical appliances, electronic/electronic articles; o Construction and building materials covering large surface areas, including metal articles; o Automotive care products; lubricants and greases; fuels and related products; o Lawn and garden products; o Explosive materials; o Arts, crafts, and hobby materials; o Ink, toner, and colorant products; photographic supplies; and o Laboratory chemicals • Consumer use in: o Floor coverings; foam seating and bedding products; cleaning and furniture care products; furniture & furnishings including stone, plaster, cement, glass and ceramic articles; metal articles; or rubber articles; o Fabric, textile, and leather products (clothing); o Laundry and dishwashing products; o Adhesives and sealant; paint and coatings; o 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; o Automotive care products; lubricants and greases; fuels and related products; o Paper products; plastic and rubber products; toys, playground, and sporting equipment; o Arts, crafts, and hobby materials; and o Ink, toner, and colorant products; photographic supplies • Disposal In this preliminary determination, EPA concludes that the following COUs are not expected to contribute to the unreasonable risk: • Commercial use in paper products; plastic and rubber products; toys, playground, and sporting equipment; • Consumer use in water treatment products; • Consumer use in machinery, mechanical appliances, electrical/electronic articles; other machinery, mechanical appliances, electronic/electronic articles; and • Consumer use in lawn and garden products. Whether EPA makes a determination of unreasonable risk for a particular chemical substance under amended TSCA depends upon risk-related factors beyond exceedance of benchmarks, such as the endpoint under consideration, the reversibility of effect, exposure-related considerations (e.g., duration, magnitude, or frequency of exposure, or population exposed), and the confidence in the information used to inform the hazard and exposure values. In this draft risk evaluation, the Agency describes the strength of the scientific evidence supporting the exposure assessment as robust, moderate, slight, or indeterminate. When the assessment is supported by robust evidence, overall confidence in the exposure assessment is high; when supported by moderate evidence, overall confidence is medium; when supported by slight evidence, overall confidence is low. The Agency also evaluated the weight of scientific evidence supporting hazard assessment and dose response. This draft risk evaluation discusses the weight of scientific evidence and overall confidence in the exposure assessment as well as the hazard assessment in the Draft Human Health Risk Assessment for Formaldehyde. The Draft Page 7 of28 ------- 255 256 257 258 259 260 261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 276 277 278 279 280 281 282 283 284 285 286 287 288 289 290 291 292 293 294 295 296 297 298 299 300 301 302 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Environmental Risk Assessment for Formaldehyde describes weighing the scientific evidence to determine confidence in the environmental risk assessment. The strengths, limitations, assumptions, and key sources of uncertainty in the fate and transport are discussed in the Draft Chemistry, Fate, and Transport Assessment for Formaldehyde. These and other formaldehyde risk evaluation "modules" as well as scoping, assessments, and other documents and spreadsheets can be accessed in the docket HO-OPPT-2018-043 8. In the formaldehyde unreasonable risk determination, EPA considered risk estimates with an overall confidence rating of low, medium, or high. In general, the Agency makes an unreasonable risk determination based on risk estimates that have an overall confidence rating of medium or high, since those confidence ratings indicate the scientific evidence is adequate to characterize risk estimates despite uncertainties. For COUs that had a low confidence rating, EPA is concluding at this time that these COUs do not contribute to the unreasonable risk of formaldehyde. If in the final TSCA risk evaluation for formaldehyde, EPA determines that formaldehyde presents an unreasonable risk of injury to health or the environment under the COUs, the Agency will initiate risk management rulemaking to mitigate identified unreasonable risk associated with formaldehyde under the COUs by applying one or more of the requirements under TSCA section 6(a) to the extent necessary so that formaldehyde no longer presents such risk. EPA would also consider whether such risk may be prevented or reduced to a sufficient extent by action taken under another federal law, such that referral to another agency under TSCA section 9(a) or use of another EPA-administered authority to protect against such risk pursuant to TSCA section 9(b) may be appropriate. 2.1 Unreasonable Risk to Human Health This assessment provides a risk profile of formaldehyde by presenting a range of estimates for different health effects for different COUs. When characterizing the risk to human health from occupational exposures during risk evaluation under TSCA, EPA conducts baseline assessments of risk and makes its determination of unreasonable risk from a baseline scenario that does not assume use of respiratory protection or other personal protective equipment (PPE). Making unreasonable risk determinations based on the baseline scenario should not be viewed as an indication that EPA believes there are no occupational safety protections in place at any location, or that there is widespread noncompliance with existing regulations that may be applicable to formaldehyde. Rather, it reflects the Agency's recognition that unreasonable risk may exist for subpopulations of workers that may be highly exposed because they are not covered by Occupational Safety and Health Administration (OSHA) standards, such as self- employed individuals and public sector workers who are not covered by a State Plan, or because their employer is out of compliance with OSHA standards, or because EPA finds unreasonable risk for purposes of TSCA notwithstanding existing OSHA requirements. Jn addition, the risk estimates are based on exposure scenarios with monitoring data that likely reflects existing requirements, such as those established by EPA {i.e., National Emission Standards for Hazardous Air Pollutants [NESHAP] under the Clean Air Act), OSHA {i.e., formaldehyde standard), or industry or sector best practices. A calculated MOE that is less than the benchmark MOE is a starting point for informing a determination of unreasonable risk of injury to health, based on non-cancer effects. Similarly, a calculated cancer risk estimate that is greater than the cancer benchmark is a starting point for informing a determination of unreasonable risk of injury to health from cancer. It is important to emphasize that these calculated risk estimates alone are not "bright-line" indicators of unreasonable risk. For example, before determining whether a COU contributed to the unreasonable risk of formaldehyde to the general population, the Agency compared the exposures and risk estimates for people living and working near formaldehyde release sources (fenceline populations) with risk estimates from "background" air concentrations of Page 8 of 28 ------- 303 304 305 306 307 308 309 310 311 312 313 314 315 316 317 318 319 320 321 322 323 324 325 326 327 328 329 330 331 332 333 334 335 336 337 338 339 340 341 342 343 344 345 346 347 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 formaldehyde {i.e., ambient or outdoor air that includes formaldehyde typically released from "biogenic" or other non-TSCA sources). 2.1.1 Populations and Exposures EPA Assessed to Determine Unreasonable Risk to Human Health EPA evaluated risk to workers, including occupational non-users (ONUs); consumer users and bystanders; and the general population using reasonably available monitoring and modeling data for inhalation and dermal exposures, as applicable. With respect to health endpoints upon which EPA is basing this preliminary unreasonable risk determination, the Agency has medium or high confidence in the following point of departures (PODs): (1) nasopharyngeal cancer due to chronic inhalation; (2) non- cancer effects (sensory irritation) due to acute inhalation; (3) non-cancer respiratory effects (reduced pulmonary function, allergy-related conditions, asthma, and sensory irritation) due to chronic inhalation; and (4) non-cancer effects (sensitization) due to acute dermal exposure. EPA evaluated risk from inhalation and dermal exposure of formaldehyde to workers as well as inhalation exposures to ONUs. The Agency evaluated risk from inhalation and dermal exposure to consumer users and risk from inhalation exposure to bystanders. Finally, EPA also evaluated risk from inhalation exposure to the general population. Oral exposures were not assessed quantitatively as there is no supporting evidence that the oral route is a reasonably foreseen route of exposure for occupational and general populations ((see Draft Human Health Risk Assessment for Formaldehyde). EPA qualitatively assessed some oral exposures for relevant consumer COUs, but EPA is determining that this route is not likely to contribute to risk to consumers or bystanders due to the high volatility of formaldehyde, rapid evaporation rate, and due to a lack of supporting evidence via the oral pathway from products and articles (see Draft Consumer Exposure Assessment for Formaldehyde). Descriptions of the data used for human health exposure and human health hazards are provided in the Draft Human Health Risk Assessment for Formaldehyde. Uncertainties for overall exposures and hazards are presented in the Draft Human Health Risk Assessment for Formaldehye and summarized separately in the Occupational, Consumer, Indoor Air, and Ambient Air Exposure Assessments Modules, and are considered in this preliminary unreasonable risk determination. 2.1.2 Summary of Unreasonable Risks to Human Health EPA is preliminarily determining that the unreasonable risks presented by formaldehyde are due to • non-cancer effects in workers from inhalation and acute dermal exposures; • cancer effects for some workers from inhalation exposures under one condition of use; • non-cancer effects in occupational non-users (ONUs) from inhalation exposures; and • non-cancer effects in consumers and bystanders from inhalation and acute dermal exposures. Table 2-1 and Table 2-2 provide further detail regarding which COUs contribute to the above health effects. EPA's exposure and overall risk characterization confidence levels are summarized in the Draft Human Health Risk Assessment for Formaldehyde as are health risk estimates for workers, including ONUs, the general population, consumers, and bystanders 2.1.3 Basis for Unreasonable Risk to Human Health In developing the exposure and hazard assessments for formaldehyde, EPA analyzed reasonably available information to ascertain whether some human populations may have greater exposure and/or Page 9 of 28 ------- 348 349 350 351 352 353 354 355 356 357 358 359 360 361 362 363 364 365 366 367 368 369 370 371 372 373 374 375 376 377 378 379 380 381 382 383 384 385 386 387 388 389 390 391 392 393 394 395 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 susceptibility than the general population to the hazard posed by formaldehyde. The Agency identified as potentially exposed or susceptible subpopulation(s) (PESS) people who are expected to have greater exposure to formaldehyde, such as workers exposed to formaldehyde, those who frequently use consumer products containing high concentrations of formaldehyde, people living or working near facilities that emit formaldehyde, and people living in mobile homes and other indoor environments with high formaldehyde concentrations (see Draft Human Health Risk Assessment for Formaldehyde). Additionally, EPA identified as PESS people who may have greater susceptibility to the health effects of formaldehyde, including, infants and children, developing embryos and fetuses, people of reproductive age, and people who have pre-existing health conditions, such as asthma, allergies, nasal damage. A full PESS analysis is in Appendices C. 1 and C.2 of the Draft Human Health Risk Assessment for Formaldehyde. Risk estimates based on high-end exposure levels (e.g., 95th percentile) are generally intended to cover individuals with sentinel exposure levels whereas risk estimates at the central tendency exposure are generally estimates of average or typical exposure. EPA aggregated exposures across certain routes and exposure scenarios for consumers and bystanders for COUs with quantitative risk estimates. The uncertainty factors of 10 (acute inhalation due to sensory irritation and acute dermal due to sensitization) and 3 (chronic inhalation due to respiratory effects) for human variability that EPA applied to MOEs accounts for increased susceptibility of populations such as children and elderly populations. EPA also generally relies on high-end exposure levels to make an unreasonable risk determination to capture vulnerable populations that are expected to have higher exposures. For cancer, although there is likely to be variability in susceptibility across the human population, EPA did not identify specific human groups that are expected to be more susceptible to cancer following formaldehyde exposure. Therefore, for cancer risk, EPA is using central tendency risk estimates as staring point to inform the risk determination. More information on how EPA characterized sentinel and aggregate risks is provided in the Human Health Risk Assessment, Section 4.3. 2.1.4 Unreasonable Risk in Occupational Settings Based on the occupational risk estimates and related risk factors, EPA is preliminarily determining that the non-cancer risks from worker acute inhalation and dermal exposure to formaldehyde in occupational settings contribute to the unreasonable risk presented by formaldehyde. EPA is also preliminarily determining that chronic inhalation exposures to formaldehyde workers and in occupational settings contribute to the unreasonable risk presented by formaldehyde. Cancer risks in excess of the benchmark (lxlO"4) were identified for one COU for worker chronic inhalation exposure: automotive care products; lubricants and greases; fuels and related products. Products under this commercial COU include polishes, waxes, and other detailing products such as a vinyl coatings, greases and other lubricants used in the maintenance of automobiles, machinery, and other equipment. EPA did not make a preliminary risk determination for one COU that presents slight evidence and therefore was of low confidence. For COUs assessed, worker risks were evaluated using the central tendency and high-end estimates to account for susceptible populations that may be exposed while working. In a majority of the COUs, non- cancer risks were found for both central tendency and high-end exposures, while cancer risks were mainly found for high-end exposures. There were no COUs assessed qualitatively for the occupational analysis. EPA analyzed the occupational scenarios using a time weighted average for a typical 8-hour shift as well as a 12-hour shift. The risk determination is only based on a time weighted average for 8-hours as this is the most common scenario and also represents a more conservative estimate of risk to account for susceptible populations. For many COUs assessed, ONUs were evaluated using the central tendency Page 10 of 28 ------- 396 397 398 399 400 401 402 403 404 405 406 407 408 409 410 411 412 413 414 415 416 417 418 419 420 421 422 423 424 425 426 427 428 429 430 431 432 433 434 435 436 437 438 439 440 441 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 estimates for workers since the risk to ONUs are assumed to be equal to or less than risk to workers who handle materials containing formaldehyde as a part of their job. For three COUs, (i) manufacturing; (ii) processing as a reactant; and (iii) processing, incorporation into an article: additive in rubber product manufacturing, EPA had specific ONU data, and these COUs were evaluated using the ONU high-end exposures. Additionally, EPA evaluated dermal exposures only for workers since ONUs are not expected to directly handle formaldehyde. Non-cancer risk estimates were calculated from acute and chronic exposures. These terms are in reference to the duration of exposure to formaldehyde. Acute refers to an exposure time frame of 24 hours or less (15 minutes for inhalation) and chronic refers to an exposure time frame of greater than three months. Chronic cancer risk estimates include an exposure time frame over a 40-year work tenure for the high-end exposure and a 31-year work tenure for the central tendency exposure. EPA considered other sources of formaldehyde in the outdoor and indoor environments to provide a rational context for interpreting the inhalation risk estimates of the occupational uses. For example, biogenic sources of formaldehyde result in outdoor air concentrations of about 0.28 |ig/m3; the maximum monitored ambient air concentration of formaldehyde was 60.1 |ig/m3 and the maximum modeled formaldehyde concentration was 50.5 |ig/m3 The monitored indoor air concentrations of formaldehyde (collected from March 2018 to June 2019) range from 0.27 to 124.2 |ig/m3 for all homes, with 95% of homes having concentrations below -40 |ig/m3, and other reports suggest candles, incense, cooking and wood combustion activities can emit formaldehyde with concentrations up to 44.2 |ig/m3. Across all conditions of use, full work shift (8 to 12 hours) inhalation exposure concentrations of formaldehyde were between 7.5 to 17,353.3 |ig/m3 for workers and ONUs. Therefore, some inhalation exposure concentrations for workers and ONUs are within the outdoor and indoor air concentrations, and some, are greater than what would be expected from total indoor and outdoor exposures. In this preliminary risk determination EPA has high level of certainty of the contribution of an occupational COU when the risk from such occupational COUs 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 occupational COU when the risk from the COU is within the expected risk based on monitored concentrations in the indoor air. Most of the occupational COUs contribute to the unreasonable risk presented by formaldehyde due to acute dermal exposures at the workplace. More information on EPA's confidence in these risk estimates and the uncertainties associated with them can be found in the Draft Human Health Risk Assessment for Formaldehyde. 2.1.5 Unreasonable Risk to Consumers Based on the consumer risk estimates and related risk factors, EPA is preliminarily determining that non-cancer risks from acute inhalation exposure to formaldehyde for consumer users and bystanders and chronic inhalation for consumers contribute to the unreasonable risk of formaldehyde. Dermal exposures were assessed for acute non-cancer risks for consumers only since bystanders would not be expected to physically interact with any of the consumer COUs. Several of the consumer COUs assessed indicated that the consumer dermal exposures contribute to the unreasonable risk of formaldehyde. In addition, chronic risk was not assessed for some COUs because EPA does not expect consumers to use the products or articles containing formaldehyde for a length of time that would result in chronic exposure to formaldehyde. EPA is not finding that cancer risk due to chronic inhalation exposures to consumers and bystanders contribute to the unreasonable risk of formaldehyde. Page 11 of 28 ------- 442 443 444 445 446 447 448 449 450 451 452 453 454 455 456 457 458 459 460 461 462 463 464 465 466 467 468 469 470 471 472 473 474 475 476 477 478 479 480 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Consumers and bystander risks were evaluated for consumer COUs that represent specific age groups. Typically, consumers are adults since most products purchased are for adult use or application, while bystanders would include other adults in the home as well as children. For some consumer COUs, EPA determined that certain exposure routes were not appropriate and, therefore, were not assessed for the relevant COU. For example, for one consumer COU, machinery, mechanical appliances, electrical/ electronic articles; other machinery, mechanical appliances, electronic/ electronic articles, no assessment was made for any exposure route as EPA determined there were no viable exposure pathways via inhalation or dermal routes for products within this COU. This is because it is unclear how a consumer exposure would occur during a normal use of an electronic product, such as a circuit board component located within an electronic product. Circuit boards may include formaldehyde-based adhesives in small amounts to glue the intricate parts, such as wiring separate components together before encasing them in a larger body. Many of these products might include appliances, electric controls, telephones, electrical switches and circuit breakers (see Human Health Risk Assessment Module). For all of the consumer COUs, EPA evaluated the risk to consumers and bystanders using the high-end exposures to account for vulnerable populations that are expected to have higher exposures to certain uses, such as children with asthma. Similar to occupational COUs, EPA considered other sources of formaldehyde in the outdoor and indoor environment to provide a rational context for interpreting the inhalation risk estimates of the consumer uses. For example, biogenic sources of formaldehyde result in outdoor air concentrations of about 0.28 |ig/m3; the maximum monitored ambient air concentration of formaldehyde was 60.1 |ig/m3 and the maximum modeled formaldehyde concentration is 50.5 |ig/m3; and the monitored indoor air concentrations of formaldehyde (collected from March 2018 to June 2019) range from 0.27 to 124.2 |ig/m3 for all homes, with 95 percent of homes having concentrations below -40 |ig/m3, and other reports suggest candles, incense, cooking and wood combustion alone can emit formaldehyde with concentrations up to 44.2 |ig/m3. In this preliminary determination, EPA has high level of certainty to the contribution of a consumer COU when the risk from such consumer COU is much greater than the risk expected from the formaldehyde in the indoor air, and EPA is less certain of the contribution by the consumer COU when the risk from the COU is within the expected risk from indoor air. Most of the consumer COUs contribute to the unreasonable risk presented by formaldehyde due to acute dermal exposures. EPA has high confidence in the inhalation exposure assessment for consumers and medium confidence in the dermal exposure assessment for consumers. More information on EPA's confidence in these risk estimates and the uncertainties associated with them can be found in the Draft Human Health Risk Assessment for Formaldehyde. Page 12 of 28 ------- 481 482 483 484 485 486 487 488 489 490 491 492 493 494 495 496 497 498 499 500 501 502 503 504 505 506 507 508 509 510 511 512 513 514 515 516 517 518 519 520 521 522 523 524 525 526 527 528 529 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 2.1,6 Unreasonable Risk to the General Population Based on the risk estimates calculated using releases from manufacturing, processing, and industrial uses of formaldehyde, and related risk factors, EPA is preliminarily determining that there are no cancer risk effects that contribute to the unreasonable risk of formaldehyde to the general population, including people living or working near facilities (fenceline populations) from the ambient air. In addition, EPA is preliminarily determining that there are non-cancer risk effects to the general population due to chronic inhalation exposure from consumer products in residences and automobiles for four of the consumer COUs assessed which contribute to the unreasonable risk of formaldehyde in indoor air. For members of the general population exposed due to releases from the COUs, EPA considers a cancer risk benchmark range of 1x 10~4 to 1 x 10 6; however, the benchmark is not considered a "bright-line" and other risk related factors were considered. EPA considered other sources of formaldehyde in the outdoor and indoor environment to provide a rational context for interpreting the risk estimates to the general population. For example, EPA also considered the biogenic sources which result in outdoor air concentrations of about 0.28 |ig/m3, and the estimated annual ambient (outdoor) air concentration near releasing facilities, which ranged from 0.0001 to 5.75 |ig/m3 for formaldehyde COUs. EPA also considered concentrations of formaldehyde monitored in ambient air, which ranged from below the method detection limit to 60.1 |ig/m3 and a median value of 1.6 |ig/m3. Formaldehyde is not expected to persist in water or land based on the chemical, fate, and transport properties of formaldehyde. As such, EPA does not expect general population exposure to formaldehyde to occur via either the water or land pathway and therefore did not quantitatively assess exposures via these routes. Inhalation — Ambient Air EPA is using the results from IIOAC modeling in the formaldehyde ambient air assessment to determine whether there is unreasonable risk under the COUs to individuals living 100 to 1,000 m from industrial facilities that report air releases of formaldehyde attributable to its domestic manufacturing, import, processing, and industrial COUs. The population living or working within 100 to 1,000 m of the facilities (or fenceline population) are considered PESS and would represent the highest general population exposed to formaldehyde. EPA did not include other commercial COUs of formaldehyde in its ambient air assessment because those commercial releases associated with commercial COUs are generally lower than industrial releases (for example commercial uses related to adhesives and sealants, construction and building materials, automotive care products). The maximum outdoor air concentration near releasing facilities from the COUs is up to 5.7 |ig/m3, which is below the maximum monitored ambient air concentration of 60.1 |ig/m3. These data suggest that formaldehyde contributions from the COUs are not substantially higher than formaldehyde concentrations that are expected to occur due to background levels. As a result, EPA has preliminarily determined that no formaldehyde COUs contribute to the unreasonable risk of formaldehyde for cancer to the general population. Cancer inhalation risk estimates from IIOAC modeling and from AirToxScreen modeling of biogenic and secondary formation sources are presented in the Draft Human Health Risk Assessment for Formaldehyde. EPA's confidence in inhalation risk estimates for cancer risk is moderate at both 100 and 1,000 m. For one COU, distribution in commerce, EPA did not find any information to evaluate releases via ambient air. EPA also did not expect this COU to be similar to other COUs evaluated and therefore could not use similar data. Page 13 of 28 ------- 530 531 532 533 534 535 536 537 538 539 540 541 542 543 544 545 546 547 548 549 550 551 552 553 554 555 556 557 558 559 560 561 562 563 564 565 566 567 568 569 570 571 572 573 574 575 576 577 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 EPA has high confidence in the overall characterization of exposures for this ambient air exposure assessment due to the use of environmental release data from multiple sources. The greatest uncertainty is associated with the contribution to the total formaldehyde in ambient monitoring data from the COUs due to the contributions from biogenic sources and other background sources. More information on EPA's confidence in these risk estimates and the uncertainties associated with them can be found in the Draft Human Health Risk Assessment Module. Inhalation — Indoor Air EPA estimated cancer and non-cancer risks in indoor air for four consumer COUs via the inhalation pathway in two common indoor environments: automobile and residential. These COUs were chosen because they represent the most common products found in these two indoor environments. The four consumer COUs assessed included: • 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 (residential); • Fabric, textile, and leather products not covered elsewhere (clothing) (residential and automobile); • Floor coverings; Foam seating and bedding products; Cleaning and furniture care products; Furniture & furnishings including stone, plaster, cement, glass and ceramic articles; metal articles; or rubber articles (residential); • Paper products; Plastic and rubber products; Toys, playground, and sporting equipment (residential). EPA considered available indoor air monitoring data as well as air concentrations modeled based on emissions associated with the four COUs assessed, as described in thz Draft Indoor Air Exposure Assessment for Formaldehyde. The cancer risk estimates are based on indoor monitoring data based on the assumptions that those concentrations represent an average exposure over a 78-year lifetime. The basis for chronic non-cancer and cancer risk estimates for indoor air were designed to estimate concentrations at the central tendency because this represents the most common scenario in an indoor environment. The monitored indoor air concentrations of formaldehyde (collected from March 2018 to June 2019) range from 0.27 to 124.2 |ig/m3 for all homes, with 95 percent of homes having concentrations below -40 |ig/m3, and other reports suggest candles, incense, cooking and wood combustion can emit formaldehyde with concentrations up to 44.2 |ig/m3. The risk estimates in the indoor scenario for the residential COUs, included two COUs with wood products: (1) 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; and (2) floor coverings; foam seating and bedding products; cleaning and furniture care products; furniture & furnishings including stone, plaster, cement, glass and ceramic articles; metal articles; or rubber articles. The data used for cancer risk estimates was based on monitoring conducted before the Formaldehyde Emissions Standards for Composite Wood Products final rule pursuant to Title VI of TSCA that was enacted in 2018. TSCA Title VI reduces exposure to formaldehyde emissions from certain composite wood products such as hardwood plywood, medium density fiberboard, and particleboard. By including certain requirements for these composite wood products such as product-testing requirements, labeling, recordkeeping, and import certification, TSCA Title VI ensures that hardwood plywood, medium- density fiberboard, and particleboard products sold, supplied, offered for sale, imported to, or Page 14 of 28 ------- 578 579 580 581 582 583 584 585 586 587 588 589 590 591 592 593 594 595 596 597 598 599 600 601 602 603 604 605 606 607 608 609 610 611 612 613 614 615 616 617 618 619 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 manufactured in the United States comply with EPA's emission standards. In addition, by March 2024, laminated products—a type of product in which a wood veneer is applied to a composite wood core— will be considered hardwood plywood, significantly expanding the scope of TSCA Title VI to further reduce formaldehyde emissions from composite wood products. Similarly, the chronic non-cancer risk estimates for indoor air are based on studies with medium level of confidence regarding the use of the COU-specific emission rates, and the transformation of formaldehyde once it is released from the articles. Therefore, in this preliminary determination, EPA is finding that the COUs related to exposure in residences from wood articles does not contribute to the unreasonable risk of formaldehyde. In addition, in this preliminary determination, EPA finds that based on the risk estimates of the other COUs evaluated, those COUs do not contribute to the unreasonable risk of formaldehyde based on chronic inhalation exposures to the general population. EPA's overall confidence in the indoor air consumer analysis was medium. More information on EPA's confidence in these risk estimates and the uncertainties associated with them can be found in the Draft Human Health Risk Assessment for Formaldehyde of the draft risk evaluation. 2.2 Unreasonable Risk to the Environment In general, the Agency determines a risk profile by comparing a range of environmental toxicity endpoints with ambient concentrations associated with the COUs of formaldehyde. When the ambient concentrations are less than the concentrations associated with the toxicity endpoint, this generally means that risk of injury to the environment that would support a determination of unreasonable risk for the chemical substance is not indicated. When the ambient concentration is greater than the concentration associated with the toxicity endpoint, this generally means that risk of injury to the environment that would support a determination of unreasonable risk for the chemical substance is indicated. 2.2.1 Populations and Exposures EPA Assessed to Determine Unreasonable Risk to the Environment For terrestrial organisms, EPA evaluated exposures via air. EPA expects the air pathway (inhalation, ambient air exposure) is the dominant pathway and route of exposure to formaldehyde for terrestrial organisms based on the continuous release of formaldehyde from various sources. EPA did not quantitatively evaluate exposures to aquatic organisms via water or land pathways. Although formaldehyde is directly released to water, land, and air, formaldehyde concentrations were not modeled for the water and land pathways because formaldehyde is not expected to persist in soil and water based on physical-chemical, fate, and transport characteristics. Formaldehyde does not absorb or bind to soil or sediment and does not persist on land (due to volatility and reactivity of formaldehyde). Because formaldehyde is not expected to persist in water or soils, EPA determined that an in-depth analysis of releases to water or land was not justified and targeted its review of releases to air. In general, EPA has medium to high confidence in environmental releases for industrial COUs1 and low to medium confidence in commercial COUs. Environmental fate and transport data indicate formaldehyde does not bioaccumulate. EPA concluded that risk to terrestrial organisms via the dietary pathway is not indicated. EPA has high confidence in this assessment conclusion. 1 COUs that are included under the life cycle stage of manufacturing, processing, and industrial use. Page 15 of 28 ------- 620 621 622 623 624 625 626 627 628 629 630 631 632 633 634 635 636 637 638 639 640 641 642 643 644 645 646 647 648 649 650 651 652 653 654 655 656 657 658 659 660 661 662 PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 2.2.2 Summary of Unreasonable Risks to the Environment EPA quantitatively assessed risk via the ambient air pathway for the COUs evaluated and is preliminarily identifying: • no indication of risk to terrestrial mammals through air exposure because air concentrations are much lower than the most sensitive toxicity value; • no indication of risk to other terrestrial taxa, because even though no inhalation toxicity data are available for other terrestrial species, there are orders of magnitude difference in the toxicity and exposure for mammals; and • no indication of risk to plants from formaldehyde exposures in ambient air because air concentrations are an order of magnitude less than the most sensitive toxicity value. EPA qualitatively assessed risk via the surface water, dietary, and land pathways and concluded that these were not relevant pathways of exposure and is preliminarily identifying: • no indication of risk to terrestrial organisms through soil exposure because exposure is not expected since formaldehyde does not absorb or bind to soil and does not persist on land; • no indication of risk to aquatic organisms because exposure is not expected since formaldehyde rapidly transforms in water and is not expected to persist; and • no indication of risk to terrestrial organisms through a dietary pathway because formaldehyde does not bioaccumulate. Although terrestrial organisms may be exposed to formaldehyde in air, EPA did not identify risk to any environmental taxa due to formaldehyde under its COUs. EPA has high confidence in its environmental assessment conclusion. 2.2.3 Basis for Unreasonable Risk of Injury to the Environment Based on the draft risk evaluation for formaldehyde—including the risk estimates, the environmental effects of formaldehyde, the exposures, physical-chemical properties of formaldehyde, and consideration of uncertainties—EPA did not identify risk of injury to the environment that would contribute to the unreasonable risk determination for formaldehyde. Ambient air was determined to be the driver of exposure, but EPA does not expect this pathway to contribute to unreasonable risk to the environment. EPA does not expect exposure to formaldehyde via water, land, or dietary pathways to contribute to unreasonable risk to the environment. The Agency's overall environmental risk characterization confidence levels were varied and are summarized in the Draft Environmental Exposure Assessment for Formaldehyde. 2.3 Additional Information Regarding the Basis for the Unreasonable Risk Table 2-1 and Table 2-2 summarize the basis for this draft unreasonable risk determination of injury to human health and the environment presented in this draft formaldehyde risk evaluation. In these tables, a checkmark (V) indicates how the COU contributes to the unreasonable risk by identifying the type of effect (e.g., non-cancer and cancer for human health) and the exposure route to the population or receptor that results in such contribution. As explained in Section 1, for this draft unreasonable risk determination, EPA considered the effects of formaldehyde to human health at the central tendency and high-end, as well as effects of formaldehyde to human health from the exposures associated from the condition of use, risk estimates, and uncertainties in the analysis. See Draft Human Health Risk Assessment for Formaldehyde for a summary of risk estimates. In addition, certain exposure routes for some COUs were not assessed because it was determined that there was no viable exposure pathway. These COUs and their respective exposure routes are grayed out in Table 2-1 and Table 2-2. Page 16 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Table 2-1. Supporting Basis for the Draft Unreasonable Risk Determination for Human Health (Occupational Conditions of Use) ¦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 Cycle Stage Category Subcategory Population Exposure Route" Human Health Effects'' Acute Non-cancer Chronic Non-cancer Cancer Manufacturing Domestic Manufacturing Domestic Manufacturing Worker Dermal V Inhalation S ~ ONU Inhalation General Population Inhalation - Ambient Air Import Import Worker Dermal S Inhalation V ~ ONU Inhalation General Population Inhalation - Ambient Air Processing Processing - reactant Use in adhesives and sealant chemicals Worker Dermal V Inhalation S ~ ONU Inhalation General Population Inhalation - Ambient Air Use as an intermediate Worker Dermal V Inhalation S ~ ONU Inhalation General Population Inhalation - Ambient Air Use as a functional fluid Worker Dermal S Inhalation V ~ ONU Inhalation General Population Inhalation - Ambient Air Worker Dermal S Page 17 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Life Cycle Stage Human Health Effects'' Category Subcategory Population Exposure Route" Acute Non-cancer Chronic Non-cancer Cancer Processing aids, specific to petroleum production in all other basic chemical manufacturing Inhalation •/ ~ ONU Inhalation General Population Inhalation - Ambient Air Worker Dermal Processing - reactant Bleaching agent in wood product manufacturing Inhalation •/ ~ ONU Inhalation General Population Inhalation - Ambient Air Worker Dermal S Agricultural chemicals in agriculture, forestry, fishing, and hunting Inhalation V ~ ONU Inhalation Processing General Population Inhalation - Ambient Air Worker Dermal S Finishing agents in textiles, apparel, and leather manufacturing Inhalation V ~ ONU Inhalation General Population Inhalation - Ambient Air Paint additives and coating additives not described by other categories in transportation equipment manufacturing (including aerospace) Worker Dermal S Inhalation V V Processing - incorporation into an article ONU Inhalation V General Population Inhalation - Ambient Air Worker Dermal Inhalation S Additive in rubber product manufacturing ONU Inhalation General Population Inhalation - Ambient Air Adhesives and sealant chemicals in wood Worker Dermal S product manufacturing Inhalation V V Page 18 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Life Cycle Stage Human Health Effects'' Category Subcategory Population Exposure Route" Acute Non-cancer Chronic Non-cancer Cancer ONU Inhalation •/ V General Inhalation - Population Ambient Air Worker Dermal •/ Inhalation ~ Petrochemical manufacturing ONU Inhalation •/ General Inhalation - Population Ambient Air Worker Dermal V Asphalt, paving, roofing, and coating materials manufacturing Inhalation S ~ ONU Inhalation V General Population Inhalation - Ambient Air Worker Dermal V Processing - incorporation into Solvents (which become part of a product Inhalation S ~ formulation or mixture) in paint and coating ONU Inhalation V manufacturing General Inhalation - Processing formulation, Population Ambient Air mixture, or reaction product Worker Dermal S Processing aids, specific to petroleum production Inhalation S ~ ONU Inhalation V General Population Inhalation - Ambient Air Worker Dermal S Paint additives and coating additives not described by other categories Inhalation V ~ ONU Inhalation S General Population Inhalation - Ambient Air Worker Dermal S Processing for use as an intermediate Inhalation V ~ ONU Inhalation S Page 19 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Life Cycle Stage Human Health Effects'' Category Subcategory Population Exposure Route" Acute Non-cancer Chronic Non-cancer Cancer Inhalation - Ambient Air General Population Worker Dermal ~ Solid separation agents in miscellaneous manufacturing Inhalation V ~ Processing - ONU Inhalation S Processing incorporation into General Population Inhalation - Ambient Air formulation, mixture, or reaction Worker Dermal V Inhalation S ~ product Agricultural chemicals (nonpesticidal) ONU Inhalation V General Population Inhalation - Ambient Air Worker Dermal V Surface active agents in plastic material and resin manufacturing Inhalation S ~ ONU Inhalation V General Population Inhalation - Ambient Air Worker Dermal V Ion exchange agents in adhesive Inhalation S ~ manufacturing and paint and coating ONU Inhalation V manufacturing General Population Inhalation - Ambient Air Lubricant and lubricant additive in adhesive Worker Dermal S manufacturing Inhalation V ~ Page 20 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Life Cycle Stage Human Health Effects'' Category Subcategory Population Exposure Route" Acute Non-cancer Chronic Non-cancer Cancer ONU Inhalation •/ General Inhalation - Population Ambient Air Worker Dermal •/ Plating agents and surface treating agents in Inhalation ~ all other chemical product and preparation ONU Inhalation •/ manufacturing General Population Inhalation - Ambient Air Worker Dermal V Soap, cleaning compound, and toilet preparation manufacturing Inhalation S ~ Processing - incorporation into formulation, mixture, or ONU Inhalation V General Inhalation - Processing Population Ambient Air Worker Dermal V reaction Inhalation S ~ product Laboratory chemicals ONU Inhalation V General Inhalation - Population Ambient Air Worker Dermal S Adhesive and sealant chemical in adhesive manufacturing Inhalation S ~ ONU Inhalation V General Population Inhalation - Ambient Air Worker Dermal S Bleaching agents in textile, apparel, and leather manufacturing Inhalation V ~ ONU Inhalation S General Population Inhalation - Ambient Air Repackaging Sales to distributors for laboratory chemicals Worker Dermal S Inhalation V ~ ONU Inhalation Page 21 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Life Cycle Stage Category Subcategory Population Exposure Route" Human Health Effects'' Acute Non-cancer Chronic Non-cancer Cancer General Population Inhalation - Ambient Air Recyling Recycling Worker Dermal ~ Inhalation •/ ~ ONU Inhalation General Population Inhalation - Ambient Air Distribution in Commerce Distribution in Commerce Distribution in commerce Worker Dermal Inhalation V V ONU Inhalation V General Population Inhalation - Ambient Air Industrial Use Non- incorporative activities Process aid in: Oil and gas drilling, extraction, and support activities; process aid specific to petroleum production, hydraulic fracturing Worker Dermal S Inhalation V ONU Inhalation V General Population Inhalation - Ambient Air Use in construction Worker Dermal V Inhalation S V ONU Inhalation V General Population Inhalation - Ambient Air Oxidizing/reducing agent; processing aids, not otherwise listed Worker Dermal V Inhalation S ~ ONU Inhalation General Population Inhalation - Ambient Air Industrial products Paints and coatings; adhesives and sealants; lubricants Worker Dermal V Inhalation S V ONU Inhalation V Page 22 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Life Cycle Stage Human Health Effects'' Category Subcategory Population Exposure Route" Acute Non-cancer Chronic Non-cancer Cancer General Population Inhalation - Ambient Air Floor coverings; foam seating and bedding Worker Dermal ~ 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. Inhalation •/ V Furnishing treatment/ care products ONU Inhalation V Treatment products Worker Dermal V Water treatment products Inhalation S ~ ONU Inhalation Treatment/ care products Worker Dermal S Laundry and dishwashing products Inhalation Commercial ONU Inhalation Use Construction, Worker Dermal V paint, electrical, and metal products Adhesives and sealants; Paint and coatings Inhalation S V ONU Inhalation V Construction and building materials Worker Dermal S Furnishing treatment/care products 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 Inhalation V V ONU Inhalation V Machinery, mechanical appliances, Worker Dermal S Electrical products electrical/electronic articles; other machinery, mechanical appliances, electronic/electronic articles Inhalation V ~ ONU Inhalation Metal products Worker Dermal V Inhalation S ~ Page 23 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Life Cycle Stage Human Health Effects'' Category Subcategory Population Exposure Route" Acute Non-cancer Chronic Non-cancer Cancer Construction and building materials covering large surface areas, including metal articles ONU Inhalation Automotive Automotive care products; lubricants and greases; fuels and related products Worker Dermal •/ and fuel Inhalation S V ~ products ONU Inhalation V ~ Agriculture use products Worker Dermal S Lawn and garden products Inhalation S ~ ONU Inhalation Outdoor use products Worker Dermal S Commercial Use Explosive materials Inhalation V ~ ONU Inhalation Packaging, paper, plastic, Paper products; plastic and rubber products; toys, playground, and sporting equipment Worker Dermal Inhalation hobby products 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 Inhalation V ~ Disposal Disposal Disposal ONU Inhalation General Population Inhalation - Ambient Air Page 24 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Life Cycle Stage Human Health Effects'' Category Subcategory Population Exposure Route" Acute Non-cancer Chronic Non-cancer Cancer " 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. Table 2-2. Supporting Basis for the Draft Unreasonable Risk Determination for Human Health (Consumer Conditions of Use) ¦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 Cycle Stage Category Subcategory Population"'' Exposure Route Human Health Effects' Acute Non-cancer Chronic Non- cancer Consumer Use Furnishings treatment/ care products Floor coverings; foam seating and bedding products; cleaning and furniture care products; furniture & furnishings including stone, plaster, cement, glass and ceramic articles; metal articles; or rubber articles Consumer Dermal Y Inhalation V Bystander Inhalation Y General Population Inhalation - Indoor Air Furnishing treatment/ care products Fabric, textile, and leather products not covered elsewhere (clothing) Consumer Dermal Inhalation ¦/ Bystander Inhalation General Population Inhalation - Indoor Air Treatment products Water treatment products Consumer Dermal Inhalation Bystander Inhalation Treatment/ care products Laundry and dishwashing products Consumer Dermal ¦/ Inhalation Bystander Inhalation Construction, paint, electrical, Adhesives and sealants; paint and coatings Consumer Dermal Inhalation ¦/ ~ Bystander Inhalation Page 25 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Life Cycle Stage Consumer Use Category and metal products Subcategory Population"'' Exposure Route Human Health Effects' Acute Non-cancer Chronic Non- cancer 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 •/ 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 Y 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 ¦/ General Population Inhalation - Indoor Air Hobby products Arts, crafts, and hobby materials Consumer Dermal V Inhalation ~ Bystander Inhalation Packaging, paper, and plastic Ink, toner, and colorant products; photographic supplies Consumer Dermal V Inhalation ¦/ ~ Bystander Inhalation " Only inhalation exposure routes were assessed for Bystander. Page 26 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Life Human Health Effects' Cycle Stage Category Subcategory Population"'' Exposure Route Acute Non-cancer Chronic Non- cancer h 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. Page 27 of 28 ------- PUBLIC RELEASE - DO NOT CITE OR QUOTE March 2024 Page 28 of 28 ------- |